ML20127P548
| ML20127P548 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/07/1985 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Snyder B Office of Nuclear Reactor Regulation |
| References | |
| 0250A, 250A, 4410-85-L-0109, 4410-85-L-109, NUDOCS 8505240022 | |
| Download: ML20127P548 (7) | |
Text
S;plc - &n GPU Nuclear Corporation Nuclear
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s Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
(717) 948-8461 4410-85-L-0109 Document ID 0250A May 7, 1985 TMI Program Office Attn: Dr. B. J. Snyder Program Director US Nuclear Regulatory Commission Washington, DC 20555
Dear Dr. Snyder:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Relief Request from ISI Test Requirements for Category B and C Valves GPU Nuclear letter 4410-85-L-0058, dated April 9, 1984, transmitted a request for relief from the Inservice Inspection (ISI) test requirements for certain category B and C valves. Your letter, dated March 22, 1985, commented on this request. restates your comments and provides our responses.
Additionally, the attachments to our earlier letter, referenced above, have been revised accordingly and are enclosed as Attachment 2.
Sincerely,
/
F. R. Standerfer Vice President / Director, TMI-2 FRS/RDW/eml 8505240022 850507 PDR ADOCK 05000320 Attachment cc: Deputy Program Director - TMI Program Office, Dr. W. D. Travers
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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
p-ATTACINENT 1 (4410-85-L-0108)
$ Table I, Section A NRC COMMENT Table I, Section A identifies valves exempt from testing because they are in-systems out-of-service during_the recovery period. Several valves in the list are containment isolation valves and are identified as such in Procedure
'4301-M8, Containment Integrity Verification. Therefore the following valves should have been' identified as Category A valves:
MS-V-4A&B Main Steam Isolation Valve to Turbine MS-V-7A&B Main Steam Isolation Valve to Main Turbine MS-V-11A&B Main Steam to Emergency Feed Pump Turbine EF-V-33A&B Emergency Feed to OSTG's IC-V-2,3,4,5 Intermediate Closed Cooling Containment Isolations CF-V-114A&B Core Flood System Containment Isolations CF-V-144 Core Flood System Containment Isolations CF-V-145 Core Flood System Containment Isolations CF-V-146 Core Flood System Containment Isolations BS-V-1A&B Building Spray Containment Isolations BS-V-130A&B Building Spray Containment Isolations GPU' NUCLEAR RESPONSE GPU Nuclear concurs.with the above comment. Table I, Section A has been revised accordingly and is attached.
Table I, Section C: This section identifies valves which are in service, but perform no safety-related functions.
NRC COMENT MU-V-10.
This valve is in the Internals Indexing Fixture (IIF) processing flow stream and is manipulated by Procedure 2104-10.2. You should justify that this valve does not perform a safety-related function.
'GPU NUCLEAR RESPONSE
~
MU-V-10 is located in the main flow path of the IIF processing system, between the waste transfer pumps and the reactor vessel.
TMI-2 Operating Procedure 2104-10.2, " Primary Plant Operations in Drain Down Condition", requires MU-V-10 to be open for boration make-up using the waste transfer pumps.
0250A i
[
ATTACtfENT 1 (4410-85-L-0108)
Though MU-V-10 is located in a boration control flowpath, it is not required to fulfill a safety function. This is justified by:
Tre IIF processing system is not required for either emergency core cooling or baration control. These functions are currently performed by the Mini Decay Heat Removal System, the Standby Pressure Control System, Decay Heat Removal System and gravity feed from the Borated Water Storage Tank.
In the event _of a decrease in RCS level, MU-V-10 would be isolated by the closure of valves WDL-V40 (IIF supply flow) and FCC-V003 (IIF discharge flow). WDL-V40 and FCC-V003 automatically secure flow to and from the IIF in the event of high or low water in the IIF. The closure of valve FCC-V003 will in turn trip the IIF Processing Pump, DWS-P-1, thereby terminating system operation.
FCC-V003 is also provided with a spring loaded actuator which will cause this valve to fail close on loss of air or electricity; thus siphoning from the IIF is prevented. However, as stated in Appendix No. 2 to the Submerged Demineralizer System Technical Evaluation Report, should FCC-V003 remain open, suction would be broken 2 1/2 feet above the reactor vessel flange. Thus a sufficient inventory of reactor coolant for shielding and decay heat removal would remain.
Based on the above considerations, valves WDL-V40 and FCC-V003 are not required to be ISI tested.
NRC COMMENT HJ-V-439 This valve is identified as-containment isolation valve in Procedure 4301-M8. Verify th=c it does not perform a containment integrity function.
GPU NUCLEAR RESPONSE GPU Nuclear concurs with this comment. MU-V-439 is a containment isolation valve for the Reactor Coolant Pump Seal Supply line. Therefore, this valve has been deleted from Table I, Section C, and has been added to Table I, Section A.
NRC COMMENT DH-V-2 This valve is required to be open for RCS level indication which is a safety-related function. It is therefore miscategorized.
GPU NUCLEAR RESPONSE DH-V-2 has been red-tagged in the "open" position since the TMI-2 accident and is not required to be cycled in order to fulfill any safety-related function during the recovery period. Therefore, this valve is not miscategorized.
0250A
(*
ATTACHENT 1 m :j -
.(4410-85-L-0108)
NRC COMMENT RR-V-11A,B,C These valves are identified as containment' isolation valves in i Procedure 4301-M8. These valves perform the safety-related function (containment integrity) and should be identified as-Category A valves.
RR-V 'sA,B,C -
Same comment as above, Procedure 4301-M8 states that they-should be open under administrative controls.
- RR-V-60,0,E~
LSame comment as'above, Procedure 4301-M8-states.that "C" may' be open under administrative controls, "D"'may be open on an intermittent basis under administrative controls, and "E" should be'open under administrative' controls.
/
RR-V-250 Same comment as RR-V-5A,B,C.
GPU NUCLEAR RESPONSE GPU Nuclear concurs with the above comments. The above valves have been deleted from Table I, Section C, and have been added to Table I, Section A.:
Additionally,-RR-V-11D has also been deleted from Table I, Section C and added to Table I, Section-A since this valve performs the same function as RR-V-11A,B, and C.-
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ATTACHENT 2
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(4410-85-L-0108)
TABLE I-A.-
.' Valves in systems out of service during the recovery period'.
MS-R1 A&B RC-R1 A&B MS-R2 A&B RC-V1
.MS-R3 A&B' RC-V149 MS-R4 A&B IC-V100
'MS-R5 A&B IC-V147-MS-R6 A&B CF-V4 A&B MS-V3 A&B CF-V5 A&B MS-V12 A&B CF-V100 A&B MS-V14 BS-V4'A&B MS-V207 -
B9 V100 A&B
~FW-V18 A&B BS-V105 A&B CO-V81 A&B BS-V113 CO-V215 A&B PP-V110 A&B
~EF-V1 A&B EB-V6 EF-V2 EB-V7 EF-V11 A&B EB-V8 EF-V13 A&B EB-V9 EF-V26 EB-V10 EF-V27 A&Bi EF-V32 A&B-B.
" Category A" valves which are exempt from testing.
DW-V28 DC-V103 MS-V4 A&B SA-V20 DC-V115 MS-V7 A&B
.MU-V2 A&B NM-V52.
MS-V11 A&B MU-V16 A,B,C,D AH-V1 A&B EF-V33 A&B MU-V18 AH-V4 A&B IC-V2 MU-V25 AH-V5 IC-V3' MU-V161 A,B,C,D AH-V7 IC-V4
-MU-V376 AH-V52 IC-V5 MU-V377 AH-V60 CF-V114 A&B MU-V378 AH-V62 CF-V144 MU-V402 A,B,C,D AH-V72 CF-V145 SF-V105 AH-V81 CF-V146 WDL-V1092 AH-V90 A&B BS-Vll A&B WDL-V1125 AH-V101 BS-V1130 A&B WDG-Vl99 AH-V102 MU-V439 NS-V72 AH-V105 RR-Vll A,B,C,0
'NS-V81 AH-V107 RR-V5 A,B,C NS-V99
_AH-V120 A&B NS-V100-WDL-V1126' CA-V1 CA-V8 CA-V3 CA-V9 CA-V6 SV-V18 CA-V10 SV-V55
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2 TABLE I (continued)
(4410-85-L-0108)
C.
Valves in systems whidi are in service but are not required to perfone saf;ty related functions durirg j
recovery Valve Ms.
Explanation h v10 This valve was fommerly used for boron conta l.
It is in a line which ties in lines from the domineralized service water system, reactor coolant bleed tanks, the boric acid pumps, and the deborating danineralizers. Since baron control is now perfommed by the Stan@y Pressure Control (SPC) system, EV10 nood not i
be verified operable.
E V12 This is an outlet valve for make-tp tank 1A. The make-4p tank is no lonDer in j
use, and therefore this valve is not required to function.
l HY-V55 This valve is part of the hydrogen sLpply manifold to the seko-ap tank, thus j
the justification is the sans as for MJ-V12..
W-V28 asstification is the same as HY-V55.
l E V36 These valves are in a line from the malaHp (NJ) pump discharge header to the E V37 seal return coolers. The line is also a path for operating the W pumps on recirculation. The seal retum coolers are not required to be operable during recovery. Additionally, the breakers for the make-ap pumps are racked-out, thus the maleMp ptsups will not be operated durirg the recovery mode.
E V433 These valves are part of the discharge line from the W plups to the seal E V434 injection line. Seal injection is not utilized during recovery, therefore l
these valves are not required to be operable.
E V127 These valves are in a line from the boric acid system to the W system.
W-V325 Since boron control is performed by the SPC system, these velves serve no E V326 safety function.
DH-V1 These valves remain open durire the recovery period to allow Reactor Coolant System (RCS) pressure sensing and level indication. Additionally CH-V2 is a Dl-V2 containment isolation valve, and, like category "A" velves, is maintained according to the Recovery Technical Specifications.
l DH-V7A/B These valves may be opened to allas aD10gy-4:ack" operation of the W & Decay Heat Removal (DW) pumps (i.e., the OH system sLpplies water to the RCS through l
the W system) when the~ plant is at operatin0 pressure. During the recovery period, such operation is not required, therefore, DH-V7A/B serve no safety related function.
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r TMR.E I (continued)
(4410-85-L-0108)
Explanation Valve No.
i These are the suction check valves to the reactor building sesrgency canling W V46A/B pumps which are no longer in service. Therefore, there is no need to test these valves.
This valve is part of the E stpply to the intennodiate coolers which are no 1
I WV51 longer in service. Therefore, there is no need to test this valve.
i Since This is an isolation valve for the river water ptop house de-icinD line.
there is virhin11y no heat load in the plant, openig the do-icin0 line is not W V55 required. Therefore, there is no need to test this valve.
l This is the auction valve to the control huilding area east fan coil units.
the to the extremely los heat loads durinD recovery, the operation of this E V246 valve is not regAired.
These valms are associated with the leakage coolers (W L-C-1A/B) which ass not I
DC-V96A/B DC-V118A/B in operation during recovery.
l This valve is in a line between the recimimad boric acid pumpe and the horic acid six tank. Since the process of m'1 mining boric acid is not dono during W S-Vill i
recovery, there is no need to test this valve. This valve, homever, may be used later in the recovery period for transfer of miscellaneous waste to the l
boric acid mix tark at which time the testing of this valve will be j
r:-:-b=ted.
1 l
These are discharge valves for the reactor buildin0 energency cooling river RR-VIA/B/C/D The M System is no longer required to be operable water (RR) booster pump.
during recovery and has been reenved from the TMI-2 Technical Specification J.
l RR-V2A/8/C/D l
l l
These valves are located tgmtreme of the Reactor Building Nonnel Cooling This system operates to maintain a habitable environment in the Reactor RR-y6C/D/E Coils.
The original l
adiding, but is not required by the Technical Specifications.
i safety function of these vales was to open on an Engineered Safety Feature Since the ES system is out of service during the recovery period, (ES) signal.
these valves no longer serve a safety fasetion.
4 I
4-
.