ML20113H711
| ML20113H711 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/30/1992 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NRC92-085, NRC92-85, VPNPD-92-271, NUDOCS 9208050196 | |
| Download: ML20113H711 (18) | |
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b Wisconsin.
1 Electnc POWER COMPANY.
- 231 w Mcvn Po nw toda wooo wd3201 M14)224 2Ms VPNPD-92-273 NRC-92-085-July 30, 1992 U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station P1-137 Washington, D. C.- 20555 Gentlemen: ,
K DOCKETS 50-266 AND 50-301 h: -IN-SERVICE TESTING-PUMP AND VALVE PROGRAM TilIRD 10-YEAR PROGRAM SAFETY EVALUATION REPORT POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Your letter dated April 17, 1992, transmitted a Safety Evaluation Report _(SER)_ completed by the Office of Nuclear Reactor
' Regulation and an-attached Technical Evaluation Report (TER) concerning_our-II.-Service Test (IST) Program, third 10-year interval. The purpose'of this letter is to address the IST Program relief requests which were denied in the SER and to '
comment'on those issues included 11n the SER and its cover letter that we believe warrant an immediate reply. As required in the L SER, we will respond to all items.in the " Anomalies and Actions P
Items" section of-the TER by April- 17,_1993. Additionally, in g the interim we expect-to provide. periodic updates'on issues addressed in the SER and TER as they are resolved.
Section 2.0.of'the SER addressed modifications associated with four systems: CVCS-charging, CVCS-boric acid transfer, ESF HVAC, L and compenent cooling water. _These systems and components were added: to our IST_ Program in ~ response to Generic Letter (GL)
L 89-04,1 " Guidance on Developing Acceptable In-Service Testing l
Programs."' In a letter dated April 22, 1991, we committed to
- examine these'four systems and' evaluate the actions necessary.to enable code required testing. We have evaluated the subject
" systems--and have initiated modifications to' facilitate the required-testing. The-SER-required that these modifications be completed during the next scheduled refueling outage for each unit (fall-1992 Unit-2 outage and spring 1993 Unit 1 outage).
The sta as of the subject modifications are as follows:
- 1. - The CVC charging system is-fully testable in accordance with ot IST Program. . There is no need to modify this system.- Wefhave issued test procedures which fulfill the ,
requirements of the IST Program.
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- I Document Control Desk July 30, 1992 Page 2 4
- 2. Modifications to the CVCS-boric acid transfer system have been initiated. Wluan complete, these modifications will enable us to obtain pump vibration data, required pump pressures, and pump f3ow rates. Pump Relief Request PRR-11,
" Boric Acid Transfer Pumos," (interim relief granted for one year) and PRR-12, " Boric Acid Transfer Pumps," (relief denied), which are addressed in TER Sections 2.5.1, 2.5.2, and 5.9, had been written to account for lack of instrumentation associated with the boric acid transfer pumps. These relief.regtests will not be required once the planned modifications have been completed. Additionally, Valve Relief-Request VRR-26, " Boric Acid Transfer Pumps Discharge check Valves," (open item), addressed in TER~
Sections 3.3.5 and 5.27, will be withdrawn when modifications have-been completed, since flow rate instruments will lx3 available to allow full stroke testing of boric acid transfer pump discharge check valves (1 and 2 CV-333-A and B). >
We are planning to complete those boric acid system modifications during the fall 1992 Unit 2 outage (currently scheduled to end on November 11, 1992) and the spring 1993 Unit 1 outage'(scheduled to end on May 19, 1993), as l_
required in the'SER.
Because Valve Relief-Request VRR-26 has been designated as an "open item" in the SER, we' request that you grant interim relief for VRR-26, until the subject boric acid system '
modif3 cations have been completed. Additionally, in Item B i below, we have requested that you grant interim relief for Pump Relief Request PRR-12 until the subject boric acid system modifications-have been completed.
We are currently pursuing a study to determine whether or not the charging ' pumps, without the uaa of the boric acid transfer' pumps, can add-sufficient boron to the' reactor coolant system to place _the reactor in a shutdown condition.
The. charging pumps would-take suction directly from the-refueling water storage tank. If we determine that the-boric acid transfer pumps are not required to shutdown the l plant, we may pursue elimination of the boric acid system L testing from the IST program. We will notify you if the study is successful and if we wish to pursue removal of the boric acid system. testing from the IST program.
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Document Control Desk July 30, 1992 Page 3 )
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- 3. Modifications to the ESF HVAC. system have been initiated to improve the testability of components in that system. After these modifications are completed, Pump Relief Request PRR-15, " Cable. Spreading Room Chilled Water Pumps and control Room Chilled Water Pumps," (interim relief granted for one year), addressed in TER Sections 2.7.1 and 5.11, will be withdrawn, since flow rate instrumentation will be installed for chill water pumps (P-111 A and B and P-112 A and B).
Additionally, VRR-31, " Chilled Water Pump's Discharge check Valves" (relief granted), addressed in TER Sections 3.2.1 and 5.11, will-be withdrawn, since the instrumentation to be i
installed _will permit full flow testing of chill water pump discharge check valves (HV-898A, HV-900A, HV-914A, and ,
HV-916A).
These modifications are not specific to either PBNP Unit 1 or Unit 2 and do not neci to be installed during an outage condition. The modification completion dates required in the SER, however, are unit-specific and coincide with the completion of the. fall 1992 and spring 1993 refueling outages. We have determined that these modifications are best performed during the cooler months of fall ano early winter when the impact of removing air conditioning from I
service is diminished. Consequently, we will complete the subject modifications by December 31, 1992. because these modifications are not unit-specific, we believe that this cchedule complies with the intent of the schedular requirements contained in the SER.
- 4. Modifications to the component cooling water system are in r progress to allow all required valves to be leak tested.
These modifications will be completed by the end of the fall 1992 Unit 2 refueling outage.-
Relief requests included in our IST Program have been denied, or
= denied in part, by the SER. The SER cover letter stated that for i
. relief' requests that have been denied, testing should-comply with I the Code requirements or. Generic Letter 89-04 guidelines within l
the first quarter-after receipt of the SER. Each of the denied L relief requeste is discussed below:
i A. Relief Request PRR-5,'" Auxiliary Feedwater Pumps," was
-formally withdrawn in our letter to the NRC dated March 24,
.1992.
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Document Control Desk July 30, 1992 Page 4 B. Relief Request PRR-12, " Boric Acid Transfer Pumps," (TER Sections 2.5.2 and 5,9) is addressed above in Item 2.
Physical modifications are required to conduct full Code-required testing of this system; consequently, full Code-required testing will not be conducted on this system within the next quarter, as required by the SER. The pumps, however, will continue to be test run on a quarterly basis until instrumentation is installed. We are requesting that you grant interim relief for relief request PRR-12 until the subject modifications are completed. Ac noted above in Item 2, these modifications will be completed durir.g the fall 1992 Unit 2 outage and the spring 1993 Unit 1 outage. Pump Relief Request PRR-12 will be withdrawn during the second quarter of 1993, after completion of the subject modifications.
C. Relief Request VRR-4, " Safety Injection and Safety Injection Accumulator Check Valves," has been revised and is enclosed for NRC review (Enclosure 1). Section 4.0 of the SER requested additional justification of valve grouping i'or the eight valves identified in that relief request. Although the SI-00a67 A and B valves are exposed to reactor coolant system (RCS) pressure (while the SI-00842 A and B valves typically are not exposed to RCS pressure), all of these valves are designed for the same service conditions.
Additionally, those valves are all identical in size, installation orientation, and manufacturer's design. Other concerns raised in SER Section 4.0 regarding maintenance history and future inspection scheduling are addressed in the revised relief request.
In-service testing of these valves will be scheduled, as necessary, upon NRC approval of our revised relief request.
In SER Section 4.0 and in several other sections of the SER and TER, the NRC recommends examination of non-intrusive methods for monitoring check valve performance. We are presently examining several non-intrusive test methods for various check valve applications but have yet to identify any method that we believe is suitable to our needs.
D. Relief Request VRR-5, " Valves Tested During Cold Shutdowns,"
which is addt;ssed in TER Sections 3.17.1 and 5.38, was approved by the SER for those valves which are able to be tested during any cold shutdow.. conditian but denied for those valves "...that_cannot be tested during any cold shutdown of sufficient duration to complete cold shutdown l
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Documcic Control Desk July 30, 1992 Page testing." As discussed in VRR-5, for IST scheduling during short duration cold shutdowns we will utilize the criteria contained in ASME/ ANSI OMa-1988, Part 10, "In-Service Testing of Valves in Light-Water Reactor Power Plants;"
Section 4.2.1.2.(o), " Exercising Requirements," which states that "if exercising is not practicable during operation or cold shutdowns, it may be limited to full-stroke testing during refueling outages." ,
E. Relief Request VRR-23, " Containment Isolation Valves," was identified as inadequate as originally submitted for NRC review. The relief request did not specify all of the valves for which relief was sought, and the alternate method of testing was not sufficiently described. The relief request has been revised to correct these deficiencies and is enclosed for NRC review (Enclosure 2). The alternate tes'.ing method described in the revised relief request is conservative and does not allow excessive leakage through ,
any one valve to go undetected.
In-norvice testing of these valves will be scheduled, as necessary, upon NRC approval of our revised relief request. ,
i F. Relief Request VRR-28, " Auxiliary Feedwater Pump Minimum Flow Valves," sought relief from measuring the full-stroke time of auxiliary feedwater (AF) pump minimum flow valves AF-4002 (Unita 1&2), AF-4007 (common), and AF-4014 (common).
Please note that in TER Sections 3.1.1 and 5.24, the recommended relief denial was based on the determination that the valves can be full-stroked exercised during cold shutdown testing. Air-operated stroke time tests are ,
currently not possible,-however, because the only means to 1 manually test these valves is with a manual handwheel, which dcas not permit a valid time stroke test. Additionally, the fail-safe test for these valves is not performed in a trafitional sence. Pr.9_ fail-safe test is performed during AP pump _ operation in apD n the valves are observed to return to the shut position ait y opening during pump start. Under ordinary conditions with the AF pumps in standby, the normal position for these valves is the same as their fail-safe position, which is shut. Consequently, a traditional fail-safe test is not required. The IST program'will be revised to reflect this fact by December 11, 1992.
l A modification reques has been initiated to change the configuration of the system to allow for a manual stroke of thu valves using air. When this is completed, procedures
m i Document Control Desk July 30, 1992 Page 6 will be implenented which require stroke time testing of the valves at the frequency required by ASME,Section XI. At that time, VRR-28 will be withdrawn. This modification is currently scheduled for completion during the fall 1992 Unit 2_ outage and the spring 1993 Unit 3 outage. This schedule compiles with the schedule established in the SER for other modifications.
TER Section 5.25 states that the IST Program should be revised to address the AF minimum flow valves safety function in the open direction. Since the AF pumps are capable of delivering feedwater at-any steam generator pressure, the minimum flow valves are not required to open
[ to protect the AF pumps under any-anticipated accident
[
' conditions. The valves will, nevertheless, be stroke time tested in the open direction, as well as in the shut ,
direction, once the modification to permit stroke time testing is completed.
Modifications are required to conduct Code-required testing of these valves. Consequently, this testing will not be implemented until these modifications are complete. We are requesting that you grant interim relief for relief request VRR-28 until the subject modifications are completed.
VRR-28 will be withdrawn during the second quarter of 1993 after completion of the subject modifications.
G. Relief-Request VRR-34, " Post-Accident Containment Vent Isolation Valves," which sought an extension of-the test +
frequency of post-accident containment vent manual valves, is_ formally withdrawn. Post-accident containment manual vent valves will be stroke tested during each cold shutdown.
The justification for this frequency is contained in Cold Shutdown' Justification (CSJ) 33 (Erclosure 3).
'H. Because we have completed modifications to 2 residual heat removal (RHR), containment spray (CS), and safety injection (SI) systems, we are now'able to formally .ithdraw several
. relief requests. We are withdrawing the following relief requests:
- a. PRR-3, " Safety Injection Pumps"
- b. PRR-4, " Residual Heat Removal Pumps"
- c. PRR-6, " Containment Spray Pumps"
Document' Control Desk July 30, 1992 Page 7 ,
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- d. VRR-6, " RWST to RilR Pumps Suction Check Valves"
- e. VRR-7, " Safety Injection Pump's Discharge Check Valves" VRR-8, " Refueling Water Storage Tan- to Containment f.
Spray _ Pumps Suction Check Valves"
- g. VRR-9, " Containment Spray Nozzles' Supply Check Valves" The-SER cover letter also-requested that we submit a description of the process used in developing our IST Program. This description is enclosed (Enclosure 4).
If there are any questions regarding this matter, please do not hesitate to contact us.
Sincerely,
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- )
Bob Link Vice President Nuclear Power Enclosures L
l Copies to NRC Regional Administrator, Region III NRC Resident Inspector Adele DiBiasio, Brookhaven National Laboratory l
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Enclocuro 1 RELIEF REQUEST NO. VRR-4 EYSIIHL Safety Injection (1?OE017, Sh 1/110E035, Sh 1)
QQME9NENTSt SI-00842 A&B (Units 1&2)
SI-00867 A&B (Units 1&2)
CATEGO.R t A/C FUNCTION:
These valves open with differential pressure to provide flow paths from the safety injection (SI) pumps and SI accumulators to the reactor coolant system (RCS) cold legs during an accident.
They are normally closed. In the closed position, they serve as RCS pressure isolation valves.
HECTION_.XI REQUIREMEHIl l
l Check valves shall be exercised at least once every three months, except as provided by IWV-3522. (IWV-3521) l BASIS FOR REkI.EE1 During normal operation, neither SI pump discharge pressure of 1500 psi nor SI accumulator pressure of 760 psig is sufficient to overcome RCS pressure. Full or partial stroke tenting is, therefore, not possible.
During cold shutdown, partial or full stroke testing via the use of SI pumps or SI accumulators is not permitted so as to prevent the possibility of r low-temperatare over-pressurization event.
A full stroke test to the RCS could be possible during refueling when the reactor vessel head is removed, but the volume and flow rate required for the test could result in damage to the core internals. There is also the potential of forcing a nitrogen bubble into the RCS piping and refueling cavity resulting in possible safety implications, which makes this testing concept inadvisable.
BLTERFATE TESTING The following alternate testing will be performed:
- 1. At a minimum for these valves, partial open and shut stroke tests will be done at each refueling outage. In addition,
, partial open and shut stroke tests will be conducted at each
! cold shutdown which requ'a s an Event V test. (See Technical Specification .L 3.16.)
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- 2. Seat leakage tests of SI-00867 A and B will be performed in accordance with Point Beach Technical Specification 15.3.16,
" Reactor Coolant System Pressure Isolation Valve Leakage l Tests."
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Page 1 of 3 l
Enclosuro 1 m
RELIEF REQUEST NO. VRR-4 (continued)
- 3. Seat leakage tests of SI-00842 A&B will be performed guarterly coincident with SI pump tests. A seat leakage
]*wd rate of five gpm or less will be considered acceptable.
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- 4. Valves SI-00842A nnd SI-008G';A will er.h be disassembled, inspected, and amiually stroked once every six years, rotating the sequance of valves being inspected such that a different one is completed each fme until all have been y<, inspected and the sequence repea*s. Should a failure be
!& detected, the other valve for thhc unit shall be
- h. -
disassemoled and preget operation verified prior to corepletion of that outage. The opposito unit'r two valves _
will be dit e ssembled and inspected durina that unit's next a scheduled refueling outage.
- 5. Valves SI~90842B and SI-00867B require a complete corc offlosd in order to disassemble and inspect. One .alve of the four will be disassembled, inspected, and manually
.. stroked each outage in which a complete core offload is uneduled. Typically this vill be done concurrently with
.cactor vessel inspections. The disassembly schedule will be arranged such that a different valvo is disassembled, inspected, and manually stroked during each core offload and all valves are completed at least once every 120 months.
Should a failure be detected, the other valve for that unit will be disassembled and proper operatian verified prior to t t4 completion of the outage.
- 6. In the inspections which result from the detection of a >
failure, should an additional failure be detected, all remaining six valves will be disassembled, inspected, and -
manually stroked. Valves associated with the unit in outage will be completed prior to the return of tha. unit to service, even if ic requires an unscheduled core offload to be performed. Valves associated with the opposite unit will be completed during the n.at scheduled refueling outage, : '
even if a complete core offload was not previously planned.
RARIS FOB _ EXTENDED INSPECTION INTERVAL:
The NRC, in Generic Letter (GL) 89-04, Positian 2, requested information to support extensior of valve disaeeambly' and inspectico intervals of greater than once every six years.
Within the last three years, each valve of the eight identified
'in this request has been disassembled, inspected, and manually stroked per the criteria in GL S9-04, Position 2. This maintenance was performed in conjunction with retaining block stud replacement done in response to NRC Information Notice 88-05. m o date, no degradation of valve operability or performance has been noted in any disassembly and inspection Page 2 of 3 l
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4 Enclosuro 1 l
, 1 RELIEP REQUEST NO. VRR-4 (Continued) s performed on these valves. The following table lists each specific valvo, the individual maintenance work request-(MWR)
'under which the inspection was performed, and the completion date:
UNIT 1 SI-00842A MWR 872759 April 14, 1988 MWR 890172 April 13, 1990 GI-00842B NWR 89017A April 21, 1990 SI-00867A MWR 87275a April 15, 1988 MWR 890175 April 24, 1990 SI-00867B MWR 890178 April 21, 1940 UNIT 2 SI-00842A MWR 872760 October 18, 1987 MWR 890173 October 05, 1989 SI-00842B MWR 890175 November 04, 1989
~SI-00867A MWR 872753 Cctober 20, 1987 MWR 890177 October 05, 1989 SI-00867B MWR 890179 November 03, 1989
- The; request to provide the basis for an extended inspection interval only applies to SI-00842B and SI-00867E, as these are
.the only valves which will go beyond the six-year period specified in GL 89-04,- Position 2. The maintenance history of all eight valves is provided for completeness to show the trouble-free history of the. valves in general.
Additional dustification_for the extended inspection-interval may be found in the NRC Safety Evaluation Report (SER) o- the In-Service Test _ Program at Point Beach dated April 17, 1992. The Technical Evaluation Report-(TER), section 3.14.3.4, attached to the SER states, " ...it would be an extreme hardship to require the licensee to comply with the six-year inspection. interval for theEtwo-valves which require the-reactor to be de-fueled and dt 3ned in order to-be tested (SI-00842B)."
L The drawings referenced by this request will show that the conditions which must exist to permit ;ae disasserably of LSI-00842B must also exist to permit the disassembly of SI-00867B.
-Thus, the extended period-for inspection should apply to both '
(four vrives total, two per unit).
STATUS Relief-granted with } ovisions per NRC SEF of 4/17/92. Request revised as this submictal for NRC review 7/92.
Page 3 of 3
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Unclosuro 2
=RELIEFLREQUEST NO. 7RR-23 RXRIEH1 Primary' Containment 1
GQMEONENTS - Containment Isolation Valves per Table VRR-23-1 CATEGORY : A or-A/C PUNCTION These valves are closed to provide containment isolation.
RECTION II' REQUIREMENT' Category A valves shall ba leak testt , except that valves which function in.the course of plant operation in a manner that demonstrates functionally adequate seat tightness need not be tested._ In such cases, the valve record shall provide the basis for:the conclusion that operational observations constitute '
satisfactory. demonstration. Valve seat leakage shall be determined per lWV-3424 and analyzed per IWV-3426.
(IWV-3421, IWV-3424, IWV-3426, and NRC GL 89-04, Position 10)
DASIS FOR_RELIMEL Due'to the configuration of system piping and components, in many cases individual leakage rate tests are impractical or impossible.- In.these cases, it is customary to perform tests of valves-in parallel. This. concept of testing and evaluation is
' consistent with_the intent of 10 CFR 50, Appendix J,_and Section
- XI, IWV-3424 (b) , which per nits leakage testing by_ measurement of feed rate required to' maintain pres!ntre between two valves. This method of testing is valid as-long as the leakage measured is charged entirely _to each? valve being tested.
.In-practi v,: the11eakage rate' limit assigned to a set of valves tested in parallel-is never greater than the leakage rate limit E 'which would be assigned:to the most limiting valve in the~ set if
~it wereito-be.testedlalone. -Herce, the practice of leakage-rate testing valves'in-parollel'is at least'ac> conservative as the leakage rate testing required per Section XI. ~ Additionally, when leakage rates. exceed the limit specified for a set of valves, testing will be-done to determine individual valve leakage rates wherever: possible- to f acilitate corrective maintenance efforts.
- This method-of testing valvestin parallel saves time, manpower-resources,.and radiation exposure and is a safe and viable J = alternative ~toileakage rate testing each
- valve Individually.
ALTERNATE TESTINGt l In thoseLcases where testing individual valves is impractical or E impossible, valves will ta leak rate tested simultaneously in multiple valve ~ arrangements. A maximum permissible leakage rate Page 1 of 2
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EncicGuro 2 RELIEF REQUEST No. VRR-23 (Continued) will be applied to each combination of valves; and, in no case, will this limit exceed the limit which would be applied to the most limiting valve in the set if it were to be tested individually. If the limit for a set of valves tested in parallal should be exceeded, the test lineup will be modified wherever possible to determine individual valve leakage rates.
ETATM11 This relief request was originally submitted with the IST Program, Revision 1, dated May 28, 1991. NRC SER dated April 17, 1992, approved only part of Ohls request. Request revised as this submittal for NRC' review 7/92.
BBkE VRR-23-J MAIXM YAkVE Auxiliary Steam HV-632 (Unit 1) HV-633 (Unit 1) !)
HV-808 (Unit 1) HV-809 (Unit 1)
HV-818 (Unft 1) HV-263 (Unit 2)
HV-286 (Unit 2) HV-287 (Unit 2)
Hv-636 (Unit 2) HV-G37 (Unit 2)
Chemical & Volume CV-3238 (Units 1&2)
Control CV-394B (Units 1&2)
Component Cooling Water CC-755 A&B (Units 1&2)
CC-759 A&B (Units 1&2)
Containment Spray SI-862 A&B&G&H (Unita 1&2)
SI-864 A&B (Unita 1&2)
SI-868 A&B (Units 1&2) _
Heating & Ventilation VNPSE-3212 (Unita 1&2)
VNPSE-3213 (Units 1&2) ,
VNPSE-3244 (Units 1&2) ,
VNPSE-3245 (Units 1&2)
Instrument Air IA-1182 (Unit 1) IA-1184 (Unit 1)
IA-1314 (Unit 2) IA-1316 (Unit 2)
Post-Accident containment U2-V-04 (Units 1&2) H2-V-05 (Unita 1&2)
Vent /Honitoring H2-V-06 (Units 1&2) H2-V-07 (Units 1&2)
H2-V-12 (Unita 1&2) H2-V-13 (Units 1&2)
H2-V-19 (Units 1&2) H2 -V-20 (Units 1&2)
H2-V-22 (Units 1&2) H2-V-23 (Units 1&2)
Waste Disposal SF-816 (Units 1&2) WL-1698 (Units 1&2)
WL-1723 (Units 1&2) WL-1728 (Units 1&2)
WL-1003 A&B (Units 1&2)
Page 2 of 2
1 Enclocuro 3 COLD BHUTDOWN JUSTIFICATIOt: CBJ-33 Post-Accident Containment Vent Manual Valves H2-V-04 (Units 1&2) H2-V-05 (Units 1&2)
H2-V-12 (Units 1&2) H2-V-13 (Units 1&2)
H2-V-19 (Units 1&2) H2-V-20 (Units 1&2)
H2-V-22 (Ultits 1&2) H2-V-23 (Units 1&2)
Excrcising these valves to the OPEN position at any time _other tlian cold shutdown constitutes a violation of reactor containment integrity as discussed in Technical Specification 15.3.6 A (a).
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-._ l Encl 0Duro 4- ,
DEVELOPMENT OF THE IN-SERVICE TEST PROGRAN-
.. AT 1 POINT BEACH NUCLEAR PLANT: _l ihs third interval _ pump and' valve IST Program for Point Beach
- Nuclear Plant _was developed using the services of a contractor familiar with:this type of work'in conjunction with plant l personnel.
- The contractor was Technical Services for Energy. Technical
.Servicesifor Energy has extensivo experience in the.IST field and has prepared in-services inspection and testing progr ams for several-nuclear plants.
1The~ general code requirements were__ applied to Point Beacn Plant i using'a systemctic approach by first reviewing the function of
- each of the= plant _ systems as it relates to a limited number of bounding accident scenarios. One major deviation with the general-code requirements was made because the Point Beach Plants are' licensed for safe shutdown and not expressly cold shutdown; the requirementLto support achievement of cold shutdown without a LOCA~was not addressed. -The review eliminated systems (and associated components) .that did not fit the basic code definitions-including that of_IST boundary classification.
Next,za' series:of rules or guidelines was developed that
~ established the: criteria to be used during the review of the remaining systems and-components.- These rules established policiescandl assumptions to assure consistency during reviews.
The guidelines are outlined in' Attachment'1. From this point, in
- a series--of steps, each of the-individual components in each of the remaining significant1 safety systems (and supporting systems)
- was evaluated with respect to the function-of each component and 1the need for ita_ operability as it-relates to the scope of
- Section XI.: TheseEsteps included:
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l'. :A review'of flow diagrams-of each system;and identification of any components _(pumps.or, valves) that "could" poter.tially y Lbe . included in the program.scopa.- Based on theLreviewer's l experience,. valves used-for maintenance isolation, vents, ,
-drains, etc., were excluded. Typically, all pumps, power- .
operated valves, check: valves, and safety valves remained in
=the. population designated for further evaluation.
2.- Each system'was broken down_by component. Based on general system operational requirements, a. narrative description of each system's_ components' safety function (s) during propcsed cscenariosiwas drafted.
' 3. Sequr'tially, plant documents that refer to or discuss safe -related component or system functions were reviewed
. in ; detail . -- Information from these documents was compared to the1 drafts. developed in'the paragraph labove. Where Page-1 of 2-
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Enclocuro'4' DEVELOPMENT OF THE IN-8ERVICE TEST PROGRAM
..AT-POINT BEACM NUCLEAR PLANT (Continued).
appropriate,1 corrections and references were applied to the s individual narratives. Documents reviewed 2ncluded the following:.
- a. -Updated Final Safety Analysis Report b.- Technical Specifications
- c. . Plant System Description (Training) Documents d.--Special-Analyses (i.e., HELB, etc.)
- e. Commitment Correspordence, including GL 89-04 and
. response support documents
- f. Plant Opersting Procedures ,
- g. Emergency Operating Procedures
- h. Appendix J Leakrate Test Program
- 4. . Based.on the finalized component Fafety function OValuation
- derived'from the document revie.v and the corrected narrntives, the program testing requirements were then established by applying the rules (Attachment-1 guidelines)
-to each case.
- 5.' The functional descriptionsLof the system components were subjected;to a comprehensive-review by knowledgeable plant 1
- personnel to. confirm the. accuracy of the document.
The. product-of_the process was the IST Program document itself. .The IST Program document is a collection of appendices.containing valve and: pump' listings with test
' requirements, relief requests, and cold shutdown.
l justifications.; A1second document which 5as prepared is a background document.. This document is a collection of system-based appendices. . Each appendix contains the 1 components that wereiconsidered.during the evaluation. -For each component, there is a narrative summary of function and test requirements.
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>^N .
Attachnent 1-to Enclocure 4 y
g P" GUIDELINES FOR IST PROGRAM DEVELOPMENT =!
ASME Section IX requires testing of those pumps and valves that )
. perform _a-specific.functiottin shutting down the reactor, H including cooldown to cold shutdown, or in. mitigating the consequences of an accident. In=this regard, the following guidelines are set'forth for evaluation.of. system components (pumps 1and valves) with respect to their inclusion in the Point Beach IST Program and to what extent testing will be performed.
, l. .
Where multiple components are capable of performing the same -l equivalent and redundant specified funce'_on (e.g., multiple valves closing in series) and where'the components are not supplied by! alternate and~ redundant power supplies, only one !
need be-included in;the program. The component must be relied uR2D.to perform and not simply have the capability of performance. This exemption only-applies where licensing documents do not take credit'for the designed redundancy.
Components-performing-redundant functions shall be included in the testing program if, in-the process of analysis or
-licensing justification, they are relied upon to be operable.
2 '. , :The Point Beach FSAR and related-design basis documents
=shallibe the primary refarences for determining which
.ccmponentc are required to. perform specified-functions related to the spectrum of predicated accidents. Although several other plant; source, documents (Tech Specs, EOPs)
' identify various; components that may be important to plant
!' safetyfor that are to be operated in conjunction with h recovery fromt an accident, unless specific credit is taken tinLthe-plant' safety analysis (or is implied in the analysis) c -for_aipump or' valve, the component need not be included in the IST' Program. . Anfexception to this-are those cases.where ,
ithe:NRC-imposes. test' requirements-at,their. discretion.
l- . .
E L3. Valves---installed primarily for the' purpose-of providing convenient operational' flexibility 1(e.g., system' cross-
-connects) but which wouldLnot be required to operate I -assuming:that.the= designated first-line systems and T compor.ents- operate' satisfactorily need not be included in
- the program.- .Thi s does not exclud e act i va valves that could f -be called upon;-as a result of optional system lineups
- existing priorLtolthe: initiation of an accident.
! =4. , Valves:that are actuated as a resu]t of a safety system:
automatic response shall be includcl in-the program to the
-extentethat-the testing shall' verify. valve operation required L as'a result of the safety system input. This
- applies only lf valve movement-is required-to support those L,
- functions required:as specified by the code. This requirement' extends only to testing defined by the code and
' is not~ intended to. imply the need-for verifying a valve's
-response 'tolautomaticologic~cystem output. ,
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AttcchmOnt 1 to Enclocuro 4
~
GUIDELINES FOR IST PROGRAM DEVELOPMENT (Continued) 5.- Valves whose sole function in to provide system or component l
' redundancy related to failure of passive components need not j be included if a set of all of the active components (pumps i and valves) needed to fulfill the specified system (train) function-are tested - double or unrelated simultaneous failures need not be assumed. In some cases where protection of crit'. cal systems from passive failures is a commitment, then 4mnents providing the redundancy or isolation of fai ~: components are included in the testing program.
- 6. System safety / relief valves shall be included except where the function of the valve is solely to provide overpressur.:
protection of an isolated component due to thermal expansion of the internally contained fluid or a valve is installed only as response to construction code requirements. In the case of safety / relief valves installed on process lines that penetrate primary containment and could be isolated during an accident, _if an overpressure condition could be created within the piping at the penetration such that the structural integrity of the containment could be jeopardized, than the valve should be setpoint tested.
- 7. All valves included in the Point Beach leakrate testing program complying with 10 CFR 50, Appendix J shall be included-in the program as Category A valver.
- 8. Any active Category A valve shall be designated for testing (exercising) to the closed direction.
- 9. When a valve's normal position during operation is its position required to perform its designated safety function and-valve movement may be required due to plant evolutions or possible repositioning during accident response or recovery operations, then periodic exercising per the code is required ( i . e .~ , the valve cannot be considered passive).
- 10. Where an air-operated valve is provided with a simple air-pilot valve, the pilot valve need not-bc specifically included in the program provided that the testing performed on the main valve verifies the proper operation of the pilot valve.
- 11. Control valves are specifically excluded from testing per IWV-1200(a); however, if a control valve must change position to support a safety-related function and it has a fail-safe position, then it must be included in the program and tested to the extent practical. Steam turbine governor valves are considered to be an integral part of the turbine and, as such, are not included in the IST Program.
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AttachmOnt 1 to Enclocurc 4 GUIDELINES FOR IST PROGRAM DEVELOPMENT (continued)
- 12. Check valves are included where a valve serves as the only
_ effective: boundary lbetween piping associated with a necessary safety function and non-safety grade (non-seismic) piping. Failure of passive system components is assumed only for non-safety grade systems.
- 13. Where a valve performs a safety function in both directions (open and closed) exercising in both directions is required as described in Reference 1. For these power-operated valves, stroke time measurements in both directions would be required.
- 14. Pumps and valves whose only safety function is predicated on plant shutdown and recovery from a fire per commitments made as a result of 10 CFR 50, Appendix R are not included in the IST Program.
- 15. Pumps and valves that are not categorized as ISI Class 1, 2, or 3 need not be included in the IST program.
- 16. -Check valves that have a safety function to close should be evaluated with respect to categorization as Category A/C versus C with respect to tbn follcwing issues:
- a. Whecher the flow requirements for connected systems can be achieved with the maximum possible leakage through the check valve,
- b. The effect of any reduced system f'.ows resulting from the leakage on the performance of other systems and components.
- c. The consequences of loss of fluid from the system.
- d. The effect that backflow through a valve may have on
_ piping and components, such as the effcct of high temperature and thermal stresses,
- e. The radiological exposure to plant personnel and the public caused by the leak.
17._ The issues raised in Paragraph 16, above, are epplied to all boundary valves included in the diesel fuel oil system and selected valves in other critical systems.
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