ML20133N093

Forwards Requests for Relief from ASME Code Requirements for Inservice Testing Program & Justifications for Request Covering Containment Spray Sys Valves CS-92,CS-94 & CS-53

ML20133N093
Person / Time
Site:	Maine Yankee
Issue date:	08/07/1985
From:	Whittier G Maine Yankee
To:	Butcher E Office of Nuclear Reactor Regulation
References
5894L-SEN, GDW-85-205, MN-85-139, NUDOCS 8508130368
Download: ML20133N093 (5)

Text

r' mamE sanHEE AmmmPm1/ERComPAlWe nuousra?ll0oTs"al (207) 623-3521 9

August 7, 1985 Mil-85-139 CDW-85-205 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. Edward J. Butcher, Jr.

Acting Branch Chief Operating Reactors Branch No. 3 '

Division of Licensing

References:

(a) License No. OPR-36 (Docket No. 50-309)

(b) MYAPCo Letter to USNRC dated August 8, 1983 (MN-83-165)

Subject:

Maine Yankee Inservice Testing Program Gentlemen:

In accordance with 10 CFR 50.55a(g), att1ched are several changes to the Maine Yankee Inservice Testing Program, Reference (b). Maine Yankee has determined that certain tests required by the 1980 Section XI of the ASif Code, Subsection IWP are impractical. Requests for relief from the code and Maine Yankee's basis for relief are attached.

We trust this information is satisfactory. Picase contact us should you have any questions.

Very truly yours, MAINE YANKEE ATOMIC POWER COM)ANY

$/U e fi fy G. D. Whittler, Manager Nuclear Engineering & Licensing CDW/bjp Attachments (4 Pagos) cc: Dr. Thomas E. Murley Mr. Corne11us F. Holden q 0500130360 DH Ob0007 ADUCK 05000109

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c MAINE YANMEE ATOMIC POWEQ COMPANY VALVE RELIEF REQUEST CR-13 NLNBER: V-37 SYSTEM: Containment Spray VALVE: CS-92, CS-94 DRAWING NO: FM-32A/92A CATEGORY: C CLASS: 2 FUtCTION: Containment Suction Check Valves EXEM3T TEST: Q, Qp, C, Cp, R BASIS FOR RELIEF: Partial or full stroke exercising these valves during power operation or shutdowns would requir3 flooding containment sump to provide contairunent spray pump suction. Flooding the containment sump is impractical and could damage several plant components.

ALTERNATE TEST: (0) One valve will be disassembled and exercised every other refueling outage. If a degraded condition is found, the valve in the other train will be disassembled and tested. This method will ensure valve operability, reduce radiation exposure, testing costs, and general respirator work. Both of these valves were opened after nearly 10 years of service, and the valves exhibited no indication of wear.

5894L-SEN

, MAINE YANKEE ATOMIC POWER COMPANY VALVE RELIEF REQLEST CR-16 NUMBER: V-63 SYSTEM: Containment Spray VALVE: CS-53 ORAWING NO: FM-32A/92A CATEGORY: C CLASS: 2 FUNCTION: Recirculation Check Valve EXE WT TEST: Q BASIS FOR RELIEF: This valve is a six inch recirculation check valve. To full stroke test this valve, it would be necessary to align and operate four major safeguards pumps simultaneously.

Also, during an accident situation it would be highly unlikely that this valve would be recuired to go full open since recirculation is not required curing normal pump operation.

ALTERNATE TEST: (Qp) This valve shall be part stroked each month during routine pump testing.

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5894L-SEN _ _ _ _ _ _ _ - _ _ _ - _ -

, MAINE YANKEE ATOMIC POWER COMPANY CR-16 GENERIC RELIEF REQUEST ,

Justification for using a fixed reference value versus the results from the previous test for the basis of determining increased test frequencies.

CODE REQUIREPENT IWA-3417 states that if, for power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 seconds or 50% or more for valves with full-stroke times less than or equal to 10 seconds is observed, test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed.

RELIEF REQTST Relief is requested from the requirement to use the previous test results for the basis of increased test frequency. The use of a fixed reference value determined from the results from several previous tests would be used instead.

IMSIS FOR RELIEF Using a fixed reference value provides a more logical and stringent basis for determining increased test frequencies. Amering to the words of the code as stated above, a valve's stroke time could increase during each test and still be considered acceptable, while in fact, the valvo could be falling or, at least, worthy of being tested at an increased frequency.

Using a fixed reference value as a standard would give rise to an increased test frequency much sooner than the standard set forth in the words of the code.

Having a fixed reference value would provide a means for promptly identifying whether or not a valve is operating in the normal, alert, or inoperative range. The reference values with corresponding alert and inoperative values may be incorporated into plant surveillancq procedures which control valve testing, and therefore, would allow one to immediately assess whether or not a valve is operating satisfactorily.

ALTERNATE IMSTS FOR INCREASFO TEST FREQTPCIES If a fixed reference value is exceeded by either;

a. 2)4 or more for those reference values greater than 10 seconds, or

b. 50% or more for those reference values less than or equal to 10 seconds, Maine Yankee chall increase that frequency to once a month until the condition is corrected.

5094L-SEN

, M AINE YANKEE ATOMIC POWEQ COMPANY CR-18 KJMBER: P-5 SYSTEM: High Pressure Safety Injection Suction PUMP: P-14A, P-148, and P-14S CLASS: 2 TEST REQUIREMENTS: The pressure measurement instruments shall have a full-scaled rarige of three times the reference value or less.

BASIS FOR RELIEF: The Maine Yankee HPSI pumps are dual function pumps.

P-14A, B and S are normally used as charging pumps to the reactor coolant system and have a reference suction pressure of about 30 psig. Per Section XI, the required test pressure gauge should have a full scale range of no more than 0-90 psig. This narrow range would be insufficient for pressure measurement and may lead to instrument failure when the pumps function as HPSI pumps.

ALTERNATE TEST: The suction gauges used shall have a full-scale range of 0-120 psig, which should be sufficient to allow adequate pressure indication during an accident situation. By using pressure gauges with a wider range, the accuracy in measuring suction pressure will be decreased slightly.

However, since the pumps' discharge pressures are approximately 2500 psig, the values for differential pressure will not be significantly affected.

5894L-SCN

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