ML20116P041
| ML20116P041 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 11/17/1992 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-92-0446, W3F1-92-446, NUDOCS 9211240270 | |
| Download: ML20116P041 (5) | |
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7 [$1 R. F. Ourski W3F1-92-0446 l
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QA November 17, 1992 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
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Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-36 Intervice Testing UST) Plan - Pumps and Valves, Revision 7, Change 3 Gentlemen:
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Revision 7, Change 1 of the Waterford 3 Inservice Testing (IST) Plan -
Pumps and Valves was submitted to the NRC by Entergy Operations, Inc. via letter no. W3T1-91-0468, dated September 3,1991.
This letter provides, by attachment, a revised relief request in accordance with specific instructions contained in the staff's letter dated August 19, 1992, which addresses the relief requests submitted in Revision 7, Change 1 of the IST Plan.
Section 3.2 of the staff's safety evaluation contained a basis for the denial of relief request 3.1.62 for the high pressure safety injection pump discharge safety valves.
The revised relief request offers additional justification as to why these valves cannot'be tested in accordance with code frequency requirements for valves designated as performing a safety function in both the open and closed position.
Additional alternative testing is included to provide adequate verification of the required functions for these valves.
Given that the next quarterly surveillance is due to be performed in mid-January, Entergy Operations, Inc. respectfully request that this submittal be reviewed in an expeditious manner.
For your information, please note that Revision 7, Change 2 of the IST Plan was prepared but has not yet been implemented at Waterford 3, and therefore has not been submitted to the NRC.
?90004 9211240270 921117 PDR ADOCK 05000382 g, *l P
i Inservice Testing (IST) Plan - Pumps and Valves, l
Revisior, 7, Change 3 W3F1-92-0446 Page 2 November 17, 1992 If you have any questions concerning this submittal, please contact i
B.R. Loetzerich at (504) 739-6636.
Very truly yours, t.f b
cci J.L. Milhoan, NRC Region IV i
D.L. Wigginton, NRC-NRR R.B. McGehee i
N.S. Reynolds NRC Resident Inspectors Office t
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Inservice Testing (IST) Plan - Pumps and Valves, Revision 7, Change 3 1
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Entergy Operations Inc., Waterford 3 Revision 7
' Pump and valve Inservice Test Plan Change 3 1
4 3.1.62 Test Reauf remtD1 IWV 3521 requires that " check valves shall be exercised at i
1 east once every 3 months.
IWV-3522(a) requires that
" Valves.
. whose function is to prevent reversed flow shall be tested in a manner that proves that the disk travels to the saat promptly on cessation or reversal of flow."
Dasis for Relief These valves perform a safety function in both the open and closed positions.
As previously discussed in the Basis for Relief for Relief Request 3.1.14, the operability testing (full-stroke) of these check valves' open safety function can only be accomplished by directing full hPSI pump flow into the RCS, No other flow path exists which could achieve the required HPSI pump flow rate.
These valves cannot be full-stroke exercised during power operation because the HPSI pumps cannot overcome RCS pressure to provide flow into the RCS, Partial stroke exercising at power is possible through a flow path to the RWSP through a drain valve. H wever, the capacity of this flow path is insufficient to full stroke the subject check valves.
During cold shutdown, the RCS is on shutdown cooling (SDC).
Pressurizing the SDC system with full HPSI flow increases the possibility of low temperature, overpressure concerns.
Therefore, the required flow can only be achieved during refueling outages, when the Reactor Vessel head is removed.
Since these valves can only be. exercised to the full open position during each refueling outage, the requirement to verify that t'ae disk travel to the seat from the open position can only be performed during each. refueling outage.
,.6 (48.of 61) 202
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Entergy Operations Inc., Waterford 3 Revision 7
- Pump and Valve Inservice Test Plan Change 3 Alternate Testing These valves will be part-stroke exercised open and then verified to close quar *erly.
These valves will be full stroke exercised and then verified to close during each refueling outage.
Comments Approval for Relief Request 3.1.14 granted per NRC SEP dated February 7, 1989. Upon receipt of approval of this Relief Request, this comments ecction will be updated to identify the approval document.
Valves SI 207A SI-207B SI 207AB f
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