ML20154Q388
| ML20154Q388 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/27/1988 |
| From: | Bailey J GEORGIA POWER CO., SOUTHERN COMPANY SERVICES, INC. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GN-1493, NUDOCS 8810030386 | |
| Download: ML20154Q388 (19) | |
Text
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Georg4 N*er Compay Pttst Offeo Dos 282
- Wwsborn Georg>a 30830 TeWee 404 554 9961 434 724 8114 Soutrern Cortcany Serv <es. Inc Nst Off.co Bom 262$
8 rmoras Alabama 35202 Vogtle Project wer,e 20s ""
September 27, 1988 United States Nuclear Regulatory Commission ATTN:
Document Control Desk Files X7BC35 Washington, D.C.
20555 Log GN-1493 PLANT VOOTLE - UNIT 2 NRC DOCKET NUMBER 50-425 CONSTRUCTION PERMIT NUMBER CPPR-109 INSERVICE TEST PROGRAM:
ISI-P-016, REVISION 1 Gentlemen:
We have enclosed ten (10) copies of the af fected pages for Revision 1 to the VEOP Inservice Test Program ISI-P-016 transmitted on March 25, 1988.
This revision is being made so that the Unit 2 program will remain consistent with the VEOP-1 Inservice Test Program changes which will be submitted for review in the near future.
Revision 1 contains two (2) relief requests (RR-26 and RR-
- 27) and one (1) cold shutdown justification (CS-39).
Relief Request 26 is "intentionally blank" (as is Unit 1) and Relief Request 27 pertains to valve leakage trending.
Cold Shutdown Justification 39 pertains to RHR valve HV-8804A.
If any additional information is required, please do not hesitate to contact me.
Sincerely,
.k*
J. A.
Bailey Project Licensing Manager JAB /sem xc NRC Regional Administrator J. B.
Hopkins (2)
NRC Resident Inspector G. Bockhold, Jr.
P. D. Rice J. E. Joiner Esquire J. P. Kane R. J. Goddard. Esquire R. A. Thomas R. W. McManus B. W.
Churchill, Esquire Vogtle Project File ge l of 8810030386 800927 P
ADOCK 05000425 i
g 4
PNU
Reviolon Insertion Instructions for Distribution of ISI-P-016, Rev. 1 Replace the following pages as provided:
Approval Page 1-2 1-3' 12-31 12-94 Add the following pages as provided:
13-26 13-27 14-39 4
A O
SOUTHERN COMPANY SERVICES INSPECTION, TESTING, AND ENGINEERING DEPARTMENT FOR GEORGIA POWER COMPANY ISI-P-016 INSERVICE TEST PROGRAM V0GTLE ELECTRIC GENERATING PLANT UNIT 2 SCS G3C O
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8-25-88 INCORPORATED RR-27 & CS-39 i
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Section XI requires quarterly testing of all components unless it is impractical to do so.
This program specifies quarterly testing of pumps and valves unless it has been determined that such testing would:
a.
Be impractical due to system or co nponent design.
b.
Render a safety-related system inoperable.
c.
Cause a reactor or turbine trip.
d.
Require significant deviations froa normal plant operations, e.
Require entry into inaccessible plar.t e.r e u s,
f.
Increase the possibility of an intersystem LOCA.
Each component excluded from quarterly testing has been analyzed to determine when appropriate testing may be performed.
If operation of a valve is not practical during plant operation, the code allows part-stroke exercising during normal plant operation and full-stroke exorcising at cold shutdown.
Since the Code accepts cold shutdown testing, this program does O
not request relief for those valves for which testing is delayed until cold shutdown.
The Program does provide a justification for delay of testing until cold shutdown.
These justifications are prepared ir. s format similar to relief requests, and are located behind the CoJd Shutdown Justification tab.
Where it has been determined that testing is not practical during plant operation, or at cold shutdown, a specific relief request has been prepared.
Each specific relief request provides justification for not performing the Code-specified tests, and provides appropriate alternative testing.
In addition to specific relief requests, general relist requests which address specific Code requirements found to be impractical for this site have been prepared.
Relief requests are 1ccated behind the Relief Requests tab.
The three general relief requests which have been written are RR-2, RR-3 and RR-27.
RR-2 requests relief from IWV-3417(b) and IWV-3523 which state that, when corrective action is required as a renuit of tests made during cold shutdown, the condition shall be corrected before startup.
Relief was requested to allow corrective action to be performed prior to the valve being required for plant operability as defined in the Plant Technical Specifications. Rh-3 requests relief from IWV-3417 for valves l
with stroke times of 2 seconds or less.
Relief was requested to ruquire the acceptance of the test to be based only on the stroke O
time limit and not the "50 percent" criterion in IWV-3417.
RR-27 requesta relief from IWV-3427(b) for all Catagory A and AC valves 0957n 1 2 016 REV 1
O 6 inch nominal diameter and larger.
Relief is requested from performing valve trending to determine seat degradation.
1.5 DEFINTIONS Terms below, when used in the Inservice Testing Program, are defined as followst Quarterly:
An interval of 92 days for testing components 1
which can be tested during normal plant operation.
cold Shutdown:
Testing scheduled for cold shutdown will commence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after entering cold shutdown.
Testing will continue until all tests are complete or the plant is ready to return to power.
Completion of all testing is not a prerequisite to return to power.
Testing not completed at one cold shutdown will be performed during subsequent cold shutdowns that may occur before the refueling outage.
In case of frequent cold shutdowns, valve testing will J
not be performed more often than once every 3 months.
The 48-hour interval need not hold for planned cold shutdowns when their duration is of 3
sufficient time to accomplish all shutdown l
testing.
Refueling.
Testing scheduled for refueling will be performed during the normal scheduled refueling shutdowns before returning to power operation.
O 0957n 1-3 016 REV 1
~~
O O
O VEGP Unit ho. 2 016 REV 1 Valve Test List Sotes:
tesidual heet assovel - System to. 1205 Sheet 1 of a Eeliet Wolve Act.
Eso, or valve
_{1 ass 08 6 -
51:e Act.
Position or
_ Tests _and_ Free. _
C.S.
Description h=m 151 %L LCsef.)
_. Ila.J Ire Ire met = !!!! 5 !".r fass C_"
t f]El SI _F5V LT M t, and notes a
FW 0610 2 212 2M00122 0
3.H GA NO O
Al C/C A
Y 0 0
M Pues (N-5)
P6-001 Riniflaw FW 0611 2 212 2M00122 0
3.00 GA NO 0
at 0/C A
Y0 0
M Pues (E-5)
P6-002 Riniflom HW 0716A 2 212 2M00122 0
0.00 GA NO O
Al C/C A
Y 0 0
M Train A (F-7)
Not Leg Isolation NW 07160 2 212 2M00122 0
0.M GA ND 0
At 0/C A
Y0 0
M Train I (D-7)
Not Leg Isolation NW00NA 2 212 2M00127 0
0.00 GA NO C
AI 0/C A
Y CS CS CS-M M heet (F-0) at-2 Enchanger n
(ME) Train A to CVCS Cheroe Puno Suction OMon 12-31
.. ~.
~ - - - - - - - - - -.
l
O NOTES 1.
Valves included in the Appendix J, Type C local leak rate test program.
The Appendix J, Type C requirements are implemented in lieu of paragraphs IWV-3421 through IWV-3425.
Leakage rate analysis and corrective actions as required by IWV-3426 and 3427(a) will be performed.
l 2.
This is a RCS pressure isolation valve and is leak rate tested per plant Technical specifications.
3.
These are Anchor-Darling testable check valves.
These valves have a manual operation lever.
4.
These valves perform a safety function in the open position.
These valves are normally open therefore testing from the closed to open position is unnecessary.
O 1
l l
O 0959n 12-94 016 Rev. 1
RELIEF REQUEST RR-26 THIS PAGE LEFT INTENTIONALLY BLANK 1
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0961n 13-26 016 Rev. 1
(}
RELIEF REQUEST RR-27 SYSTEM:
All VALVE (S):
All Category A and AC Containment Isolation Valves 6 in.
Nominal Diameter and Larger CATEGORY:
A. AC CLASS:
1 and 2 FUNCTION:
Containment Isolation TEST REQUIREMENT:
IWV-3427(b) requires that for valves 6 in. nominal pipe size and larger, if a leakage rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate by 50% or greater, the test frequency shall be doubled: the tests shall be scheduled to coincide with a cold shutdown until corrective action is taken, at which time the original test frequency shall be resumed.
If testa show a leakage rate increasing with time, O
and a projection based on three or more tests indicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate by greater than 10%. the valve shall be replaced or repaired.
BASIS FOR RELIEF:
IWV-3427(b) is apparently attempting to predict the failure of a valve based on gradual degradation that is of a trendable nature.
This would apply to a valve where the seat, internals, etc. are wearing at a measurable rate, wad the eventual failure of the valve could be predicted from successive leakage tests.
However, historical data at Plant Match. Plant Vogtle and other nuclear plants has demonstrated that. In general, valves do not exhibit gradually increasing leakage rates as implied by IWV-3427(b).
The two general patterns of behavior for valves ares (1) essentially constant leakage rates followed by sudden failure or (2) erratic test results which do not trend.
Therefore, trending as required by IWV-3427(b) does not serve any useful function.
O.
ALTERNATE TESTING:
Valves with leakage limits exceeding the allowable limits will be repaired or replaced per IWV-3427(al.
i t
i 0961n 13-27 016 Rev. 1 i
-s CS-39 SYSTEM:
Residual Heat Removal System No. 1205 VALVE (S):
1205-HV-8804A CATEGORY:
B CLASS' 2
FUNCTION:
This valve opens to allow flow from the RMST through the RNR Pumps to the centrifugal charging pumps during post-accident recirculation.
QUARTERLY TEST REQUIREMENT:
Exercise and time COLD SHUTDOWN TEST JUSTIFICATION:
Exercising this valve during normal operation could introduce refueling O
water into the RCS through the 5
normally operating charging pump.
RCS boron concentration could be adversely affected and could cause a plant shutdown.
QUARTERLY PARTIAL STROKE TESTING:
None COLD SHUTDOWN TESTING:
Exercise and time O
14-39 016 REV. 1
Revision Insertion Instructions for Distribution of ISI-P-016, Rev. 1 1
j Replace the following pages as provided:
I Approval Page i
1-2 1-3 J
12-31 12-94 l
Add the fo33owing pages as provided:
13-26 13-27 3
14-39 l
3 0
i i
i e
}
i t
l 1
l I
]
1, l
O SOUTHERN COMPANY SERVICES INSPECTION, TESTING, AND ENGINEERING DEPARTMENT FOR GEORGIA POWER COMPANY ISI P 016 INSERVICE TEST PROGRAM V0GTLE ELECTRIC GENERATING PLANT UNIT 2 i
SCS G3C O
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nev.
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ENG.
MGR.
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J-2-88 ISSUED FOR PST / IST 32.sg 3/2/rs 3g,ff g,.,
3/y4e j/;,/g
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3
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'912 W 4
g.gg g/[,,g 9/f3fgg 64 6 f/A/v 1
8-25-88 INCORPORATED RR-27 & CS-39 t
I
()
Section XI requires quarterly testing of all components unless it i
is impractical to do so.
This program specifies quarterly testing of pumps and valves unless it has been dotermined that auch testing would:
a.
Be impractical due to system or component design, b.
Render a safety-related system inoperable.
c.
Cause a reactor or turbine trip, d.
Require significant deviations from normal plant operations.
e.
Require entry into inaccessible plant areas.
f.
Increase the possibility of an intersystem LOCA.
Each component excluded from quarterly testing has been analyzed to determine when appropriate testing may be performed.
If operation of a valve is not practical during plant operation, the code allows part-stroke exercising during normal plant opera *41on and full-stroke exercising at cold shutdown.
Since the Code accepts cold shutdown testing, this program does O
not request relief for those valves for which testing is delayed until cold shutdown.
The Program does provide a justification for delay of testing until cold shutdown.
These justifications are prepared in a format similar to relief requests, and are located behind the Cold Shutdown Justification tab.
Where it has been determined that testing is not practical during plant operation, or at cold shutdown, a specific relief request has been prepared.
Each specific relief request provides justification for not performing the Code-specified tests, and provides appropriate alternative testing.
In addition to specific relief requests, general relief requests which address specific Code requirements found to be impractical for this site have been prepared.
Relief requests are located behind the Relief Requests tab.
The three general relief requests which have been written are RR-2. RR-3,and RR-27.
RR-2 requests relief from IWV-3417(b) and IWV-3523 which state that, when corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup.
Relief was requested to allow corrective action to be performed prior to the valve being required for plant operability as defined in the Plant Technical Specifications. MR-3 requests relief from IWV-3417 for valves l
with stroke times of 2 seconds or less.
Relief was requested to requi'.*e the acceptance of the test to be based only on the stroke O
time limit and not the "50 percent" criterion in IWV-3417.
RR-27 requests relief from IWV-3427(b) for all Catagory A and AC valves 0957n 1-2 016 REV 1
s g
6 inch nominal diameter and larger.
Relief is requested from performing valve trending to determine seat degradation.
1.5 DEFINTIONS Terms below, when used in the Inservice Testing Program, are defined as follows:
Quarterly:
An interval of 92 days for testing comoonents which can be tested during normal plant operation.
Cold Shutd' n-2 ting scheduled for cold shutdown will commence tw later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after entering cold shutdown.
Testing will continue until all tests are complete or the plant is read.y to return to power.
Completion of all testing is not a prerequisite to return to power.
Testing not completed at one cold shutdown will be performed during subsequent cold shutdowns that may occur before the refueling outage.
In case of frequent cold shutdowns, valve testing will not be performed more often than once every 3 months.
The 48-hour interval need not hold for (g/
(,,
planned cold shutdowns when their duration is of i
sufficient time to accomplish all shutdown testing.
Refueling:
Testing scheduled for refueling will be performed during the normal schecuted refueling shutdowns before returning to power eperation.
4 0
0957n 1-3 016 REV 1
m.
p
%/
.i VEGP Unit No. 2 016 REV 1 Valve fast List
'l Systee:
Residual Heat Removal - Systen No. 1205 Sheet 1 of 4 Reliet.
Valve Act.
Rec. or
.41ve class AM4 Size Act.
Position or Tests and freo.
C.S.
Descriotion humbec ISI Pro]. (Coordj Cja { h ) Ty g Tyge g a Fall Safety Pass PI g ST FSV g Jus k and_ Notes 1
FV 0610 2 212 2X408122 8
3.00 GA NO O
AI 0/C A
Y 0 0
RHR Puno (H-5)
P6-001 Niniflow FV 0611 2 212 2X408122 8
3.00 GA NO O
At 0/C A
Y 0 0
RHR Puno (E-5)
P6-002 Nintflow HV 8716A 2 212 2X408122 8
8.00 GA NO O
A! 0/C A
Y0 0
RHR Train A (F-7)
Hot teg Isolation HV 87168 2 212 2X408122 8
8.00 GA NO 0
AI 0/C A
Y 0 0
RHR Train 8 (D-7)
Not Leq Isolation MV 8884A 2 212 2X408122 8
8.00 GA NO C
AI 0/C A
RR-2 Exetuqer (HX) Train A to CVCS Charge Puno Suction
. e.,
0960n 12-31
T
~
NOTES i
1.
Valves included in the Appendix J, Type C local leak rate test program.
The Appendix J, Type C requirements are implemented in lieu of paragraphs IWV-3421 through IWV-3425.
Leakage rate analysis and corrective actions as required by IWV-3426 and 3427(a) will be performed.
l 2.
This is a RCS pressure isolation valve and is leak rate tested per plant Technical Specifications.
3.
These are Anchor-Darling testable check valves.
These valves have a manual operation lever.
4.
These valves perform a safety function in the open position.
These valves are normally open therefore testing from the closed to open position is unnecessary.
O t
i i
0959n 12-94 016 Rev. 1 l
(.
=
RELIEF REQUEST RR-26 THIS PAGE LEFT INTENTIONALLY BLANK O
I 0961n 13-26 016 Rev. 1
COLD SHUTDOWN JUSTIFICATION CS-39 SYSTEM:
Residual Heat Removal System No. 1205 VALVE (S):
1205-HV-6804A CATEGORY:
B CLASS:
2 FUNCTION:
This valve opens to allow flow from the RWST through the RHR Pumps to the centrifugal charging pumps during post-accident recirculation.
QUARTERLY TEST REQUIREMENT:
Exercise and time COLD SHUTDOWN TEST JUSTIFICATION:
Exercising this valve during normal operation could introduce refueling O
water into the RCS through the normally operating charging pump.
RCS boron concentration could be adversely affected and could cause a plant shutdown.
QUARTERLY PARTIAL STROKE TESTING:
None COLD SHUTDOWN TESTING:
Exercise and time i
I O
l 14-39 016 REV. 1 i
r 1.*
i RELIEF REQUEST RR-27 SYSTEM:
All VALVE (S):
All Category A and AC Containment Isolation Valves 6 in.
Nominal Diameter and Larger CATEGORY:
A, AC CLASS:
1 and 2 FUNCTION:
Containment Isolation TEST REQUIREMENT:
INV-3427(b) requires that for valves 6 in. nominal pipe size und larger, if a leakage rate exceeds the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate by 50% or greater, the test frequency shall be doubled; the tests shall be scheduled to coincide with a cold shutdown until corrective action is taken, at which time the original test frequency shall be resumed.
If tests show a leakage rate increasing with time, O
and a projection based on three or more tests indicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate by greater than 10%, the valve shall be replaced or repaired.
BASIS FOR RELIEF:
IWV-3427(b) is apparently attempting to predict the failure of a valve based on gradual degradation that is of a trendable nature.
This would apply to a valve where the seat, internals, etc. are wearing at a measurable rate, and the eventual failure of the valve could be predicted from successive leakage tests.
However, historical data at Plant Hatch, Plant Vogtle and other nuclear plants has demonstrated that, in general, valves do not exhibit gradually increasing leakage rates as implied by IWV-3427(b).
The two general patterns of behavior for valves are:
(1) essentially constant leakage rates followed by sudden failure or (2) erratic test results which do not trend.
Therefore, trending as required by IWV-3427(b) does not serve any useful function.
ALTERNATE TESTING:
Valves with leakage limits exceeding the allowable
)
limits will be repaired or replaced per IWV-3427(a).
0961n 13-27 016 Rev. 1
- -. _. _