ML20117J385
| ML20117J385 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/22/1996 |
| From: | Naslund C UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3421, NUDOCS 9609100304 | |
| Download: ML20117J385 (5) | |
Text
Callaway Plant g
Post Otisce Box 620 Fulton. Missoun 6*5251 Union
^"9""'
199' Eucenuc 323 l
U.
S.
Nuclear Regulatory Commission l
ATTN:
Document Control Desk i
Mail Station P1-137 Washington, D.
C.
20555-0001 ULNRC-3421 Gentlemen:
l CALLAWAY PLANT DOCKET NUMBER 50-483 l
INSERVICE INSPECTION PROGRAM PLEN
Reference:
ULNRC-3377 dated May 22, 1996 This letter transmits a revision to Relief Request EN-02 of Revision 15 of the Callaway Plant Pump and Valve Inservice Test (IST) Program.
The IST Program, which was transmitted by Reference 1, was developed to comply with the rules and regulations of 10CFR.50.55a and Section XI of the ASME Boiler and Pressure Code, 1989 Edition.
1 It was recently determined that valves ENV0003 and ENV0009, RWST to containment spray pump check valves, were not identified in the IST Program as requiring l
testing in the closed direction.
Relief Request EN-02 l
currently allows testing by disassembly using grouping l
to satisfy the full stroke open requirement.
As I
disassembly is permitted by the ASME Code to satisfy closed as well as open testing requirements, and grouping is authorized by Position 2 of Attachment 1 to Generic Letter 89-04, we believe we have the specific written relief from the Commission as required by 10CFn.50.55a (g) (6) (1) to implement this testing.
i In keeping within the guidance provided in NUREG 1482, i
" Guidelines for Inservice Testing at Nuclear Power Plants", submittal of complete program revisions need only be made once every cycle or every other cycle unless major changes occur.
For this reason, and to
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9609100304 960822 L
PDR ADOCK 05000483 f
P PDR g {
1
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l-l ULNRC-3421 Page 2 of 2 l
avoid introducing confusion during your review of the l
currently submitted Revision 15 of the IST plan, this relief request is submitted outside of a complete program revision.
Please substitute the enclosed l
pages into Revision 15 currently under review.
1 If you have any questions concerning this information, I
please contact us.
I l
l Sincerely, i
l
/
und i
C D.
Nasl nd Ianager, Nuclear Engineering l
l DSH/
Enclosures I
l l
}
i i
't i
1 l
1
~....
ULNRC-3421 cc:
T.
A.
Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N.
- Street, N.W.
Washington, D.C.
20037 l
I M.
H.
Fletcher Professional Nuclear Consulting, Inc.
19041 Raines Drive i
Derwood, MD 20855-2432 l
L.
Joe Callan Regional Administrator l
U.S.
Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive l
Suite 400 Arlington, TX 76011-8064 l
Senior Resident Inspector l
Callaway Resident Office U.S.
Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 l
l Kristine M. Thomas (2)
Office of Nuclear Reactor Regulation l
U.S.
Nuclear Regulatory Commission 1 White Flint, North, Mail Stop 13E16 11555 Rockville Pike Rockville, MD 20852-2738 Manager, Electric Department Missouri Public Service Commission I
P.O.
Box 360 l
Jefferson City, MO 65102 Ron Kucera Department of Natural Resources l
P.O.
Box 176 Jefferson City, MO 65102 Don Woodlan TU Electric 1601 Bryan Street Dallas, TX 75201-3411 Pat Nugent Pacific Gas & Electric j
Regulatory Services i
P.O.
Box 56 Avila Beach, CA 93424 i
l EN-02 i
RELIEF REQUEST VALVE:
ENV0003,9 CATEGORY:
C CLASS:
2 L
l FUNCTION:
Valves open to provide flow from the refueling water storage tank to the spray headers. Valves close to prevent backleakage to the RWST.
TEST REQUIREMENT:
Exercise chock valve (full stroke open and closed) to the position required to fulfill its function every 3 months.
l BASIS FOR RELIEF:
These valves cannot be full stroke exercised open since the only full fiow flowpath is to the spray headers which would result in spraying containment resulting in damage to lagging, non EQ electrical l
equipment, etc. These valves cannot be practically stroke tested closed, i
as plant design would require the installation of hoses and the use of a hydro pump or other plant equipment to serve as a pressure source.
Additionally, per NUREG-1482 response to question group #24, "If a l
valve performs a safety function in both the open and closed positions, however, the Code requires that the valve be exercised to the open position and then verified to close". As discussed above, since open testing of these valves is satisfied by disassembly on a reactor refueling frequency, the closure test requirement of these valves will be satisfied by disassembly on a reactor refueling frequency as well.
ALTERNATE TESTING:
ENV0003 and ENV0009 are Walworth Company Model 12-N-376-SP, 12 stainless steel check valves installed in a horizontal orientation that have the same service conditions as they are corresponding valves in the 'A' and 'B' trains of the Containment Spray System.
Exercise check valve (partial stroke) every 3 moriths. A different valve of this group will be disassembled, inspected, and manually full stroked at each refueling, until the entire group has been tested. If the full-stroke capability of the disassembled valve is in question, the remainder of the valves in this group will also be disassembled, inspected, and l
manually full stroked during the same refuel outage.
l 2
Page 48
CALLAWAY NUCLEAR PLANT INSERVICE TEST PROGRAM CONTAINMENT SPRAY SYSTEM (EN)
DRAWING M-22EN01 VALVE DESCRIPTION COOR ACT.
VLV VLV VLV TESTS SFTY ACTIVE RROR NOTES NUMBER TYPE CAT.
SIZE PERF/
FREQ.
PASSIVE JUST.
ENHV0001 CTMT RECIRC SMP TO CTMT SPRY PMP A G-7 MO GT B
12 FS/CS O/C ACTIVE EN4 HV PI/RF ENHV0006 CTMT SPRY PMP A DISCH HV G4 MO GT B
10 FS/Q O
ACTIVE PI/RF ENHV0007 CTMT RECIRC SMP TO CTMT SPRY PMP B B-7 MO GT B
12 FS/CS O/C ACI1VE EN4 i
HV PI/RF ENHV0012 CTMT SPRY PMP B DISCH HV B4 MO GT B
10 FS/Q O
ACTIVE Pl/RF ENV0002 CTMT SPRY ISO VLV ENCAP A OlJT G-7 SA CK C
12 FS/SD O
ACTIVE EN-1 CHECK ENV0003 RWST TO CTMT SPRY PMP A CHECK G-7 SA CK C
12 FS/SD O/C ACTIVE EN-2 PS/Q I
ENV0004 CTMT SPRY PMP A DISCH CHECK G-5 SA CK C
10 FS/SD O
ACTIVE EN-5 PS/Q ENV0008 CTMT SPRY ISO VLV ENCAP B OUT CHECK B-7 SA CK C
12 FS/SD O
ACTIVE EN-1 ENV0009 RWST TO CTMT SPRAY PMP B CHECK B-7 SA CK C
12 FS/SD O/C ACTIVE EN-2 i
PS/Q ENV0010 CTMT SPRY PMP B DISCH CHECK B-5 SA CK C
10 FS/SD O
ACTIVE EN-5 PS/Q Page 48