ML20199H027

Requests Relief from Requirements of OM-1-1987, Requirements for Inservice Performance Testing of NPP Pressure Relief Valves, Part 1.3.3, Test Frequency,Class 1 Pressure Relief Devices for Prvs

ML20199H027
Person / Time
Site:	Waterford
Issue date:	01/14/1999
From:	Ewing E ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-99-0013, W3F1-99-13, NUDOCS 9901250094
Download: ML20199H027 (5)

Text

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y Ent gy Operrtions,Inc. '1 Killona. LA 70066 Tel 504 739 6242 Early C. Ewing.111

(: Dwector ar Safety & Regulatory Mairs I

E e W3F1-99-0013

!^ A4.05 L PR l

January 14,1999 -

U.S. Nuclear Regulatory Commission

) ATTN

Document Control Desk Washington, D.C. 20555 l

Subject:

Waterford 3 SES Docket No. 50-382

! License No. NPF-38 Pressurizer Code Safety Valves Relief Reqmi Gentlemen:

o i

Entergy, on behalf of Waterford 3, is hereby requesting relief from the requirements of OM-1-1987, " Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices", Part 1.3.3, Test Frequency, Class 1 Pressure Relief

j. Devices for the pressurizer relief valves. This code requires that a minimum of 20%

of the sample group population be tested every 24 months.' Thus, Entergy is required by the code to test one pressurizer relief valve every 24 months. However, both pressurizer relief valves are currently tested every 24 months at Waterford 3.

I The attached request supports relief from the testing requirements for a period of time up to 6 months past the next scheduled test, which would be required on September 21,2000. Entergy is requesting relief in accordance with 10CFR50.55a

- (a)(3)(i), "The proposed alternatives would provide an acceptable level of quality and i

. safety." The basis for this request is that the valves were replaced on September 21, 1

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1998, approximately 5 months prior to the scheduled start of Refueling Outage 9 on  ;

February 19,1999. Currently, Refueling Outage 10 is scheduled for September 15, '

2000, which would be within the 24 month interval of the last replacement. However, l. 4 due to mid-cycle outages during Cycle 9, it is likely that the start date for Refuel I;)

i Outage #10 will be revised to September 29,2000. This would cause the 24 month L

interval to be exceeded. If this request is not granted, testing of one of the two pressurizer relief valves will be required during Refuel 9. Therefore, Entergy

requests a response prior to February 19,1999. This request has been discussed

. with Mr. David Wigginton and Mr. Chandu Patel of the NRC Staff. $U 7L>n; a' +: :PDR 9901250094 ADOCK 05000382 990114 E

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!- Pressurizer Code Safety Valves Relief Request W3F1-99-0013

! Page 2

- January 14,1999 i

L Very truly yours, i i -

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/' E C Ewing Director i Nuclear Safety & Regulatory Affairs i i

ECE/ CWT

! Attachment cc: E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR l J. Smith l N.S. Reynolds l NRC Resident inspectors Office l

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, Attachment 1 to  ;

l W3F1-99-0013 l Page 1 of 3  :,

p l j r VRR-07 " Pressurizer Relief Valves"  !

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' Component (s) Affected:

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! . RC MVAAA317 A Valve RC MVAAA317 B Valve

Test Reauirement

OM-1-1987, " Requirements for Inservice Performance Testing of Nuclear Power Plant i Pressure Reliei Devices", Part 1.3.3, Test Frequency, Class 1 Pressure Relief Devices,  !

requires that a minimum of 20% of the sample group population be tested every 24 months. i l '

Basis for Relief:

This is a one-time exemption from the Code requirement to test Waterford 3's  !

i pressurizer safety valves at an interval not to exceed 24 months. The proposed l

. , altemative includes (a) performing the testing and/or valve replacement during  ;

Waterford's tenth refueling outage expected to begin on September 29,2000, or (b) ,

performing the testing and/or valve replacement during a Mode 5 outage of sufficient '

duration as described below under Attemate Testing. In Entergy's judgment, the - ,

proposed alternati/e provides an acceptable level of quality and safety.  :

L Waterford 3's Class 1 pressurizer relief valves were replaced during an outage on September 21,1998. Waterford 3 shutdown to replace one of the relief valves which was leaking to the quench tank causing operational contingencies to be implemented.

The non-leaking relief valve was also replaced to maintain the same testing schedule for both valves. The replacement valves were installed on September 21,1998,

• approximately five months prior to the scheduled start of Refuel Outage #9 on February 19,1999. Currently, Refuel Outage #10 is officially scheduled to begin on September 15,2000. However, due to mid-cycle outages during Cycle 9, it is likely that the start date for Refuel Outage #10 will be revised to September 29,2000. As a result of this expected schedule revision, the 24 month period between Code required testing for the two relief valves will expire before the start of Refuel Outage #10.

L The intent of OM-1 is to periodically monitor the valves for degradation and to take any L appropriate corrective actions based on test results. It is reasonable to conclude that

extending the test interval by approximately one week does not significantly impact the I

ability to meet the Code intent. An extension of 6 months (25% of the test interval) is f'

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Attachment 1 to W3F1-99-0013 l

Page 2 of 3 l

also considered reasonable since it is consistent with the allowable extension provided I by Technical Specification 4.0.5 (c) for other surveillance intervals. Such a lengthy extension could be necessary to accommodate mid-cycle forced outages that may cause the start date of Refuel Outage #10 to be later than presently scheduled.

Test results for the past three tests of the two currently installed relief valves were reviewed. The as-found test data was satisfactory in three of the six cases reviewed. I In two of the remaining cases, the as-found setpoint was not in tolerance. However, as documented in LER 95-003, the setpoint variation was attributed to the " jack-and-lap" process used to recondition the valve seats. As a corrective action, Entergy revised the l testing procedures to require steam set pressure verification when the " jack-and-lap" process is used. In the third case where a failure was noted, the temperature profile I used to test the valve was not the same as the profile used to establish the setpoint for !

the previous cycle of operation. As documented in LER 93-009, this resulted in an l apparent setpoint drift when significant drift did not actually occur. The three failures i were the result of maintenance / test practices and not indicative of active degradation mechanisms. Therefore, the performance history of these valves is considered to be satisfactory to support this extension.

Although valve seat leakage during plant operation has been observed, this presents only operational and not safety problems. Seat leakage during plant operation is routed to the quench tank. As quench tank levelincreases, plant operators must periodically drain its contents to limit tank pressure and avoid relief through the rupture disc.

Leakage from one or both relief valves can be monitoied by plant operators using valve tailpipe temperature indicators and by periodic Reactor Coolant System (RCS) leakrate calculations required by plant Technical Specifications. If leakage becomes excessive, appropriate actions will be taken.

Extending the current test interval, as given in the Altemate Testing section below, provides an acceptable level of quality and safety, it eliminates the need to repeat the extensive tasks associated with replacing these large components during Refuel Outage #9 after having just performed this work five months earlier. These six-inch valves weigh in excess of one thousand pounds and are located in the pressurizer cubicle inside containment. It is desirable from a personnel and equipment safety standpoint not to remove the valves after such a short time in service. Valve replacement requires approximately 200 man-hours of effort including extensive scaffolding / rigging. It results in approximately 700 millirem of exposure and impacts other work activities inside containment during valve movement.

Attachment 1 to W3F1-99-0013 Page 3 of 3 Alternate Testina:

With the exceptions given in items 1 and 2 below, the pressurizer relief valves will be satisfectorily tested in accordance with OM-1 requirements or replaced with pre-tested valves during Refuel Outage #10 currently expected to begin on September 29,2000.

1. If a Mode 5 outage of sufficient duration occurs anytime during Cycle 10 and the start of Refuel Outage #10 is (or has previously been) delayed by 6 months or more beyond September 21,2000 (the current testing due date), valve testing and/or replacement will be performed.

2. If refueling Outage #10 occurs after September 21,2000, valve testing and/or replacement will be performed during the first Mode 5 outage of sufficient duration after September 21,2000. In any event, valve testing and replacement will occur pricr to March 21,2001.

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