ML20205P496
| ML20205P496 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 11/02/1988 |
| From: | Richey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLS-88-259, NUDOCS 8811080173 | |
| Download: ML20205P496 (7) | |
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Carolina Power & Light Company NOV 0 21988 SERIAL: NLS-88-259 10CFR50.55a United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PIANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50 324/ LICE!'SE NOS. DPR-71 & DPR-62 i
ASME CODE RELIEF REQUEC2 DIESEL CENERATOR STARTING AIR CHECK VALVES Centlemen:
Conformance with ASME ection XI, Subsection IWV 3520 code requirements is impractical for the Brunswick Steam Electric Plant (BSEP) diesel generator starting air check valves. Therefore, pursuant to 10CFR50.55a(g)(5), Carolina Power and Light Company (CP&L) herein requests relief frorn IWV-3520 for the subject valves. NRC review and approval is needed to suppott the upcoming BSEP 1 refueling outage which is scheduled to begin November 12, 1988.
BACKGROUND ASME Section XI, Subsection IWV-3520 is a testing procedure for check valves that requires full stroke exercising during cold shutdowns for all Category v check valves not full stroke exercised during plant operation. In addition, this subsection requires confirmation that each check valve disk is on its seat, and/or moves away from its seat, by visual observation, by electrical signal initiated by a position indicating device, by observation of appropriate pressure indications in the system, or by other positive means.
Literal compliance with these requirements is impractical fer the subject valves because there are no external or remote means to verify valve position during system operation, nor is there an external means to manually cyclo the valves.
On November 24, 1987, purcJant to 10CFR50.55a(g)(4), CP&L submitted r.
revised In Service Testing (IST) Program which included relief request number VR 26 for the diesel generator starting air valves, and program remark number V 08 which included both the diesel generator starting air check valves and the diesel generator starting air (jet assist) valves.
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Document Csntrol-Dsck' NLS-88 259 / Page 2 Subsequent to this submittal, CP&L has completed a review of periodic test procedures for these check valves and has determined that relief request number VR-26 and program remark number V-08 should be amended.
The primary purpose of the revision to VR-26 and the new relief request VR-31 is that the diesel, of which these valves are a part, must be shut down and inspected at least every 18 months in accordance with Technical Specification 4.8.1.1.2.d.1.
Plant procedures are being revised to take credit for disassembly of these valves during these shutdowns.
This represents a more conservative approach than identified in the previous program submittal in that 100% of the subject valves will be examined overy 18 months versus the sampling required by the previous program.
Thu change in V 08 will allow the sample disassembly valves to be examined over a 2 year interval versus the current requirement of each refueling outage. This will provide more flexibility to the pisnt in that some of the valve disassemblies may be performed during t 4 tem outages versus exclusively during unit refueling outages as currently required by program note V 08.
For these reasons, revised relief request number VR-26, revised program-remark number V 08, and additional relief request VR-31 are enclosed for your review and approval.
ADMINISTRATIVE INFORMATION In accordance with the requirements of 10CFR170.12, a check for $150 was remitted on February 18, 1987, via CP&L letter NLS-87 038, as payment of the application fee for the BSEP second interval In-Service Testing Program. An additional fee for this request is not considered necessary because:
1)
CP&L has not received NRC approval of the BSEP In Service Testing Program that was submitted on November 24, 1987, and 2) this request is just superceding a small portion of the referenced program.
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"I Document CsntrS1 Desk NLS-88-259 /-Page 3 A BSEP-1 refueling outage is scheduled-to begin on November 12, 1988, with testing of the subject valves scheduled to begin December 5,1988 To support this outage, the Company requests your approval of this request by November' 21, 1988.
Please refer'any questions regarding this submittal to Mr. Stephen D.
Floyd at (919) 836-6901.
Yours very truly, 1
R. B. Richey Manager Nuclear Services Department PDM / pdm (\\cor\\ISTRRDG)
Enclosure cc:
Mr. M. L. Ernst Mr. W. H. Ruland Mr. B. C. Buckley 1
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ENCIDSURE 1 TO SERIAL NLS-88-259 DIESEL GENERATOR STARTING AIR CllECK VALVES REVISED RELIEF REQUEST VR-26 REVISED PROGRAM REMARK V-08 ADDITIONAL RELIEF REQUEST VR-01 i
RELIEF REQUEST NO. VR-26 S;* stem :
Diesel Generator Starting Air (Jet Assist)
Component:
DSA-V141 DSA-V149 DSA-V142 DSA-V150 DSA-V145 DSL-V153 DSA-V146 DSA-V154 Function:
Isolate left header from right header upon loss of left header and vice versa.
Category:
C Class:
Non-Classed Test Requirements:
Full stroke 9xercise valves to the closed position quarterly.
Basis for Relief:
There is no external / remote means to verify valve position during system operation nor is there an external means to manually cycle the valves. There is no way to isolate these valves and no test / vent connection to verify valve closure.
These valves are presently disassembled every 18 months in accordance with BSEP Technical Specification 4.8.1.1.2.d.1.
Alternate Testing:
Disassemble and manually cycle valves every 18 months.
(100CRS)
Revised 11/88
J PROGRAM REMARK 'J0. V-08 The check valves included in the check valve-disassembly program are grouped according to type, size, operating medium, and manufacturer' The groupings are listed below. -
SAMPLEDISASSEMBdYGROUPINGS i
Applicable Applicable Group Valve Group Valves SDG-1-1 1-E11-F089 SDG-5-1 1-SW-V200 t
1-E11-V193 1-SW-V201 1-SW-V202 SDG-1-2' 2-E11-F090 1-SW-V203 2-E11-V193 1-SW-V204 1-SW-Y205 f
i SDG-5-2 2-SW-V200 SDG-2-1 1-E41-F019 2-SW-V201 1-E41-F045 2-SW-V202 2-SW-V203 SDG-2-2 2-E41-F019 2-SW-V204 2-E41-F045 2-SW-V205 1
SDG-6-1 1-E11-F046A SDG-3-1 1-E21-F030A 1-E11-F046B 1-E21-F030B 1-E11-F046C 1-E41-V93 1-E11-F046D 1-E41-F046 SDG-3-2 2-E21-F030A 2-E21-F030B SDG-6-2 2-E11-F046A j
2-E41-V93 2-E11-F046B 2.
2-E11-F046C SDG-4-1 1-SW-V272 2-E11-F046D j
1-SW-V273 2-E41-F046 1-SW-V274 l
1-SW-V275 SDG-4-2 2-SW-V272 2-SW-V273 2-SW-V274 2-SW-V275 One check valve of each group will be disassembled and manually exercised every two years for the respective unit.
If any check valve fails, another check valve from the same group shall be tested.
If this valve fails, the remaining check valves in the applicable group shall be tested.
(100CRS)
Revised 11/88
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' RELIEF REQUEST NO. VR-31 System:
Diesel Generator Starting Air
- i Components: '
DSA-V21 DSA-V81 DSA-V33 DSA-V93 3
~DSA-V51 DSA-V111 DSA-V63 DSA-V123 Function:
Diesel Generator Starting Air Compressor Discharge Check Valves close upon loss of compressor.
Category:
C
' Class:
Non-Classed Test Requirements:
Full Stroke exercise valves to the closed position.
Basis for Relief: -
There is no external / remote means to verify valve position during system operation nor is.there an external means to manually cycle the valves. There are no existing vent paths upstream of the' check valves to perform a reverse flow test. These valves are presently disassembled every 18 months in accordance with BSEP Technical Specification 4.8.1.1.2.d.1.
Alternate Testing:
Disassemble and manually cycle valves every 18 months.
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(100CRS)
Additional 11/88
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