ML20203L824
| ML20203L824 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/04/1998 |
| From: | Dacimo F COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20203L827 | List:
|
| References | |
| NUDOCS 9803060253 | |
| Download: ML20203L824 (6) | |
Text
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March 4,1998 United States Nuclear Regulatory Commission Attention: Document Control Desk Wakhington, D.C. 20555
Subject:
LaSalle County Nuclear Station 2nd Ten Year Interval Pump and Valve Inservice Testing (IST) Program Plan, Revision 2 LaSalle Coung Station, Units 1 and 2 Facility Operatirig License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Attached is a copy of the LaSalle County Nuclear Station 2nd Ten-Year Interval Pump and Valve Inservice Testing Program Plan, Revision 2, applicable relief requests, and applicable Piping and Instrument Diagrams.
' Revision 2 of the LaSalle County Nuclear Station 2nd Ten Year Interval Pump and Valve Inservice Testing Program Plan contains a number cf i
changes from the previous revision. These changas are due primarily to an IST Program Assessment (Final Report) dated February 24,1997, the development of a comprehensive IST program basis data base and a program scope review. The IST program anomalies ICentified during the IST program assessment were seported to the NRC in Licensee Event Reports (LERs) 373/96-06,96-019,96-019 Revision 1 and 96-019 Revision 2. The program anomalies for each unit will be corrected prior to the startup of Unit 1 and Unit 2.
7 included within Revision 2 of the LaSelle County Nuclear Station 2nd
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Ten-Year Iriterial Pump and Valve Inservice Testing Program Plan are changes to the AEME Code relief requests previously submitted in Revision 1 of the LaSalle County Nuclear Station 2nd Ten-Year Interval Pump and Valve Inservice Testing Program Plan. Pump relief requests RP-02 and RP-03 have been deleted and are hereby withdrawn. Valve relief requests RV-01, RV-02, RV-03, RV-04, RV-06, RV-07, RV-08 and RV-09 have been deleted and are hereby withdrawn.
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Pump relief request RP-01 (Attachment A) (previously granted by the NRC as identified by letter dated December 6,1996) has been revised to includ-the Reactor Core isolation Cooling (RCIC) Water Leg Pumps 1(2)E51 C003.
These pumps were not included in the previous revision of the Inservice Testing Program Plan. It is requested that the NRC evaluate this relief request prior to the restart of LaSalle County Station Unit 1.
Valve relief request RV-05 (Attachment B) (previously evaluated by the NRC as identified by letter dated December 8,1995) has been revised. The previous revision of RV-05 requested relief from the exercise test l
requirements of ASME/ ANSI OM, Part 10 (OM-10) section 4.3.2 It was determined by the NRC that the proposed testing was not a deviation from the Code requirements. A subsequent review of the function of the subject valves (Containment Vacuum Breaker Valves) indicates that they are also sub,'ect to the requirements of ASME/ ANSI OM, Part 1 (OM-1). RV-05 has been revised to request relief from the test requiremen'..: of Section l
1.3.4.3(a) of OM 1, It is requested that the NRC evaluate this relief request within 6 months.
If there are any questions or comments conceming the revised Inservice Test Program Plan or relief requests, please refer them to Perry Bames, Regulatory Assurance Manager, at (815) 357-6761, extension 2383.
Respectfully, Fred Dacimo Site Vice President LaSalle County Station Enclosure cc:
A. B. Beach, NRC Region lll Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle
. F. Niziotek, Office of Nuclear Facility Safety - IDNS 1
O Attachment A Pump Relief Reauest - RP-01 (Rev. 03)
Affected Components EPN Class Description 1(2)E22-C003 2
HPCS Water Leg Pump 1(2)E21-C002 2
LPCS Water Leg Pump 1(2)E12-C003 2
RHR Water Leg Pump 1(2)E51-C003 2
RCIC Water Leg Pump Test Requirement Lf-6 Section 5.2 Test Requirement: Flow Measurement Basis for Relief Instrumentation is not installed for measuring flow rates. Pump flow varies with system operation and system leakage; therefore, establishing flow rates for testing purposes is not practical. The primary purpose of these pumps is to maintain the HPCS, LPCS, RHR and RCIC pump discharge lines filleu to limit the potential for water hammer upon initiation.
System modification to provide rest measuring locations places undue burden on the utility without demonstrating any increase in the level of plant safety. These pumps are in continuous operation. Pump performance is continuously inonitored by a low pressure alamt on each HPCS, LPCS, RHR and RCIC pump discharge header.
LaSalle Station monitors the subject pumps for degradation by measuring and recording pump inlet pressure, discharge pressure, differential pressure, and vibration with the differential pressure and vibration data trended. These measurements are taken quarterly and provide satisfactory indication of operational readiness as well as the ability to detect potential degradation. In addition, the main ECCS pumps discharge headers each have a low pressure alarm which continuously monitors the operability of the respective water leg pump. Station Technical Specifications also verify operability of the water leg pumps by verifying flow through a high point vent on a monthly basis.
Alternative Test Vibration measurement will be obtained under normal operating conditions and ci/aluated in accordance with OM-6.
LaSalle verifies operability of these pumps by pressure maintenance of the HPCS, LPCS, RHR and RCIC pump discherge lines within allowable pressure limits. In addition, performance monitoring of the pumps' mechanical and hydraulic perfomiance is trended.
p Comed LaSalle County Station COMBINED UNITS 1 & 2 INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES Revision 2 y m, w. m.
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Attachment B Valve Relief Reauest - RV-05 (Rey 1)
Affected ComDonentS EPN Class Cat.
Description 1(2)PC001A 2
AC Suppression Chamber drywell Vacuum Breaker 1(2)PC001B 2
AC Suppression Chamber - Drywell Vacuum Breaker 1(2)PC001C 2
AC Supnression Chamber Drywell Vacuum Breaker 1(2)PC00lO 2
AC Suppression Chamber. Drywell Vacuum Breaker Test Reauirement OM-1, Section 1.3,4.3(a); Test Requirement (Containment Relief Valves): Within every 6 month period operability tests shall be performed unless historical d ta indicates a requirement for more frequent testing.
Basis for Relief The primary containment ensures that the release of radioactive materials will be restricted to those paths and associated leak rates assumed in the accident analyses. This restriction in a
conjunction with the leakage limitation, will limit the site boundary radiation dose to within the limits of 10 CFR Part 100 during accident conditions. The primary containment walls have a steel liner, which acts as a low leakage barrier.
The primary containment structure consists of a drywell area and a suppmssion pool area.
The primary function of the drywell is to contain the effects of a design-basis recirculation 4
line break and direct the steam released from a pipe break into the suppression chamber pool. The drywell contains a floor that serves as a pressure barrier between the drywell and suppression chamber and as a support structure for the reactor pedestal.
The primary function of the suppression chamber is to provide a reservoir of water capable of condensing the steam flow from the drywell and collecting the non-condensable gases in the suppression chamber air space.
Vacuum relief valves are provided between the drywell and suppression chamber to prevent exceeding the drywell floor negative design pressure and backflooding of the suppression pool water into the drywell. The vacuum relief valves are designed to equalize the pressure between the drywell and wetwell air space regions so that the reverse pressure differential across the drywell floor will not exceed the design value of five pounds per square inch.
This is needed to maintain the structural integrity of the primary containment under conditions of large differential pressures. Therefore, the subject relief valves are considered containment relief valves and are subject to the testing requirements outlined in sections 1.3.4.3(a) and 3.3.2.3 of OM-1 for Class 2 and 3 containment vacuum relief valves.
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The vacuum relief valves (four assemblies) are outside the primary containmem,d form an extension of the primary containment boundary. The vacuum relief valves are mounted in special piping which connects the drywell and suppression chamber, in each vacuum breaker assembly, there are two local manual butterfly valves, one on each side of the vacuum breaker, which are provided as system isolation valves should failure of the vacuum breaker occur and as isolation valves for testing. The vacuum relief valves are instrumented with redundant position indication in the main control room. The valves are provided with the capability for local manual testing.
In accordance with the requirements of LCNS Technical Specification Surveillance Requirement 4.6.4.1, each vacuum breaker is verified to be closed at least once per 7 days, full-stroke exercised at least once per 31 days and within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after discharge of steam to the suppression chamber from the safety-relief valves. Additionally, both of the position indicators for each valve are verified operable at least once per 31 days, in addition to the above, the force required to open each vacuum breaker, from the closed position is verified to be less than or equal to 0.5 psid and the leakage rate of each vacuum breaker valve is verified at least once per 18 months.
The 6 month operability tests identified in section 1.3.4.3(a) of OM-1 refer to the open and close capability (exercise) tests, set pressure tests, and performance tests of any pressure and position sensing accessories outlined in section 3.3.2.3 of OM-1 for Class 2 a.nd 3 vacuum relief valves. Section 1.3.4.3(b) of OM-1 specifies that valve leakage tests be performed every 2 years unless historical data indicates a requirement for more frequem testing.
Additionally, since these valves are check valves, section 4.3.2.1 of OM-10 requires that the subject valves be exercised every 3 months.
A compa.. :on of the LCNS Technical Specification surveillance requirements, OM-1 and OM-10 test requirements for the subject valves indicates that the testing frequencies identified in the Technical Specification are more limiting in all instances except for the performance of the valve setpoint tests.
There are two primary methods to verify opening.vetpoints for these types of vacuum breaker valves. Manual exercising while measuring breakaway torque or a valve setpoint l
test using air. As stated above the subject valves are provided with the capability for local manual testing. However, this method was determined to be impractical because of the inconsistencies in the test data identified during preoperational testing. This test method was identified as an open item (373/81-28-07) by the NRC. Resolution of this issue included a commitment to perform this testing using pressurized air.
It is impractical to verify vacuum breaker setpoints using air every 6 months during plant operation. Verifying vacuum breaker setpoints requires the closure of the two me.2ually operated be:terfly valves upstream and downstream of the subject valves, the hook up of air supply hoses, the pressurization of a large volume of piping and blowdown of air inventory into the nitrogen inerted drywell. Since the two manually operated butterfly valves must be
closed to the perform this test, a Technical Specification Action Statement must be entered for the sole purpose of performing this test A review of the maintenance history of the subject valves tested at the 18 month Technical Specification frequency indicates that there have not been frequent failures of these valves to relieve pressure as designed. Addi ionally, the 18 month Technical Specification setpoint t
test frequency is consistent with the two year test frequency outlined in section I 1.3.7 of mandatory Appendix 1of the 1995 Edition of the ASME OM Code.
Alternaeve Test LaSalle will setpoint test these valves in accordance with the 18 month setpoint test frequency identified in section 4.6.4.1 of the LCNS Technical Specifications.