ML20195G762

Forwards Listing of All Relief Requests Superseding 861222 Relief Request.All Changes Made as Result of Relief Request Review,Per Concerns Raised in Insp Rept 50-155/87-22

ML20195G762
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/24/1988
From:	Frisch R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8806280129
Download: ML20195G762 (29)

Text

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b-Consumers

@powramus Power AIENCEAN'E PROGRr$5 Generet offices: 1945 West Parnall Road, Jackson, MI 49201 * ($17) 788-0550 t

J June 24, 1988 i

Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

INSERVICE TESTING PROGRAM RELIEF REQUESTS i

Consumers Power Company letter dated December 22, 1986 supplemented our 4 original January 21, 1983 Inservice Testing Program submittal and provided a

'j complete list of all of the relief requests applicable to our program.

During an inspection of our program by NRC Region III, documented in Inspection Report 87-022 dated November 25, 1987, concerns with some of our relief requests were identified. In responae to these concerns we have reviewed all of our relief requests and have revised them where necessary.

New relief requests have been included for flow rate measurement and bearing

, temperature measurement as committed to in our Decmeber 28, 1987 response to i

the inspection report. The attachment contains a complete listing of all i relief requests and supersedes our previous relief request submittal of December 22, 1986. All of the changes made as a result of this review are itemized in the attachment.

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Ralp R Frikeh Senior Licensing Analyst CC Administrator, Region III, hTC NRC Resident Inspector - Big Rock Point Plant Attachment j Ob

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8806280129 880624 PDR ADOCK 05000155

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4 e r ATTACHMENT Consumers Power Company Big Rock Point Plant Docket 50-155 INSERVICE TESTING PROGRAM RELIEF REQUESTS June 24, 1988 l l

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0 INSERVICE TESTING PROGRAM RELIEF REQUESTS The following is a complete listing of the current relief request.s applicable to Big Rock Point's IST Program and includes changes that have been made since our December 22, 1986 submittal. .

Core Spray Pumps Relief Request unchanged from 1986 submittal.

Electric and Diesel Fire Pump Test Frequency Relief Request unchanged from 1986 submittal.

Core Spray Pumps, Electric Fire Pump and Diesel Driven Fire Pump Flow Rate Measurement Added Relief Request to allow the use of ultrasonic flow measurement. ,

Core Spray Pumps, Electric Fire Pump and Diesel Driven Fire Pump Bearing Temperature Measurement ,

Added Relief Request for not taking bearing temperatures.

Control Rod Drive (VCRD-301 and CRD Pump Suction Foppet Valves) i Relief Request unchanged frem 1986 submittal.

Emergency Condenser (MO-7052, MO-7053, MO-7062 and MO-7063) l Changed testing frequency from each cold shutdown to each cold shutdown but not ,

more frequently than once every three months to be consistant with the code.

Containment Isolation Valves CV-4091, CV-4092, and CV-4093)

Changed relief request to be consistent with Technical Specifications. Also, CV-4025, CV-4027. CV-4031 CV-4094, CV-4095, CV-4096, CV-4097, CV-4102, CV-4103, CV-4105 and CV-4117 have been removed from the relief request.

Liiuid Poison System (CV-4020)

Changed testing frequency from not more frequently than quarterly to not more frequently than once every three months to read the same as the 1

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5 L(quid Poison System (VP-300)

Changed testing frequency from not more frequently than quarterly to not more frequently than once every thcee months to read the same as the code. .

Shutdown Cooling System (M0-7056, MO-7057. M0-7058 and MO-7059)

Changed alternate testing to include exercising of the valves as required for category A valves and added testing frequency.

Treated Waste Return (CV-4049 and VFW-313)

Relief Request unchanged from 1986 submittal.

Demineralized Water Supply (VMD-300)

Relief Request unchanged from 1986 submittal.

Liquid Poison System (CV-4050)

Relief Request unchanged from 19C6 submittal.

Liquid Poison Supply to Reactor Vessel (VP-301 & VP-302)

Deleted isst paragraph of 1986 submittal since isolation gate valve has been installed.

Main Steam Line Draia Isolation Valve (MO-7065)

Relief Request unchanged from 1986 submittal.

Feedwater (VFW-304 4 VFW-9)

Relief Request unchanged from 1986 submittal. (Relief request previously approved by NRC letter dated December 12, 1985.)

Feedwater (VFW-305)

Relief Request unchanged from 1986 submittal. (Relief request previously i approved by NRC letter dated December 12, 1985.)

Control Rod Drive (CVNC09's & CVNC10's)

Relief Request unchanged from 1986 submittal.

Enclosure Spray System (MO-7064 & MO-7068)

Relief Request unchanged from 1986 submittal.

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L Core Spray System (VPI-300, VPI-306, VPI-307)

Changed frequency on alternate testing to correspond with relief request for core spray pumps.

Core Spray System (VPI-303 & VPI-304)

Relief Request unchanged from 1986 submittal.

Core Spray System (VPI-301 & VPI-302)

Relief Request unchanged from 1986 submittal. ,

Reactor Depressurization System (SV-4984 - SV-4987)

Relief Request deleted.

Core Spray System (MO-7072)

Relief Request unchanged from 1986 submittal.

Core Spray System (MO-7071) i Added relief request on leak testing of MO-7071.

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l RELIEF REQUEST Item: Relief request for Core Spray Pumps Test Requirement: Monthly during plant operation and within one week after plant startup if not tested during the shutdown.

Basis for Relief: These pumps are part of the Emergency Core Cooling System.  !

Testing during power operations would require a valve lineup which would preclude their performing their required function after a loss of coolant accident (LOCA). In the event of a LOCA, areas which must be entered to change this valve lineup would be untenable. In addition, testing during power operation would require personnel entry into the very high radiation area directly beneath the reactor vessel.

Alternative Testing: Once per reactor cold shutdown and each refueling (but not more frequently than once every three months).

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RELIEF REQtfEST I t.em: Relief request for Electric and Diesel Driven Fire Pump Test Frequency Test Requirement: Monthly during plant operation and within one week after plant startup if not tested during the shutdown.

Basis for Relief: These fire pumps must be tested on a monthly basis as required by ASME Section XI ItiP testing. To perform the test would require fire water flow through the shell side of the core spray heat exchanger. This fire water is then .

discharged back to the lake.

This flow test, which is the only valid temt, will reduce the flow available to'the ECC to below that calculated as necessary. Thus, to prevent degradation of the Emergency Core Cooling System, relief is requested to allow testing each reactor shutdown. The granting of this relief request

will insure there will be adequate flow available to the d

Emergency Core Cooling System, relief is requested to allow testing for each reactor shutdown. The granting of this 1 relief request will insure there will be adequate flow i available to the Emergency Core Cooling System.

i This relief request will also apply to the fire pump discharge check valves, VFP-304 and VFP-309.  !

I Alternative Testing: Once per rer etor cold shutdown and each refueling (but not more frequently than once every three, months).

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RELIEF REQUEST Item: Relief request for Core Spray Pumps, Electric Fire Pump and the Diesel Driven Fire Fump Flcw Rate Measurement Test Requirement: Flow rate shall be measured using a rate or quantity meter installed in the pump test cavity.

Basis for Relief: Big Rock does not have flow meters installed in the test circuit for the core spray or fire pumps.

Alternative Testing: Measure the flow rate of the system usir , an ultrasonic flow measuring instrument.

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I Item: Relief request for Core Spray Pumps, Electric Fire Pump and the Diesel Driven Fire Pump Bearing Temperature Measurement  ;

1 Test Requirement: Measure pump bearing temperature l I

Basis for Relief: .The bearings in these pumps are cooled and lubricated by the water be.ing pumped. Due to water temperature variations l and bearing inaccessibility, there is no method that will i establish a meaningful bearing reference temperature.

Alternetive Testing: None, the other pump parameters will be used for determination of pump condition. j l

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RELIEF REQUEST System: Control Rod Drive (Print M-106)

Valve: VCRD-310 and CRD Pump Suction Poppet Valves Category: AC ASME Class: 2 Function: To prevent backflow from containment through the CRD supply line.

Test Requirement: Exercise quarterly and local leak rate test each reactor

' shutdown for. refueling.

Basis for Relief: The closing function.cannot be verified except during times of local leak rate testing which is performed each reactor shutdown for refueling per 100FR50, Appendix J.

Alternative Testing: Local leak rate test each reactor shutdown for refueling.

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RELIEF REOUEST System: Emergency Condenser (Print M-107)

Valve: M0-7052, M0-7053, M0-7062, MO-7063 Category: B ASME Class: 1 Function: Emergency Condenser Inlet and Discharge Isolation Valves Test Requirement: Exercise valves for operability every three months.

Basis for Relief: The exercising of these valves at power would admit steam to the emergency condenser. This action would cause unnecessary thermal stresses in the tube bundles. The proposed alternate testing will etnimize thermal cycles.

Alternative Testing: Once each cold shutdown (but not more frequently than once every three months) or when one loop becomes isolated.

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RELIEF REQUEST System: Containment Isolation Valves (Prints M-107, M-108)

Valve: CV-4091, CV-4092, CV-4093 Category: A ASME Class: 1 for CV-4092, CV-4093 2 for CV-4091 Function: To isolate containment Test Requirement: Exercise valres every three months.

Basis for Relief: These valver are interlocked and cannot be opened at a system pressure above 100 psig and therefore they can't be exercised at power. These valves are normally in their required position to perform their containment isolation function.

Alternative Testing: Exercise valves each cold shutdown (but not more frequently than once every three months),

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RELIEF REQUEST System: Liquid Poison System (Print M-107)

Valve: CV-4020 Category: B ASME Class: 1 Function: Liquid poison tank discharge isolation valve Test Requirement: Exercise valve for operability every three months.

Basis for Relief: Closing this valve prevents injection of liquid poison and prevents system from being available for operation as required by Technical Specifications. Testing can only occur during cold shutdown.

Alternative Testing: Exercise valve each cold shutdown (but not more frequently than once every three months).

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RELIEF REQUEST System: Liquid Poison System (Print M-107)

Valve: Check Valve VP-300 Category: C ASME Class: 1 Function: Once system is actuated, check valve prevents nitrogen from escaping to the steam drum while establishing a siphon.

Test Requirement: Exercise valve for operability every three months.

Basis for Relief: The valve has no operator. In addition, pressure cannot be applied to test valve operation without breaching primary boundary.

Alternative Testing: Exercise valves each cold shutdown (but not more frequently than once every three months).

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I RELIEF REQUEST j System: Shutdown Cooling System (Print M-107)

Valve: MO-7056, MO-7057, M0-7058, MO-7059 Category: A ASME Class: 1 Function: Shutdown cooling system inlet and discharge isolation valves Test Requirement: Exercise valves for operability every three months. l Basis for Relief: Exercising these valves while the reactor is at operating pressure would overpressurize the shutdown cooling system (design pressure 300 psig). In addition, amendment 28 to the Technical Specifications require opening of the valve breakers at system pressure greater than 300 poig.

Alternative Testing: Exercise valves each cold shutdown (but not more frequently than once every three months).

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RELIEF REQUEST System: Treated Waste Return (Print M-108)

Valve: Isolation Valve CV-4049 and Check Valve VRW-313 Category: A & A/C ASME Class: 2 Function: To isolate containment ,

i Test Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.

Basis for Relief: The valves are passive valves that are in the position that will perform their intended function. Thus, exercising will not provide any additional margin of safety.

Alternative Testing: Local leak rate test at each reactor shutdown for refueling.

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• s s RELIEF REQUEST 1 System: Demineralized Water Supply (Print M-110)

Valve: Inlet Check Valve (VMD-300)

Category: A/C ASME Class: 2 Function: To isolate containment Test Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.

Basis for Relief: There is no means to verify closur. of the check valve except during a local leak rate test. Thus, the local leak rate test will be the only means of testing.

Alternative Testing: Local leak rate test at each reactor shutdown for refueling.

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s RELIEF REQUEST System: Liquid Poison System (Print M-121)

Valve: CV-4050 Category: B ASME Class: 1 Function: Isolate flew of liquid poison to recirculation pump suction Test Requirement: Exercise valve for operability every three months.

Basis for Relief: An interlock opens this valve automatically when either recirculating pump is in service. Thus, exercising this valve requires taking both recirculating pumps out of service.

Alternative Testing: Exercise valve and verify position indication once during any shutdown in which both recirculation pumps are secured, or as a minimum, each reactor shutdown for refueling.

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RELIEF REOUEST System: Liquid Poison Supply to Reactor Vessel (Print M-121)

Valve: Check Valve in liquid poison supply line to reactor vessel (VP-302) and Check Valve in liquid poison supply line to recirculating pumps (VP-30::) .

Category: C ASME Class: 1 Function: To prevent reactor water backflow through liquid poison line.

Test Requirement: Exercise valve for operability every three months.

Basis for Relief: The check valves have no operators. Exercising these valves by initiating flow in the system would introduce liquid poison into the reactor during operation or shutdown.

Alternative Testing: Visually incpect valves each reactor shutdown for refueling by removing valve internals.

Discussion: The liquid poison check valves are a Chapman Type V tilting disc check valve which has a three piece body construction. The seat ring, disc and pivot pins are located in the center section which is secured between two flanges with twelve studs.

This type of check valve construction lends itself to ease of disassembly, inspection and reassembly and the check valves are isolable from the reactor vessel.

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RELIEF REQUEST System: Main Steam Line Drain Isolation Valve (Print M-121)

Valve: M0-7065 Category: A ASME Class: 1 Function: To isolate main steam line drain to condenser Test Requirement: Exercise valve for operability every three months and leak test each reactor shutdown for refueling.

Basis for Relief: The valve is electrically disabled in the closed position and does not have to change position to perform its intended function; thus, no exercising of the valve will be performed.

Alternative Testing: Note leakage rate through the valve during each NSSS hydrostatic test associated with a reactor shutdown for refueling.

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RELIEF REQUEST System: Feedwater Valve: Feedwater Check Valve VFW-304; and Feedwater Stop Check Valre VFW-9; Plug Type Category: C ASME Class: 1 Function: Primary coolant pressure boundary Test Requirement: ASME Section XI 1977, summer 1978 addendum IWV-3520 - Valve exercising is not possible during power operation, therefore full stroke test during cold shutdowns is required. Testing at every shutdown if intervals are 2 3 months or if testing has been completed within the last 3 months testing is not required. Valve disk movement shall be determined by an appropriate indicator.

Alternate Testing: Close valve VFW-9 via hand wheel during each refueling outage.

Basis for Relief: The valves cannot be exercised during power operation because feedwater flow cannot he interrupted during this time. The valves each close when feenwater flow is stopped.

Valve disk movement to the closed position for VFW-304 cannot be determined as there are no direct or indirect indications available to make the determination. Valve disk movement to the closed posh' ion for VFW-9 can be determined by turning the valve ster,into the seat. VFW-9 is a stop check valve equipped with a hand wheel and stem which can be turned into the valve disk. The stem and disk are not connected however, so raising the stem will not raise the disk.

The determination of both VFW-304 and VFW-9 being open is made by verifying proper feedwater flow exists when return-ing the system to service af ter shutdown.

The frequency interval, for closing the valve VFW-9, of each refueling outage is requested due to the high radiation area that exists in the vicinity of the valve. It requires two operators, in an approximate 350 to 500 mr/hr and return it to the full open position. The accumulated exposure for one exercise operacice amounts to 0.7 to 1 man-rem. The Consumers Power Company's pocition is that the benefit derived from exercising the valve stem, that only would be minimal from a valve reliability standpoint and would not off-set the additional radiation exposure involved. Because this area is frequented often during a refueling outage, the exercis-ing of the valve stem to verify valve closure during a refueling outage can be more easily justified.

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RELIEF REQUEST System: Feedwater Valve: Feedwater Check Valve VFW-305; Swing Type Category: A, C ASME Class: 2 Function: Containment isolation valve Test Requirement: ASME Section XI 1977, summer 1978 addendum IWV-3410 - Valve exercising is not possible during power operation, therefore .tull stroke test during cold shutdowns is required. Testing at every shutdown if intervals are 2 3 months or if testing has been completed within the last 3 months testing is not required. Valve disk movement shall be determined by an appropriate indicator.

IVW-3420 - Valves shall be leak tested every two years.

IVW-3520 - Valve exercising per category C requirements are met by fulfilling requirements of category A IWV-3410 requirements.

Alternate Testing: Perform a 10CFR50 Appendix J 1eak rate test during each refueling.

Basis for Relief: The valves cannot be exercised during power operation because feedwater flow cannot be interrupted during this time. The check valve seats (closes) when feedwater flow is stopped. Valve disk movement to the closed position cannot be determined as there are no direct or indirect indications available to make the determination. Disk movement to the open position is only possible when feedwater flow is initiated. Indication of feedwater flow provides the required indication the valve is open. Valve exercise testing therefore cannot be acconplished e:teept to verify the valve is open by indication of proper feedwater flow.

As a containment isolation valve the valve will be leak rate tested each refueling outage in accordance with 10CFR50 l Appendix J requirements. l l

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1 RELIEF REQUEST System: Control Rod Drive (Print M-122)

Valve: Scram Inlet (CVNC09) and Outlet (CVNC10) Isolation Valves (32 sets of 2 valves)

Category: B ASME Class: 2 Function: To cause a control rod drive to insert rapidly Test Requirement: Exercise valve for operability every three months.

Basis for Relief: Exercising these valves would cause the associated control rod to scram.

Alternative Testing: Exercise valves prior to reactor critical approach following a cold shutdown.

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4 RELIE'l REQUEST System: Enclosure Spray System (Print M-123)

Valve: M0-7064, M0-7068 Category: B ASME Class: 2 Function: Enclosure spray isolation valves Test Requirement: Exercise valve for operability every three months.

Basis for Relief: Exercising these valves during power operation would result in spraying water on energized electrical equipment inside containment.

MO-7064 and M0-7068 cannot be exercised during cold shutdowns because the fire system header must be taken out of service and drained to allow the exercising of the valves. This will pose an unwarranted fire hazard if the fire system is not available in the containment. Testing during each reactor shutdown for refueling prevents a more acceptable risk as far as fire suppression capabilities in the containment.

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Alternative Testing: Exercise valves each reactor shutdown for refueling.

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RELIEF REQUEST System: Core Spray System (Print M-123)

Valve: Core Spray Pump Discharge Check Valves (VPI-306, VPI-307) and Core Spray Test Tank Inlet Check Valve (VPI-300)

Category: C ASME Class: 3 Function: To prevent backflow in the Core Spray System Test Requirement: Exercise valve for operability every three months.

Basis for Relief: The valves have no operators. They cannot be exercised by initiating flow in the system during power operation because the core spray pumps cannot be operated for test during power operations.

Alternative Testing: Once each reactor cold shutdown and each refueling (but not more frequently than once every three months). (See Core Spray Pump Relief Request. These valves can only be tested when the pump is tested.)

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System: Core Spray System (Print M-123)

Valve: Primary Check Valves (VPI-303 and VPI-304) 1 Category: A, C I

ASME Class: 1 Function: Primary check valves in the core spray lines to prevent reactor pressure from pressurizing lines if the isolation valves were ,

opened. l Test Requirement: Exercise valve for operability every three months.

1 Basis for Relief: The primary check valves have no operators. The valves l cannot be opened against operating reactor pressure by 1 initiating flow through these lines, because core spray l system pressure is much less than operating reactor pressure. During shutdown, the initiation of flow through these lines would introduce non-reactor grade water into the core. The only means to insure proper valve operation is to disassemble and inspect the valve during each reactor I shutdown for refueling. There exists no method to insure disc movement torque requirements are met. The valve will be inspected and verified that the disc is free to move.

Alternative Testing: Disassemble and inspect each reactor shutdown for refueling.

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RELIEF REQUEST System: Core Spray System (Print M-123)

Valve: Secondary Check Valves (VPI-301 ard VPI-302)

Category: C ASME Class: 1 Function: To prevent water backflow from the reactor to the Fire Water System.

Test Requirement: Exercise valve for operability every three months.

Basis for Relief: The secondary check valves have no operators. Testing of the valves will take the core spray system out of service.

Thus a flow test will be performed by allowing the fire water to enter the service water system and then be discharged to the canal. (Note that proper sampling and analysis of the fire water will be performed to insure no uncontrolled release.) This flow testing will be scheduled each reactor cold shutdown (but not more frequently than three months).

Alternative Testing: Flow test the check valves each reactor cold shutdown (but not more frequently than once every three months).

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RELIEF REQUEST System: Core Spray System Valve: M0-7072 Category: B ASMI Class: 2 Function: To provide a third path of fire water to the containment Test Requirement: Exercise quarterly Basis for Relief: Exercising this valve will introduce fire water into the inhibited water of the core spray pump piping. Exercising during each shutdown will minimize the amount of fire water that enters the core spray pump piping.

Alternative Testing: Each reactor cold shutdown but not more frequently than once every three months.

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i RELIEF REQUEST Syutem: Back-up Core Spray Valve: MO-7071 Category: A ASME Class: 1 Function: Isolation valve betueen primary system and core spray system.

Test Requirement: Local leak rate test each reactor shutdown for refueling.

Basis for Relief: The back-up core spray system has three valves in series MO-7070, VPI4 03 and MO-7071 which perform as isolation valves between the lower pressure core spray system (150 psig) and the primary coolant system (1335 psig). There is a telltale located between M0-7070 and VPI-30 which would indicate leakage past VPI4 03 and M0-7071.

MO-7070 and MO-7071 are full stroked every month during plant operation. During this test the operator is cautioned to ensure that core spray pressure does not increase above 170 psig which would indicate leakage through the valves.

When M0-7070 is stroked the flow through the telltale is checked and when M0-7071 is stroked check valve VPIf 03 is checked to show that it is adequately seated. By having these three valves ir series and performing the montly stroke testing of M0-7070 and M0-7071 there is adequate insurance that there is proper isolation between the two systems.

Alternative Testing: None l

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