ML20199C065
| ML20199C065 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 01/22/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9801290093 | |
| Download: ML20199C065 (39) | |
Text
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Dave M:r:y S:uthern Nuclear Vice Present Operating Cornpa:y Fart:y Preject P.O. Box 1295 Birmingham. Alabama 35201 Tel 205.932.5131 k
SOUTHERN h January 22, 1998 COMN Enery to Serve %rWorld" Docket Nos:
50 348 10CFR50.55a 50-364-U. S. Nuclear Regulatory Commission A*ITN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Inservice Testing (IST) Program Response to NRC Questions / Comments on IST Relief Requests Submitted as Part of the 10 Year IST Uodate l
Ladies and Gentlemen:
Southern Nuc! car Company (SNC) submitted, on July 3,1997, updated IST programs for Joseph M. Farley Nuclear Plant (FNP) Units I and 2, in accordance with the requirements cf 10CFR 50.55a(f)(4)(ii). The updated programs contained pump and valve relief requests which SNCsubnutted for granting.
Telephone conference calls were held on November 18,1997 and December 17,1997 between the NRC and SNC to discuss these IST relief requests. Enclosed is a summary by relief request, of the NRC's questions / comments, SNC's response and the, specific relief request action SNC is taking as a result. Note that SNC's response to questions / comments on valve relief request E21-RR-V-1 for the Accumulator check valves is in the process of preparation and will be sent to the NRC in a subsequent letter, j )
Should you have any questions please contact this office.
Respectfully submitted, c777 7?h4l Dave Morey AJP:maf nreletol. doc Listing of Enclosures on next page ec:
Mr. L. A. Reyes, Region II Administrator Mr. J.1. Zimmerman, NRR Project Manager Mr. T. M. Ross, FNP Sr. Resident Inspector 9801290093 980122 lll1,1!I,l!ll.lil.l!Il.l!Ill.l 4
i PDR ADOCK 05000348 P
U. S. Nuclear Regulatory Commission Page 2 4
Enclosures:
D Summary by Relief Request it). Unit 1(2) Pump Relief Requests RR-P-1, Revision 1, from FNP-1(2)-M-094 III) Unit 1(2) Withdrawn Pump Relief Request RR-P-3 from FNP-1(2)-M-094 IV) - Unit 2 Revised Valve Relief Request Q2E13 RR-V-1 from FNP 2-M-094 l
V)
Unit 1 Revised Valve Relief Request Q2E13 RR-V-2 from FNP-2-M-094 VI) Uni! l(2) Revised Valve Relief Request Ql(2)E21-RR-Y-2 from L
FNP-l(2)-M-094 Vil) Unit 1(2) Withdrawn Valve Relief Request Q1(2)E21-RR-V-3 from FNP-1(2)-M-094 VIII) Unit 1(2) Revised Valve Relief Request Q1(2)N12 RR-V-1 from FNP 1(2)-M-094 IX) Unit 1(2) Withdrawn Valve Relief Request Q1(2)P16-RR-V-1 from FNP-1(2)-M-094 6
i-
)
ENCLOSUREI Summary By Relief Request 7
t i
u
o Pump Relief Reauest RR-P-1 All Pumos - Enrineerine Evaluation as Corrective Action NRC Ouestion/ Comment: The NRC advised that the evaluation used as corrective action for a pump in the required action range should include confirmation that the degradation trend would not indicate that pump performance would fall below minimum acceptable design accident requirements prior to the next scheduled surveillance or pump repair.
SNC Resoonse: SNC agrees that this would be part of a proper engineering evaluation. The relief request has been revised to specifically address this part of the evaluation.
ReliefRequest Action: A revised relief request addressing the NRC note is attached to this letter.
Pumo Relief Recuest RR-P-2 Service Water Pumo Flow-Use of Simultaneous Eauntions to Determine Individual Pumo Perfor: nance l
NRC Ouestion/ Comment: The NRC asked that SNC advise the NRC of the date of the NRC SER which approved the use of simultaneous equations to c'etermine individual Service Water pump performance from dual pump test results.
SNC Response: The NRC SER giving approval of the current testing method was contained in an NRC letter dated August 23,1993 from S. Singh Bajwa, Acting Director, NRC to D. N.
Morey, Vice President, SNC.
Relief Reauest Action: No change to the relief reguest is recuirea.
Pumo Relief Recuest RR-P-3 Service Water Pumo Flow instrumentation (Annubar)
Accuracy NRC Ouestion/ Comment: The NRC said that the SER from the 2nd interval indicated that relief was not required for the installed Annubar accuracy exceeding the code required 2%
accuracy because the code 2% accuracy requirement applies to bench accuracy not installed accuracy. The Annubars stated bench accuracy is better than the 2% code requirement.
SNC Resnaam SNC agrees with the NRC that the instmment meets the bench accuracy requirements as stated in the code.
ReliefReauest Action: The relief request is withdrawn. A copy of the withdrawn relief request is attached to this letter.
Pumo Relief Reauest RR-P-4 Boric Acid Pump Reference Values NRC Ouestion/ Comment: Are unique (different) rekrence vJues used for the quarterly and cold shutdown testing?
EI-2 l
1
SNC Response: SNC answered this question in the affirmative. Since the test setups are different for the quarterly and cold shutdown tests, different reference values are required to trend pump performance.
ReliefReauest Action: No change to the relief request is required.
Pumo Relief Reonest RR-P-5 Auxiliary Feedwattr Pumo - Use of a Curve of Reference Values NRC Ouestion/ Comment: How are reference values established for differential pressure and vibration for quarterly testing?
SNC Response: When major repair of a MDAFW pump makes it necessary to reestablish quarterly reference values, the following methodology would apply. This discussion assumes the plant is at power and only the fixed restriction pump miniflow path is available.
The pamp would be aligned per its normal quarterly STP flowpath (fixed miniflow) and the normal STP would be run which includes differential pressure (AP) and vibration measurements. In addition, suction flow values would be obtained to allow comparison of the pump's performance at the measured AP to the vendor curve for new impeller installations or.
to previous impeller performance curves for major pump work where the impeller was reused.
An adoitional comparison of the flow and AP data point to the accident analysis curve would l
also be made to verify pump performance was within the bounds of the upper and lower allowable performance and to determine the allowable degradation margin. This ma$a would then be used to determine the allowable testing limits for the IST Program for that pump.
Bslief Request Action: No change to the relief request is required Valve Relief Rmuest El3-RR-V-1 Containment Sorav Pumo Discharme Check Valve -
Disassembly - Anoticable to Unit 2 Only NRC Ouestion/ Comment: The NRC stated that SNC must show r. burden / justification for not disassembling both valves in this group every refueling outage. It was acknowledged that this relief reguest was granted in the previous interval without requesting documentation of the burden / justification. The NRC also noted that valve disassembly was not an NRC favored option and preferred all disassemblies be abandoned in favor of nonintrusive testing techniques.
SNC Response: SNC does not desire to disassemble any check valve as part of the IST Program and thus shares the NRC's goal of minimizing valve disassembly / inspections wherever possible.
The inspection histon of these valves suggests there is no need for disassembly /mspection of each valve each outage, thus any additional expense in doing so would be an unnecessary burden. The past six inspections for each valve dating back to 1985 have not detected any unsatisfactoy conditions. On a"erage, the disassembly / inspection of these valves requires 6
(
EI-3 l
a
man-hours inside containment. Additional costs associated with planning, scheduling, supervision, documentation, etc. are also required for this task.
Nonintrusive techniques cannot be employed to test these valves. They are located in the normally dry, empty containment spray piping system inside containment. There is no way to open the valves with water flow at any time without risking damage to safety related equipment in containment. The valves are partial stroke tested with air but there is not a sufficient volume of air to fully open these 8" check va!ves even instantaneously for non-nonintr sNe testing purposes.
The lack of any alternative test method plus the excellent inspection historyjustifies the staggered disassembly schedule of one valve per outage.
ReliefRequest Action: A revised relief request containing a description of the burden / justification as outlined above is attached to this letter.
Valve Relief Reauest E13-RR-V-2 Containment Soray Pumo Suction Check Valve Disassemtiv - Anolicable to Unit 2 Only NRC Ouestion/ Comment: The NRC stated that SNC must show a burden' justification for not disassembling this valve every refueling outage. It was acknowledged that this relief request was granted in the previous intesval without requesting documentation of the burden / justification. The NRC also noted that valve disassembly was not an NRC favored l
option and preferred all disassemblies be abandoned in favor of nonintrusive testing techniques.
- SNC Resoonse: SNC does not desire to disassemble any check valve aa part of the IST Program and thus shares the NRC's goal of minimizing valve disassembly / inspections wherever possible.
The inspection history of this valve suggests there is no need for disassembly / inspection of the valve each outage, thus any additional expense in doing so would be an unnecessary burden.
The past six inspections of this valve dating back to 1985 ha fe not detected any unsatisfactory conditions.
Nonintrusive techniques cannot be successfully employed to test these valves. This valve is located in the 12" Containment Spray (CS) pump suction line from the Refueling Water Storage Tank (RWST). The only normal water flow through this valve is approximately 150 gpm during quarterly CS pump testing. SNC engineers experienced with nonintrusive check valve testing indicate that this application will not be successful because the 12" check valve will not fully open with 150 gpm flow.
Disassembly / inspection of this valve every outage would be an extreme burden. There is no installed valve which can be used to isolate the check valve from the RWST for disassembly.
Isolation is accomplished by freeze sealing the line from the P.WST. This procedure is done with the assistance of a freeze seal contractor. The process requires considerable planning, scheduling, specialized equipment and a large quantity ofliquid nitrogen. Several days are EI-4 l
required for completing this procedure. There is also a potential for the freeze seal process to cause pipe cracking or deformation. This requires strict control of freeze rate and pipe temperature. The most recent freeze seal contractor cost exceeded 518,000. On average,50 FNP man-hours are required to support the contractor and to perform the disassembly / inspection of the valve. Additional costs associated with planning, scheduling, supervision, documentation, etc. are also required for this task.
The lack of any alternative test method, the excellent inspection history and the high cost of the freeze seal procedurejustifies disassembly / inspection of this valve once every third refueling outage.
ReliefRequest Action: A revised relief request containing a description of the burden /justificatior. as outline above is attached to this letter.
Valve Relief Reauest E21-RR-V-1 Accumulator Check Valve Disassembly NRC Ouestion/ Comment: NRC stated that SNC must show a burden in not disassembling all valves in this valve group every outage. NRC also noted that valve disassembly was not an NRC favored option and preferred all such testing be abandoned in favor of nonintrusive testing techniques.
SNC Respo..se: Response being developed - to be submitted in a subsequent letter.
EslicLRequest Action: To be determined.
Valve Relief Reauest E21-RR-V-2 Chargine Pumo Miniflow Check Valve Disassembly NRC Ouestion/ Comment: The NRC indicated that SNC would have to demonstrate a technical basis to show that a measurable correlation of valve degradation in the form of percent valve opening versus pump bearing or casing temperature existed in order for this relief to be granted. In addition, the NRC noted that valve disassembly was not an NRC favored option and preferred all such testing be abandoned in favor of nonintrusive testing techniques where possible.
SNC Resnonse: These '.+1ves were disassembled and inspected during the previous interval.
The alternate testing proposed by SNC in the original relief request demonstrated that SNC does not desire to disassemble any check valve as part of the IST Program and thus shares the NRC's goal cf minimizing valve disassembly / inspections wherever possible. The NRC request to develop a correlation between valve opening and pamp casing / bearing temperature is not practical, thus SNC is withdrawing its proposal to t:se this test technique.
SNC has tried acoustic and magnetic nonintrusive iehniques on this application to show that the check valve opens fully. The re;ults have been inconclusive and indeterminate. These valves are of the spring loaded plug design. When full open, the plug does not contact the back seat and thus the nonintrusive signals which are produced are at best questionable in determining percent opening and would not be useful in trending degradation. SNC could not EI-5
prove orjustify any claim of any valve opening percentage with these methods and has thus abandoned nonintrusive valve techniques.
SNC has determined that there is no other testing wh!ch can be done on these valves and will continue to test these valves by disassembly / inspection. The inspection history of these valves suggests there is no need for disassembly / inspection of all three valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past twelve inspections for these valves (total both units) dating back to 1988 have not detected any unsatisfactory
- conditions. On average, the disassembly / inspection of these valves requires 10 man-hours.
Additional costs associated with planning, scheduling, supervision, documentation, etc. are also required for this task.
The lack of any alternative test method plus the excellent inspection historyjustifies the staggered disassembly schedule of one valve per outage. A reliefrequest for this staggered testing was granted in the previous interval without requesting documentation of the burden / justification.
ReliefRequest Action: A revised relief request containing a description of the burden / justification as outline above is attached to this letter.
Valve Relief Reauest E21-RR-V-3 RHR to RCS Hot Lee Check Valve - Verifyine Valve Openine by Measurine Combined Flow throueh Parallel Check Valveg I
NRC Ouestion/ Comment: The NRC stated that the testing proposed is not an acceptable test to determine individual valve acceptability because it measures combined flow through two valves in parallel. Unless flow through individual valves can be determined then valve degradation cannot be trended.
SNC Response. SNC has determined that it will be possible to use nonintrusive check valve -
techniques to confirm full valve opening of these valves during refueling outages and will proceed to create the necessary proced tres and plans to do so.
EgliefReauest Action: The telief request is withdrawn. A refueling outagejustification will be developed and included in the IST Program to document thejustification for the refueling outage test frequency.
Valve Relief Reauest N12-RR-V-1 Main Steam to TDAFW Pumn Turbine Check Valve Disassembly NRC Ouestion/ Comment: The NRC stated that SNC must show a burden / justification for not disassembling both valves in this valve group every refueling outage. It was acknowledged that this relief request was granted in the previous inteival without requesting documentation of the burden / justification. The NRC also noted that valve disassembly was not an NRC favored option and preferred all disassemblies be abandoned in favor of nonintrusive testing techniques. NRC suggested radiography to confirm valve closure.
EI-6
SNC Response: SNC dees not desire to disassemble any check valve as part of the IST Program and thus shares the NRC's goal ofminimizing valve disassembly / inspections wherever possible.
The inspection history of these valves suggests there is no need for disassembly / inspection of both valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past seven inspections of these valves dating back to 1990 have not detected any unsatisfactoiy conditions. In early 1990 an inspection revealed a generic oversized hinge pin problem which restricted the ability of the disc to open fully. This problem was corrected per the vendors recommendations by remachining the pins. No service inducal degradation was found with these valves. On average, the disassembly / inspection of these valves requires 9 man-hours. Additional costs associated with planning, scheduling, supervision,
. documentation, etc. are also required for this task.
l SNC has reviewed the system and confirmed that there are no alternate means to reverse flow test the valve. The site personnel responsib'.e for reviewing radiographs stated that SNC could not stand behind a radiograph to corJirm valve closure. Disassembly remains the only option to confirm reverse closure capability.
ReliefRequest Action: A revised relief request containing a description of the burden / justification as outline above is attached to this letter.
YaLvt ellerReauest P16-RR-V-1 SW to SW Pumn Seals and Motor Cooler Check R
Valve Disassembly NRC Ouestion/ Comment: NRC stated that SNC must show a burden in not disassembling every valve in the group every outage. It was ackncewledged that this relief request was granted in the previous interval without requesting documeritation of the burden / justification.
NRC also'noted that valve disassembly was not a favored option by the NRC and preferred all such testing be abandoned in favor ofnonintrusive testing techniques SNC Response: SNC has reviewed the burden of disassembling each valve every outage and the valve maintenance history and has decided to withdraw the relief request.
Relief Reauest ActiDE The relief request is withdrawn. A copy of the withdrawn relief request is attached to this letter.
EI-7
o, ENCLOSURE II Unit 1(2) Pump Relief Request RR-P-1, Revision 1 from FNP 1(2)-M-094 l
FNP-1 M 094 o
PUMP RELIEF REQUEST RR-P-1 System:
Allincluded in IST Program Pumps:
Allincluoed in IST Program Class:
2 'and 3 Drawing /Coord: See Pump Test Tables.
Function:.
See Pump Test Tables.
Test
' Requirementt ISTB 6.1 - If deviations fall within the required action range of Table ISTB 5.2-2, the pump shall be declared inoperable until the cause of the deviation has been determined and the condition corrected.-
~ Relief:
The ASME Section XI Code up to and including the 1986 Edition with the 1987 Addenda, subsection IWP-3230(c) stated that;
' Corrective action shall be either replacement or repair per IWP-3111, or shall be an analysis to demonstrate that the condition does not impair L
pump operability and that the pump will still fulfill its function. A new l
set of reference values shall be established after such analysis."
The OMc-1994 Addenda (ISTB 6.2.2) and all subsequent editions and addenda
. state that;
'If the measured test parameter values fall within the required action y
range of Table 5.2.1-1, Table 5.2.1-2, Table 5.2.2-1, or. Table 5.2.3-1, as j;
applicable, the pump shall be declared inoperable until either the cause of
[
the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and new reference values are established in accordance with ISTB 4.6."
The Code which was applicable for the second interval IST Program (ASME Section XI-1983 Edition with Summer 1983 Addenda, Subsection IWP) and the latest issued edition (ASME OM Code-1995 Edition, Subsection ISTB) both provide for analysis of pump test data in lieu of arbitrary repair or replacement if the test parameters fall within the required action range. The OM Code-1990 Edition did not include such provisions. Therefbre, based on the fact that the latest published version of the OM Code, Subsection ISTB, includes provisions (Continued on next page)
E 11 - 1 Rev.1
1
. FNP 1 M494 PUMP RELIEF REQUEST RR-P-1 (continued) for evaluation of pump test da'.a which is in the Action Range in lieu of arbitrary repair or replacement indicate; that the ASME OM Code Committee supports evaluati* as an acceptable alaroach. - Additionally, another SNC nuclear facility, Plant E. I. Hatch, requeced nonroval to utilize the later OM Code requirements, relative to evaluation of pump test data (see E. I. Hatch IST Program, relief request RR-P-11), and was granted approval in an NRC Safety :
Evaluation Repon dated April 12,1996.
y-Alternate Testing:
Should pump test parameters fall within the required action range of Table ISTB l
5.2 2 (OM Code 1990 Edition), then the pump will be declared inoperable until l~
either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and the pump's continued operation at the changed values is supported in which case new reference values will be established. This analysis shall include verification of the pump's operational readiness. The analysis shall include both a pump level and a system level evaluation of operational readiness.' the cause of the change in pump-performance, and an evaluation of all trends indicated by available data. The degradation trend will be evaluated to confirm that the degradation mechanism -
will not cause sufficient further degradation such that it'would be predicted that i
the pump would fail to be able to perform its required safety function before the p
next pump test or before repairs can be performed. The results of the analysis will be documented in the record of tests. This approach is consistent with that of the ASME OM Code 1995 Edition, Subsection ISTB, paragraph ISTB 6.2.2.-
i E 11 - 2 Rev.I a_a v
A
FNP-2 M-094 e
PUMP REIAEF REQUEST RR P-1 System:
Allincluded in IST Program Pumps:
Allincluded in IST Program Class:
2 and 3 Draw!ng/Coord: See Pump Test Tables.
Function:
See Pump Test Tables.
Test Requirement:
ISTB 6.1 - If deviations fall within the required action range of Table ISTB 5.2-
- 2, the pump shall be declared inoperable until the cause of the devietion has been determined and the condition corrected.
Basis For Relief:
The AShE Section XI Code up to and includin the 1986 Edition with the 1987 Addenda, subsection IWP-3230(c) stated that;
' Corrective action shall be either replacement or repair per IWP-3111, or shall be an analysis to demonstrate that the condition does not impair pump operability and that the pump will still fulfill its function. A new set of reference values shall be established after such analysis."
The OMc-1994 Addenda (ISTB 6.2.2) and all subsequent editions and addenda T
state that;
'If the measured test parameter values fall within the required action range of Table 5.2.1-1, Table 5.2.1-2, Table 5.2.2-1, or Table 5.2.3-1, as applicable, the pump shall be declared inoperable until either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and new reference values are established in accordance with ISTB 4.6."
The Code which was applicable for the second interval IST Program (ASME Section XI-1983 Edition with Sununer 1983 Addenda, Subsection IWi') and the latest issued edition (ASME OM Code-1995 Edition, Subsection ISTB) both provide for analysis of pump test data in lieu of arbitrary repair or replacement if the test parameters fall within the required action range. The OM Code-1990 Edition did not include such provisions. Therefore, based on the fact that the latest published version of the OM Code, Subsection ISTB, includes provisions (Continued on next page)
E II - 3 Rev.I
FNP 2 M4)94 PUMP RELIEF REQUEST RR-P-1 (continued) for evaluation of pump test data which is in the Action Range in lieu of arbitrary repair or replacement indicates that the ASME OM Code Committee supports evaluation as an acceptable approach. - Additionally, another GNC nuclear facility, Plant E.1. Hatch, requested approval to utilize the later OM Code requirements, relative to evaluation of pump test data (see E. I. Hatch IST Program, relief request RR-P-11), and was granted approval in an NRC Safety Evaluation Report dated April 12,1996.
Alternate Testing:-
Should pump test parameters fall within the required action range of Table ISTB 5.2-2 (OM Code 1990 Edition), then the pump will be declared inoperable until j
either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and the pump's continued L
operation at the changed values is supported in which case new reference values-L will be established. This analysis shall include verification of the pump's operational readiness. The analysis shall include both a pump level and a system i
level evaluation of operational readiness, the cause of the change in pump performance, and an evaluation of all trends indicated by available data. The degradation trend will be evaluated to confirm that the degradation mechanism will not cause sufficient further degradation such that it would be predicted that the pump would fail to be able to perform its required safety function before the next pump test or before repairs can be performed. The results of the analysis will be documented in the record of tests. This approach is consistent with that of the ASME OM Code 1995 Edition, Subsection ISTB, paragraph ISTB 6.2.2.
E 11 - 4 Rev.I u
ENCLOSURE 111 Unit 1(n Withdrawn Pump Relief Request RR-P-3 from FNP 1(2)-M-094 m
FNP-1.M-094 PUMP RELIEF REQUEST RR-P-3 This relief request has been withdrawn
-k E III - 1
%., i g.e
FNP-2-M-094 t.
PUMP RELIEF REQUEST RR P-3 This relief request has been withdrawn l
i E III - 2 Rev.1
e ENCLOSURE IV Unit 2 Revised Valve Relief Request Q2E13-RR-V-1 from FNP-2-M-094 L
l I
f
FNPo2-M 094 e
RELIEF REQUEST Q2E13-RR V-1 Valve:
QV002A, B
}
l l
Other Valve No: 8822A, B Drawing /Coord:. D-205038 Sht. 3/C-2 & F-2 System:
Containment Spray (E13)
Category:
C Class:
2 Function:
Containment spray pump discharge check valves OM Code Test Disassemble each check valve every refueling outage in accordance with Requirements:
ISTC 4.5.4(c).
I Basis for There are no system design provisions to verify full valve opening with flow Relief:
quarterly, at cold shutdown or refueling outage.
Therefore, per ISTC l
4.5.4(c) these valves will be disassembled / inspected at refueling outages to verify operational readiness. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
These valves are the same design (manofacturer, size, model number and material ofconstruction) and have the same service corditions including valve orientation, they meet the guidance of NRC Generic Letter 89-04, Position 2, for valve grouping. The alternate testing described below is based on GL 89-04, Position 2, guidance for valve grouping and sample check valve disassembly.
The inspection history of these valves suggests there is no need for disassembly / inspection of each valve each outage, thus any additional expense in doing so would be an unnecessary burden. The past six inspections for each valve dating back to 1985 have not detected any unsatisfactory conditions. On average, the disassembly / inspection of these valves requires 6 man-hours inside containment. Additional costs associated with planning, scheduling, supervision, documentation, etc. are also required for this task.
e Nonintrusive techniques cannot be employed to test these valves. They are located in the normally dry, empty containm:nt spray piping system inside containment. There is no way to open the valves with water flow at any time without risking damage to safety related equipmeat in containment. The valves are partial stroke tested with air but there is not a suflicient volume of air to fully open these 8" check valves even instantaneously for non-nonintrusive testing purposes.
(Continued on next page) ra E IV - 1 Rev.I
FNP 2-M494 l
l RELIEF REQUEST Q2E13 RR V-1(continued)
The lack of any altemative test method plus is excellent inspection history justi6es the staggered disassembly ~ schedule of one valve per outage and makes any testing beyond this level burdensome.
Alternate The alternate testing described below is based on GL 89-04 guidance for Testing:
valve grouping and sample disassembly.
. One of these valves will be disassembled and manually full stroke exercised at each refueling outage on 4. staggered basis. The valve internals will be i
verified to be structurally sound (no loose or corroded parts) and the disk I
manually exercised to verify fbil stroke capability. If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remt.ir: a valve will also be disassembled, inspected and manually full stroke exercised during the same outage. The disassembled valve will be prt stroked with flow aAer reassembly. The necessary vdve obturator movement, verifying pan stroke exercising, will be conArmed by chnges in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring devices, E IV - 2 Rev. !.
w
ii
'q ENCLOSUREV Unit 2 Revised Valve Relief Request Q2E13-RR-V-2 from FNP-2-Al 094 l
FNP-2-M494 o
RELIEF REQUEST Q2E13 RR V-2 Valve:
QV014 Other ValveNo:
8816 Drawing /Coord: D 205038 Sht. 3/E-10 System:
Containment Spray (E13)
Category:
C Class:
2 Function:
CTMT spray pump suction from RWST check valve.
OM Code Test Disassemble valve every refueling outage in accordance with ISTC 4.5.4(c).
Requirements:
Unsis for Tliere are no system design provisions to verify full valve opening with flow Reller:
quarterly, at cold shutdown or refueling outage, Therefore, per ISTC 4.5.4(c) this valve will be disassembled / inspected at refueling outages to verify operational readiness. No reliefis required for the above per OM ISTC 4.5.4(c) if the valve is disassembled every refueling outage.
l The inspection history of this valve suggests there is no need for disassembly / inspection of this valve each outage, thus any additional expense in doing so would be an unne:essary burden. The past six inspections of this valve dating back to 1985 have not detected any unsatisfactory conditions.
Nonintrusive techniques cannot be successfully employed to test this valve.
l This valve is located in the 12" Containment Spray (CS) pump suction line from the Refueling Water Storage Tank (RWST). The only normal water flow through this valve is approximately 150 ppm during quarterly CS pump testing. SNC engineers expeienced with nonintrusive check valve testing indicate that this application will not be successful because the 12" check valve will not fully open with 150 gpm flow.
Disassembly / inspection of this valve every outage would be an extreme burden. There is no installed valve which can be used to isolate the check valve from the RWST for disassembly. Isolation is accomplished by freeze sealing the line from the RWST. This procedure is done with the assistance of a freeze seal contractor. The process requires considerable planning, seneduling, specialized equipment and a large quantity of liquid nitrogen.
Several days are required for completing this praedure. There is also a potential for the freeze seal process to cause pipe cracking or deformation.
This requires Strict control of freeze rate and pipe temperature.
The roast recent freeze seal contractor cost exceeded $18,000. On average,50 FNp man-hours a e required to support the contractcr and to perform the (Continued on next page)
EV-1 Rev.1
FNP 2 M494 RELIEF REQUEST Q2E13 RR-V 2 disassembly / inspection of the valve. Additional costs associated with i
planning, scheduling, supervision, documentation, etc. are also required for -
this task.
The lack of any alternative test method, the excellent inspection history and i
the high cost of the freeze seal procedure ju - disassembly / inspection of this valve once every third refueling outage, l
Alternate The valve will be disassembled and manually full stroke exercised once every Testing:
third refueling outage using the freeze plug method described above. The valve internals will be verified as structurally sound (no loose or corroded parts) and the disk manually exercised to verify full stroke capability. The disassembled valve will be part stroked with flow after reassembly. The necessary valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or j
similar) flow measuring devices.
i Additionally, this check valve is partially exercised quarterly' during containment spray pump surveillance t-sting when flow is recirculated to the RWST.
)
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=
E V.2 Rev.I u
ENCLOSURE VI Unit 1(2. Revised Valve Relief Request Q1(2)E21 RR-%2 from FNP-1(2).M 094 l
I
FNP.I.M 094 4
RELIEF REQUEST QlE21-RR-V-2 Valve:
QV121 A, B, C Other Valve No: 8480A, B, C Drawing /Coord: D 175039 Sht. 6/F-4, G-4,11-4 System:
SI/CVCS Category:
C qass:
2 Function:
Charging Pump Minimum Flow Line Check Valve.
OM Code Test Disassemble each check valve every refueling outage in accordance with Requirements:
ISTC 4.5.4(c).
Basis for There are no system design provisions to verify full valve opening with flow Relief:
quarterly, at cold shutdown or refueling outage, Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operational ret,diness. No relief is required for the above per OM ISTC l
4.5.4(c) if each valve is disassembled every refueling outage.
These vahes are the same design (manufacturer, size, model number and material of construction) and have the same service conditions including valve orientation, they meet the guidimee of NRC Generic Letter 89 04, Position 2 for valve grouping for purposes of implernenting a disassembly / inspection sampling plan. The burden / justification for the proposed alternate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection of all three valves each outage, thus any additional expense it. doing so would be an unnecessary burden. The past twelve inspections of these valves (total both units) dating back to 1988 have not detected any unsatisfactory conditions.
On
- average, the disassembly / inspection of these valves requires 10 man hours. Additiond costs associated with planning, scheduling, supervision, documentation, etc.
are also required for this task.
The lack of any alternative test method plus the excellent in, ection history justifies the staggered disassembly / inspection schedule of one valve per outage and makes any testing beyond the proposed level burdensome.
(Continued on next page)
E VI-1 P.ev. I l
J
RIP.1 M 094 3
- REl,IEF REQUEST' Q1E21 RR-V 2 (continued)
Alternate -
The alternate testing described be!ow : based on GL 89 04 guidance for Testing:
valve grouping and sample disassembly.
One of these valves will be disassembled and manually full stroke tested at each refueling on a staggered test basis. The valve internals will be verified as.
structurally sound _(no loose or corroded parts) and the disk manually exercised to' verify full stroke capability, if the disassembled valve.1: not
- capable of being full stroke exercised or there is binding or failure of valve intemals, the remaining-valves in the group will also be disassembled, inspected, and manustly full stroke exercised during the same outage. The dirassembled valve will be part stroked with flow after reassembly. The i.
l necessary valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat l
leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring devices.
l l
EVI2 Rey,1 m
FNPo2 M 094 RELIEF REQUEST Q2E21-RR-V.2 Valve:
QV121 A, B, C Other Valve No: 8480A, B, C Drawing /Coord: D-205039 Sht. 2/F4, G-4,114 System:
SI/CVCS l
Category:
C-Class:
2 Function:
Charging pump minimum flow line check valve.
OM Code Test Disassemble each check valve every refueling outage in accordance with Requirements:
ISTC 4.5.4(c).
Basis for There are no system design provisions to verify full valve opening with flow Relief:
quarterly, at cold shutdown or refueling outage.
Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operational readiness. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
These valves are the same design (manufacturer, size, model number and material of estruction) and have the same service conditions including valve orientation, they meet the guldance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes of implement!ng a disassembly / inspection sampling plan. The burden justification for tha proposed alternate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection of all three valves each outage, thus any additional' expense in doing so would be an unnecessary burden. The past twelve inspections of these valves (total both units) dating back to 1988 have not detected any unsatisfactory conditions.
On
- average, the disassembly / inspection of these valves requires 10 man hours. Additional costs associated with planning, scheduling, supervision, documentation, etc.
are also required for this task.
The lack of any alternative test method plus the excellent inspection history justifies the staggered disassembly / inspection schedule of one valve per outage and makes any testing beyond this level burdensome.
(Continued on next page) t E VI 3 Rev.I
FNP.2 M-094 RELIEF REQUEST Q2E21 RR V-2 (continued)
Alternate The alternate testing described below is based on GL 89-04 guidance for Testing:
valve grouping and sample disassembly.
One of these valves will be disassembled and manually full stroke tested at each refueling on a staggered test basis. The valve internals will be verified as structurally sound (no loose or corroded parts) and the disk manually exercised to verify full stroke capability. If the disassembled vrJve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valves in the group will also be disassembled,
-inspected, and manually fbil stroke exercised during the.same outage. The disassembled valve will be part stroked with flow after reassembly. The necesnry valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring devices.
EVI4 Rev.I
5 ENCLOSURE VII Unit 1(2) Withdrawn Valve Relief Request Ql(2)E21-RR-V-3 from FNP-1(2).M-094 V' ' '
FNPoloM494 RELIEF REQUEST Q1E21 RR-V 3 This relief request has been withdrawn.
E VII 1 Rev.1
FNP 2 M494 RELIEF REQUEST Q2E21 RR-V-3 This relief request has been withdrawn.
E Vil - 2 Rev, !
8 t
ENCLOSURE VIII Unit 1(2) Revised Valve Relief Request Qi(2)N12 RR-V-1 from FNP-1(2)-M 094
FNP t M 094 d
RELIEF REQUEST Q1N12-RR-W1 Valve:
QV010A, B Other Valve No: NA Drawing /Coord: D 175033 Sht. 2/E-6, C-6 System:
Auxiliary Steam Category:
C Class:
3 Function:
Main Steam to TDAFW Pump Turbine.
OM Code Test Disassemble each check valve eveiy refueling outage in accordance with Requirements:
ISTC 4.5.4(c).
Basis for There are no system design provisivis to verify valve reverse flow closure Relief:
quarterly, at cold shutdown or refueling outage.
Therefore, per ISTC 4.5.4(c) these valves will be disassembled / inspected at refueling outages to verify operational readiness. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
These valves are the same design (raanufacturer, size, modi number and material of constmetion) and have the same service conditions including valve orientation, they meet the guidance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes of implementing a disassembly / inspection sampling plan. The burden / justification for the proposed alternate testing sampling plan is detailed belosv.
The inspection history of these valves suggests there __is no need for disassembly / inspection of both valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past seven inspections of these valves dating back to 1990 have not _ detected any unsatisfactory conditions. In early 1990 an inspection revealed a generic oversized hinge pin problem which restricted the ability of the disc to open fully. This problem was corrected per the vendors recommendations by remachining the pine. No service indend degradation was found with these valves. On average, the disassembly / inspection of these valves requires 9 man-hours.
Additional costs associated with planning, scheduling, supenision, documentation, etc. are also required for this task.
The lack of any alternative test method plus the excellent inspection history
-justifies the staggered disassembly / inspection schedule of one valve per outage and makes any testing beyond the proposed level burdensome.
(Continued on next page)
E VIII-1 Rev.I
l'NPol M494 RELIEF REQUEST Q1N12 RR V-1 (continued)
Alternate The alternate testing described below is based on GL 89-04 guidance for Testing:
valve grouping and sample disassembly.
One of thesc valves will be disassembled and manually full stroke tested at
~
each refbeling on a staggered test basis. The valve internals will be verified as structurally sound (no loose orroded parts) and the disk manually exercised to verify full stroke capability. If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining "alves in the group will also be disassembled,
_ inspected, and manually full stroke exercised during the same outage. The disassembled valve will be part stroked with flow after reassembly. The necessary valve obturator movement, verifying part stroke exercieng, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring devices.
1 d
-y-----
E Vill-2 Rev.1
IHP 2cM 094 RELIEF REQUEST Q2N12 RR-%1 Valve:
QV010A, B Other Valve No: NA Drawing /Coord: D 205033 Sht. 2/E-6, C 6 System:
Auxiliary Steam Category:
C Class:
3 Functiont Main Steam to TDAFW pump turbine.
OM Code Test Disassemble cach check valve every refueling outage in accordance with kequirements:
ISTC 4.5.4(c).
Basis for There are no systera design provisions to veri @ valve reverse flow closure Relief:
quarterly, at cold shutdown or refueling outage.
Therefore, per ISTC 4.5.4(c) these valves will be disart,embled at refueling outages to verify operational readiness. No relief is required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
l These valves are the same design (manufacturer, size, model number and material of construction) and have the same service conditions including valve orientation, they meet the guidance of NRC Generic Letter 89-04, Positior. 2 for valve grouping for purposes of implementing a disassembly / inspection sampling plan. The burden justification for the proposed alternate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need. for disassembly / inspection of both valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past seven inspections of these valves dating back to 1990 have not detected any unsatisfactory conditions. In early 1990 an inspection revealed a generic oversized hinge pin problem which restricted the ability of the disc to open fully. This problem war corrected per the vendors recommendations by remachining the pins. No service induced degradation was found with these valves. On average, the disassembly / inspection of these valves requires 9 man hours.
Additional costs associated with planning, scheduling, supevision, documentation, etc. are also requir d for this task.
The lack of any alternative test method plus the excellent inspection history justifies the staggered disassembly / inspection schedule of one valve per outage and makes any testing beyond this level burdensome.
(Continued on next page)
E VI!!- 3 Rev.1 i
9
_. _. _ _.. ~. _ _ - -
FNP 2.M494 i
RELIEF REQUEST Q2N12-RR-Y 1 (continued)
Alternate Tlu alternate testing described below is based on GL 89-04 guidance for Testing valve grouping and sample disassembly.
o One of these valves will be disassembled and manually full stroke tested at cach refueling on a staggered test basis. The valve internals will be verified as structurally sound (no loose or corroded parts) and the disk manually exercised to verify full stroke capability..If the disassembled valve is not
. capable of being full stroke exercised or there la binding or failure of valve internals, the remaining valves in the group will also be disassembled, inspected, and manually full stroke exercised during the same outage. The disassembled valve will be pan stroked with flow after reassembly. The necessary valve obturator movement, verifying part stroke exercising, will be confirmed by changes in syctem pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring devices.
1 E Vill 4 Rev.I
a s g
ENCLOSUREIX Unit 1(2) Withdrawn Valve Relief Request Q1(2)P16 RR V 1 from FNP-1(2)-M-094
FNP.I.M494
,, g RELIEF REQUEST QlP16.RR-%i This relierrequest has been withdrawn.
E IX 1 Rey, !
___-J
FNP 2 M-094 RELIEF REQUEST Q2P16 RR-%)
This relief reguest has been withdrawn.
l l
l l
E IX 2 Rev.I
_