ML20206J142
| ML20206J142 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/06/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8606270018 | |
| Download: ML20206J142 (28) | |
Text
- - _ _
TENNESSEE VALLEY AUTHORITY CH ATTANoOGA. TENNESSEE 374ot SN 157B Lookout Place June 6, 1986 Director of Nuclear Reactor Regulation Attention: Mr. B. Youngblood, Project Director PWR Project Directorate No. 4 Division of Pressurized Water Reactors (PWR)
Licensing A U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Youngblood:
In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 By the April 5, 1985 letter from T. M. Novak to H. G. Parris, NRC transmitted to TVA the Safety Evaluation Report (SER) for the Sequoyah Nuclear Plant Inservice Testing (IST) Program for Pumps and Valves (P/V). As a result of telephone conversations and a July 2, 1985 meeting with NRC representatives, TVA submitted a revised P/V IST program for SQN units 1 and 2 on August 16, 1985 by letter from J. A. Domer to E. Adensam, as well as an item-by-item response to the SER for the P/V IST Program. A revised SER is to be provided by NRC following review of these submittals.
Additional revisions to the August 16, 1985 submittal are necessary and are being provided in enclosures 1 and 2 which revise enclosures 1 and 2, respectively, to the August 16, 1985 letter. A brief summary description of the revisions is provided with the enclosures to this letter. We believe that these changes in the P/V IST Program are consistent with the philosophy and guidelines previously discussed with the NRC and incorporated in the P/V IST Program. We understand review of the August 1985 submittal has not been completed and, therefore, request these additional revisions be reviewed in conjunction with that submittal.
In an attempt to preclude unanticipated issues from occurring which could impact either startup or plant operations following startup, and to assure NRC concurrence with the SQN P/V IST implementing program, we request that a written response be provided following NRC review of these submittals as soon as practical. If preparation of the full revised SER cannot be completed to
, support plant startup, a written response documenting NRC review and concurrence with the SQN program will be beneficial. To expedite and provide assistance to the NRC in meeting this request, we request a meeting with NRC representatives the week of June 23 or June 30, 1986, to discuss the P/V IST Program in detail, including the preliminary Safety Evaluation Report (SER),
8606270018 860606 7 PDR ADOCK 0500 P
f An Equal Opportunity Employer
Director of Nuclear Reactor Regulation June 6, 1986 1
d the August 16, 1985 letter and the revisions included in this letter. We believe a meeting between appropriate NRC and TVA representatives to review and discuss all issues will best facilitate arrival at a mutually agreed upon basis for our P/V IST program.
In consideration of the numerous revisions to the SQN P/V IST program which have been required since licensing and the anticipated receipt of the revised SER, we would like to document our position regarding future revisions to the program. 10 CFR 55a(q) states that the inservice inspection program "shall be revised by the licensee, as necessary, to meet the requirements" of 10 CFR 55a(q)(4). Specification 4.0.5 of the SQN technical specifications states that the ". . . . inservice testing of ASME Code Class 1,2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 55a(q), except where specific written relief has been granted by the Commission . . ..
Therefore, only those changes requesting relief or a deviation from ASME Code requirements, will be submitted to NRC for approval before implementation. Notification of other changes to the P/V IST Program will be provided to NRC as soon as practical following revision of the P/V IST Program for SQN. The changes to the P/V IST Program will also be provided to the NRC in the annual update of the SQN Final Safety Analysis Report (FSAR).
Very truly yours, TE E SE LEY AUTHORITY R. idley, D rector Nuclear Safe and Licensing Enclosures cc (Enclosures):
U.S. Nuclear Regulatory Commission Region II Attn: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Carl Stahle Sequoyah Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814
Summary D3scription of Rsvisions ProvidId in Enclosures 1 and 2 A brief description of the revisions is provided below.
- 1. Clarification is provided regarding when pump suction pressure measurement prior to pump start is required.
- 2. Relief is requested to part stroke exercise the AFW pump recirculation check valves 3-894 and 3-895 using a single AFW pump during quarterly pump tests and full stroke exercise the check valves not less than once every two years. -
- 3. Centrifugal charging pump miniflow valves FCV-62-98 and FCV-62-99 are changed from category B-Active to B-Passive valves due to power being removed from the valves for both normal and accident conditions.
- 4. Clarification is provided regarding the part stroking test configurations j for safety injection, residual heat removal, and UHI system check valves63-551, 63-553,63-555, 63-557,63-543, 63-545,63-547, 63-549,63-558, f 63-559, 63-632,63-634, 63-633,63-635, 63-640,63-643, 63-641,63-644, 87-558,87-559, 87-560,87-561, 87-562, and 87-563. Parallel valves will be part stroked in combination on the same basis that was previously identified and approved for the BIT injection check valves (see PV-6 and SER 3.4.2.4.). !
- 5. Specific reference for using an RHR pump is removed from PV-16 for the safety injection system primary check valves63-560, 63-561,63-562, and 63-563; these valves may be part stroked using the RHR or safety injection pumps.
- 6. Relief is requested from stroke time testing the reactor head vent system l throttle valves FSV-68-396 and FSV-68-397.
- 7. Relief is requested to exercise RHR return valves FCV-74-1 and FCV-74-2 only during shutdown and/or startup.
- 8. Clarification is provided regarding the proposed Technical Specification 4
revision which will add UHI valves FCV-87-7 and FCV-87-8 to the list of pressure isolation valves.
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ENCLOSURE 1
-AMENDMENT TO ENCLOSURE 1 -
REVISED SUBMITTAL OF "SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 PUMP AND VALVE INSERVICE TESTING PROGRAM"
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' SIQ1LOYAH NUCLEAR POWER PLANT TABLE A - PUMP TEST PROGRAM Drawing Inlet Otfrerential Flow Vibration Eym_n Number Soeed Pressure Bearing Observe Lube 01 Pressure Batt Amolitude Temocrature Level / Pressure (Note 12) (Note 2) n Pi Ap Q V To i
Auxiliary Feed 47W803-2 Note 1 Q*
Q Q Q Note 7 Yes W1ter (Motor)
Auxiliary Feed 47W803-2 Q Q Q Q Q Note 7 Yes Water (Steam)
CIntrifugal 47W811-1 Note 1 Q Q Q Q Q Yes Charging 47W809-1
< Safety Injection 47W811-1 Note 1 0 Q Q Q Q Yes l ,
System Essential Raw 47W845-5 Note 8 Q Note 4 Note 4 hote 5 Cooling Water !!ote 7 Note 3 Note 9 Componet 47W859-1 Note 1 Q Note 4 Note 4 Q Note 6 Yes Cooling i
Contaiment 47W812-1 Note 1 Q Spray Q Q Q Note 6 Yes l
Rasidual Heat 47W810-1 Note 1 Q Q Removal Q Q Note 8 Yes
[ ,
l Diesel Fuel Oil 47W840-1 Note 1 Note 10 Note 10 Note 7 Transfer Q Q Note 10 Note 11 Boric Acid 47W809-5 Note 1 Transfer Q Q Q Q Note 6 Yes l
j i
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1 7
_ . .__ ~ __,_., ._. - - _ , . . . _ _ . _, - , . _ - - . - . . . . _ . . . ~ . . _ . _
NOTES (continued)
- 11. The only means of measuring flow rate on these pumps is by measuring a level increase in the day tank while the pumps are running. Accuracy using this indirect method of measuring flow rate is poor. Even with poor accuracy, the 10 gpm limit will provide adequate margin for allowing the pumps to fulfill their intended function. Therefore, the B 10 gpm limit is established in lieu of the ranges given in IWP-3100-2.
- 12. Table IWP-3100-1 requires inlet pressure to be measured both before pump startup and during test. Measurement before pump startup is -
interpreted as a requirement intended only for pumps which are not already in service prior to testing, e.g. , an operating charging pump would not be stopped to record inlet pressure and then restarted to perform test. This measurement only provides indication / verification of adequate NPSH prior to pump start; this indication of pump operational readiness is not applicable for an operating pump.
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Sequoyah Nuclear Plant inservice Valve Testing Program j (3) AUXILIARY FEEDWATER DRAWI!1G !!O: 47M803-2 (R19)
N $
08 > M g HO VALVE -
y U$ $o 'ga $w $ ca k~U TESTI!!G Dy hM UtiBER 4y j ?"k h O N m
d$ la$$S
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$!gN O
REQUIRED ~ Ug MM id $ REMARKS a8U W = g3 o gN B" 4
4 3-872 2 D-9 C ,4 CK SA .- CV-1 X YES See PV-12 3-873 2 C-9 C 4 CK SA -
CV-1 X YES See PV-12 3-374 2 A-9 C 4 CK SA -
CV-1 X YES See PV-12 3-891 3 B-8 C 4 CK SA -
CV-1 X YES See PV-9, Pump Test 3-892 3 A-8 C 4 CK SA -
CV-1 X YES See PV-9, Pump Test 3-894 3 A-6 C-ACT 3 CK SA -
CV-1 X YES See PV-20 3-895 3 A-6 C-ACT 3 CK SA -
CV-1 X YES See PV-20 3-921 2 G-10 C 4 CK SA -
CV-1 X YES See PV-12 3-922 2 E-10 C 4 CK SA -
CV-1 X YES See P/-12 e
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Sequoyah Nuciarr Plant inservico Valvo Tcsting Program (62) CHEMICAL & VOLUME CONTROL SYSTEM DRAWING NO: 47W809-1 (R19) l (39 >< M ~ p $9 VALVE m d$ $ ra ta O ra %y TESTING Ny hO NUMBER 3 y y $ dy REQUIRED UD Ex! $ REMARKS k N O" >H m >b h@6 9m g
Mg My 8
U 6 4 g FCV-62-61 2 B-7 A-ACT 4 GA HG O CS, SLT l
FCV-62-63 2 B-8 A-ACT 4 GL H0 0 CS, SLT -
FCV-62-72 2 A-5 A-ACT 2 GL DIA C QT-1, SLT l FCV-62-73 2 A-4 A-ACT 2 GL DIA 0 QT-1. SLT .
FCV-62-74 2 A-4 A-ACT 2 GL DIA C QT-1, SLT ,
FCV-62-11 2 A-7 A-ACT 2 GL DIA 0 QT-1. SLT FCV-62-90 2 D,- 7 B-ACT 3 GA H0 0 QT-1 FCV-62-91 2 D-8 B-ACT 3 GA MO O QT-1 l FCV-62-132 2 E-10 B-ACT 4 GA H0 0 CS l
FCV-62-133 2 E-10 B-ACT 4 GA MO O CS l
LCV-62-135 2 H-10 B-ACT 8 GA NO C CS l
LCV-62-136 2 H-10 B-ACT 8 GA MD C CS l
62-504 2 H-10 C 8 CK SA -
CV-1 X ER See PV-2 l
62-505 2 F-10 C 3/z REL SA C l
62-548 2 F-9 C 3/4 REL SA C l
62-519 2 F-9 C-ACT 3 CK SA C CV-1 l
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Sequoyah Nuclear Plant inservice Valve Testing Program c (74) RESIDUAL HEAT REMOVAL SYSTEM DRAWIfiG 110: 47W810-1 (R11)
N O E4 Se rt; g H (5 VAINE
- Ca] $ bN NO ' D1 NM OM 7h TESTIFIG Dy hU NUMBER [A j NO N d$ '# $ $! Ed REQUIRED ~ UD N$ REMARKS U a O N E N FCV 74-1 1 G-3 A-ACT 14 GA HO .C CS, SLTP X YES See PV-19 FCV 74 2 1 G-3 A-ACT 14 GA M0 C CS, SLTP X YES See PV-19
- FCV 74 3 3 E-9 B-ACT 14 GA M0 O QT-1 FCV 74-12 2 F-6 B-ACT 2 GA MO O QT-1 FCV 74 16 2 F-4 B-ACT 8 BUT DIA 0 OT-1 FCV-74-21 2 C-9 B-ACT 14 GA MO O QT-1 FCV-74-24 2 B-6 D-ACT 2 GA MO O QT-1 FCV-74 28 2 C-4 B-ACT 8 BUT DIA 0 QT-1 FCV-74-33 2 E-4 B-ACT 8 GA M0 O CS FCV-74-35 2 C-4 B-ACT 8 GA M0 O CS74-505 2 G-3 C 3 REL SA C RF 74-514 2 F-7 C 8 CK SA -
CV-2 Pump test: See Table 0-1 74-515 2 C-7 C 8 CK SA -
CV-2 Pump test: See Table 0-1 s
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a.
PV-5 System: Safety Injection System Valve: 63-551* 63-553* 63-555* 63-557* 63-543,63-545, 63-547,63-549, 63-558,63-559 Class: 1 Category: AC Function: Opens to admit flow from SIS pumps to RCS during LOCA and closes to prevent intersystem LOCA.
Impractical Requirement: Exercise quarterly at full flow.
Basis for Relief: SIS pumps do not develop sufficient head to overcome normal RCS pressure. Use of another pump would result in an undesirable temperature transient in the RCS. Letdown
^
capability will not allow full flow testing with reactor head on.
Technical Specification 4.4.6.2.2 requires these valves to be leak tested following valve actuation and during cold shutdown if they have not beeri leak tested in the last nine months. The first (4) valves *are aligned in parallel; the last six valves are aligned in parallel in groups of (2) as listed. Individual branch line flows are only measured during refueling outage testing since plant instrumentation is not available to measure individual branch flows. Therefore, relief is requested to allow partial stroking of parallel valves in combination during cold shutdown not to exceed once per nine months and full stroke exercising during refueling outages during system performance tests.
Valve closure will be verified during cold shutdown, not to exceed once par nine months when the pressure isolation boundary leak test required by Technical Specification 4.4.6.2.2 is performed.
Alt.
Testing: Part stroke exercise parallel valves in combination during cold shutdown and full stroke exercise during refueling outages. Leak test as required by Technical Specification 4.4.6.2.2.
Frequency for Alt.
Testing: Part stroke every cold shutdown not to exceed once per nine months and full stroke each refueling outage. Leak test at the frequencies required by Technical Specification 4.4.6.2.2.
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r, PV-8 System: Safety Injection System Valve: 63-632, 63-634,63-633, 63-635,63-640, 63-643,63-641, 63-644.
Class: 1 Category: AC Function: Opens to admit flow from RHR pumps to RCS during LOCA'and closes to prevent intersystem LOCA.
Impractical , -
Requirement: Exercise quarterly at full flow.
Basis for Relief: FUUt pumps do not develop sufficient head to overcome normal RCS pressure. Use of another pump would result in an undesirable temperature transient in the RCS and possible reactor trip.
Technical Specification 4.4.6.2.2 requires these valves to be leak tested following valve actuation and during
' cold shutdown if they have not been leak tested in the last nine months. The (8} valves are aligned and stroked in parallel in groups of (2) as listed. Plani instrumentation is not available to measure individual branch flow rates. Verification of full flow (i.e.,
assumed flow rate) provides good assurance that both valves have, stroked to perform their required safety function. Therefore, relief is requested to allow full stroking of these parallel valves in combination during cold shutdown not to exceed once per nine months.
Valve closure will be verified during cold sh'utdown not to exceed once per nine months when the pressure isolation boundary leak test required by 4.4.6.2.2 is pe rformed. -
.p1t.
Testing: Full stroke exercise paralle'l valves in combination during cold shutdown. Leak test as required by Technical l Specification 4.4.6.2.2.
Frequency for Alt.
Testing. Full stroke exercise during cold shutdown not to exceed ;
once per nine months. Leak tbst at frequencies required l by Technical Specification 4.4.6.2.2.s I
- s ,
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PV-ll System: Upper Head Injection System Valve: 87-558, 87-559,87-560, 87-561,87-562, 87-563 Class: 1 Category: AC Function: Opens to admit upper head injection fluid to reactor vessel during rapid depressurization (LOCA).
Impractical Requirement: Exercise quarterly at full flow. -
Basis for Relief: Plant was not designed to allow full flow inservice testing. To test at full flow it would be necessary at minimum to remove all fuel, remove reactor internals, install a temporary impingement plate and drain the reactor coolant system. The resultant extended down time due to additional fuel movement, storage problems, water chemistry cleanup and refill operations presents an unbearable operational burden.
Technical Specification 4.4.6.2.2 requires these valves to be leak tested following valve actuation and during cold shutdown if they have not been leak tested in the last nine months. The (6) valves are aligned and stroked in parallel in groups of (2) as listed. Plant instrumentation is not available to measure individual branch flow rates. Therefore, relief is requested to allow partial stroking of these parallel valves in combinations during cold shutdown not to exceed once per nine months so as not to impose additional leak testing requirements.
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Alt.
Testing: Manually stroke all 8" CVs each refueling outage.
Disassemble and inspect one 12" CV cach refueling outage, on a rotating basis. If any 12" valve is found to be inoperable and the cause is determined to be potentially generic, then the remaining 12" CV will also be disassembled and inspected prior to declaring the valves operable.
Part stroke exercise parallel valves in combination during CSD. -
l Verify valve closure when the pressure isolation boundary leak test required by SR 4.4.6.2.2 is performed.
Frequency for Alt.
Testing: Manually stroke all 8" CVs each refueling outage.
Disassemble and inspect one 12" CV each refueling outage. Part stroke during CSD, not to exceed once per nine months. Leak test at the frequencies required by Technical Specification 4.4.6.2.2.
4 88
-r.
Alt.
Testing: Disassemble and inspect one valve each refueling outage on a rotating basis. If any valve is found to be inoperable and the cause is determined to be potentially generic, then the remaining three valves will also be disassembled and inspected prior to declaring the valves operable.
i part stroke exercise during CSDs.
Verify valve closure when the pressure isolation boundary leak test required by SR 4.4.6.2.2 is performed. .
Frequency for Alt.
Testing: Disassemble and in.'pect one valve each refueling outage.
part stroke during CSD not to exceed once per nine months. Leak test at the frequencies required by Technical Specification 4.4.6.2.2.
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o.
PV-18 System: Reactor Coolant System Valve: FSV-68-394, FSV-68-395, FSV-68-396, FSV-68-397 Class: 2 Category: B Function: Opens to provide reactor vessel head vent path; to vent non-condensibles from head during an accident to promote natural circulation and prevent gases from impeding reactor coolant circulation flow through the core.
Impractical Requirement: Exercise valve quarterly. Observe visually every two years to verify remote valve indications accurately reflect valve operation. Stroke time test FSV-68-396 and FSV-68-397.
Basis for Relief: These valves are Target Rock valves (similar to the pressurizer PORVs) and have shown a high probability of sticking open. Inappropriate or inadvertent operation of this system (resulting from valves sticking open) could create an unanalyzed condition or worsen the severity of an analyzed faulted condition. Due to the risk of stroking these valves, the licensee requests relief to exercise these valves at refueling outages only, the same frequency as proposed for future technical specification i surveillance testing.
These valves are totally enclosed, preventing visual confirmation of valve position.
FSV-68-396 and FSV-68-397 are system throttle valves with thumbwheel controllers. Timing of manual thumbwheel operation is not meaningful for purposes of detecting valve degradation. Alternative testing will provide an acceptable level of safety, l
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Alt.
Testing: Exercise at refueling outages.
Observe downstream temperature, accoustic emissions traces or changes in PRT temperature / pressure / level following valve operation to verify indicated position.
Stroke time test FSV-68-394 and FSV-68-395. FSV-68-396 and FSV-68-397 will be exercised only.
Frequency .
for Alt. '
Testing: Every refueling outage.
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PV-19 System: Residual Heat Removal (RHR)
Valve: FCV-74-1, FCV-74-2 Class: 1 Category: A-Active Function: Open to provide suction from the RCS for the Residual Heat Removal pumps when RCS pressure is below setpoint.
Close to act as pressure isolation valves above setpoint to prevent overpressurization of the RHR system.
Impractical Requirement: Full stroke exercise every 3 months while in cold shutdown.
Basis for Relief: Full stroking of RER return valves isolates decay heat removal capacity, mixing capacity needed to maintain uniform boron concentration within the RCS, and ability to produce gradual reactivity changes during boron concentration reductions in the RCS. It is generally not considered prudent to remove a valve from its safety related position to perform a periodic code test when that testing places the unit in an LCO and an overall degraded condition. With respect to these specific valves, it is deemed additionally ill-advised in consideration of Unresolved Safety Issues (USI) A-31,
" Residual Heat Removal Shutdowm Requirements" and A-45,
" Shutdown Decay Heat Removal Requirements" which address concerns regarding loss of residual heat removal capability leading to core damage. Reliability of performing heat removal functions is specifically identified as being dependent on the frequency of events that jeopardize decay heat removal operations.
Alternative testing will provide an acceptable level of quality and safety and the increase in the level of safety by normal testing is not commensurate with the difficulties or risks involved. Extended outages of greater than 3 months are not normally anticipated.
Alt.
Testing: Full stroke exercise while shutting down when going on RHR as required. Full stroke exercise during startup when coming off RHR as required.
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_Trequency for Alt.
Testing: Full stroke exercise while shutting down (when going on RHR) if not exercised in the last 3 months or the projected outage duration would cause valves to require testing prior to startup. If not stroked during shutdown and the surveillance interval expires during a outage, or if i outage during exceeds 3 months, valves need not be exercised until startup when coming off RHR. ;
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97B
PV-20 System: Auxiliary Feedwater System Valve: 3-894, 3-895 Class: No n-nuclear code class Category: C Function: Opens to provide auxiliary feedwater pump recirculation flow path back to condensate storage tank for pump protection.
Impractical . -
Requirement: Full stroke exercise valve quarterly. Verify full stroke exercising by verification of flow rate.
Basis for Relief: Full stroke exercising these check valves would require simultaneous operation of both M-D AFW pumps and the T-D AFW pump (or four M-D AFW pumps to produce greater or equivalent flow). Coordination of operation and testing all pumps together on a quarterly basis would place an unusual burden on the plant and shift operating crew without a compensating increase in the level of safety.
Alternative testing would provide an acceptable level of safe. . These check valves are not ASME code class 1, 2 or 3 j
' The NRC has defined non-visual verification of full stroke exercising to be " verification of the maximum flow rate through the check valve identified in any of the plant's safety analyses." No such maximum number is specifically identified for total AFW pump recirculation flow rate. Additionally, plant instrumentation is not available to measure this flow rate. Alternative testing using simultaneous operation of AFW pumps without flow measurement provides adequate assurance that the check 1
valve full strokes as required to provide pump protection.
Alt.
Testing: Part stroke exercise the check valves during the
- individual guarterly pump tests, a single pump operating on recirculation. Full stroke exercise the check valves either manually following disassembly or by verified acceptable operation of (2) M-D and (1) T-D AFW pumps or (4) M-D AFW pumps operating concurrently on i
recirculation. When using pumps for exercising the check valves, verification of acceptable pump performance during concurrent operation will constitute verification of check valve full stroke exercising.
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Frequency for Alt.
Testing: Part stroke exercise quarterly. Full stroke exercise not less than once every two years.
mD 97D
Sequoyah Nuclear Plant inservice Valve Testing Program gyg g (62) CHEMICAL & VOLUME CONTROL SYSTEM '
DRAWIf1G IJO: 4 xj9ng - 3
= e t1 H >< f4 VAINE M h hh 9 H {}
- N "
p hM OW TESTIt!G U dy h4 IJUMBER
- U O N N$ $ I/. Q REQUIRED ~ UD id$ REMARKS
- Ng O. N N
62-509 2 G-10 B-PAS 6" GA H 0 None 62-510 2 G-10 B-PAS 6" GA H 0 None 62-527 2 G-8 B-PAS 4" GA H 0 None 62-533 2 G-8 B-PAS 4" GA H 0 None 62-535 2 F-8 B-PAS 3" GL M 0 None 62-536 2 F-8 B-PAS 3" GL M 0 None 62-537 2 D-8 B-PAS 3" GL M 0 None 62-539 NNCC D-8 B-PAS 3" GL M 0 None 62-696 NNCC E-10 B-PAS 2" GA H 0 None FCV-62-98 3 D-9 B-PAS 2" GA HO O None Appendix R deleted FCV-62-99 3 0-9 B-PAS 2" GA H0 0 None Appendix R deleted '
D
- 4 111
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ______ ___m _ _ _ ___
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ENCLOSURE 2 AMENDMENT TO ENGLOSURE 2 -
4 RESPONSE TO SER -
SUPPLEMENT TO PUMP AND VALVE INSERVICE TESTING PROGRAM D
I 3.1.8 Valves Which Perform a Pressure Boundary Isolation Function (PSIVs)
(continued)
Upper Head Injection System (UHI)
FCV-87-7, Charging header isolation valve to UHI header FCV-87-8, Charging header isolation valve to UHI header 87-558, UHI line check valve 87-559, UHI line check valve 87-560, UHI line check valve 87-561, UHI line check valve - 87-562, UHI header check valve 87-563, UHI header check valve All of the above valves have been Categorized A or A/C as appropriate and listed in the Sequoyah Units 1 and 2 IST program.
All of the above valves, with the exception of FCV-87-7 and FCV-87-8, are listed in the Sequoyah Units 1 and 2 Technical Specifications list of pressure isolation valves. A Technical Specification revision will be submitted to add FCV-87-7 and FCV-87-8 to the list of pressure isolation valves. The revision proposes to remove the entire list of valves from the Technical Specifications, referencing only the category (PSIVs) and placing '
i the valve list in controlled plant procedures.
3.1.9 Pressuriser Power Operated Relief Valves (PORVs)
The pressurizer PORVs are included in the IST program as Category B valves and tested to the requirements of Section XI. Since the PORVs have shown a high probability of sticking open and are not needed for overpressure protection during power operation, routine exercising during power operation is considered by the NRC to be "not practical" and, therefore, not required. The PORV's function during reactor startup and shutdown is to protect the reactor vessel and coolant system from low temperature-overpressurization conditions and should be exercised prior to initation of system conditions for which vessel protection is needed.
The following test requirements for the PORVs are included in the Sequoyah Units 1 and 2 IST program:
l
- 1. Full stroke exercising shall be performed at each* cold {
shutdown or, as a minimum, once each refueling cycle.
- 2. Stroke timing shall be performed at each* cold shutdown, or, at a minimum, once each refueling cycle.
- 3. Fail safe actuation testing shall be performed at each* cold shutdown.
8
3.4.1.1 (continued) actuation and during cold shutdown if they have not been leak tested in the last nine months; exercising these valves at a greater frequency would therefore necessitate technical specification leak testing at the same increased frequency.
Individual branch line flows are only measured during refueling outage testing since plant instrumentation is not available to measure individual branch flows.
The licensee will partial stroke these valves in parallel combinations during CSDs not to exceed once per nine months, ,
full-stroke exercise these valves each refueling outage, and verify valve closure during cold shutdowns not to exceed once per nine morths when the valves are leak tested as required by Technical Specification 4.4.6.2.2.
3.4.1.2 The licensee requested and was granted (SER) relief from exercising valves63-632, -633, -634, -635, -640, -641, -643, and -644 on the RHR injection lines to the RCS loops in accordance with the requirements of Section XI. The residual heat removal pumpe do not develop sufficient head to overcome normal RCS pressure. Use of another pump could result in undesirable boron concentration and system pressure / temperature / level transients. Technical Specification 4.4.6.2.2 requires these valves to be leak tested I
following valve actuation and during cold shutdowns if they have not been leak tested in the last nine months; exercising these valves at a greater frequency than once every nine months would impose an additional leak testing requirement on these valves which could result in delaying plant startup. Plant instrumentation is not available to measure individual branch flow rates therefore i these valves will be stroked in parallel combinations with verification of total flow rate. The CVs can only be verified closed through the leak testing performed per Technical Specification 4.4.6.2.2.
The licensee will full stroke exercise these valves in parallel combinations during cold shutdowns at a frequency no greater than once per nine months and verify valve closure during CSDs at a frequency no greater than once per nine months when the valves are leak tested as required by Technical Specification 4.4.6.2.2.
3.4.1.3 The licensee requested and was granted relief (SER) from exercising valves63-622, -623, -624, -625, safety injection accumulator outlet CVs in accordance with the requirements of Section XI, contingent upon providing a method for verifying full flow capability of the valves.
These valves cannot be exercised during power operation because neither the safety injection accumulators, residual heat removal i pumps, or safety injection pumps develop sufficient head to overcome reactor coolant system pressure. These valves cannot be 14
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3.4.1.3 (continued) exercised at full flow without removing the fuel from the core, removing the internals package and causing a rapid depressurization of the RCS. Technical Specification 4.4.6.2.2 requires these valves to be leak tested following valve actuation and during cold shutdown if they have not been leak tested in the last nine months. Partial stroking of these valves during CSDs can be performed using either the safety injection or residual heat removal pumps through the check valve test system lines. If these 8
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3.4.2.4 (continued)
, during power operation utilizing the boron injection tank bypass line since this could result in a temperature transient which could cause thermal shock to the injection nozzles. Letdown capability precludes full flow exercising these valves during CSDs. Valve 63-581 will be partial stroke exercised during CSDs, the four parallel valves will be part stroke exercised in combination during CSDs, and all valves will be full stroke exercised during refueling outages.
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- 3.4.2 Category C Valves 3.4.2.1 The licensee requested and was granted relief (SER) from exercising valve 63-502, CV in suction line from the refueling water storage tank (RWST) to the residual heat removal pumps, in accordance with the requirements of Section XI.
The RHR pumps do not develop sufficient head to overcome normal RCS pressure. The pump recirculation path does not contain this CV.
The refueling cavity dewatering line cannot be used because the
- required valve alignment would result in degrading both trains of j RHR. Letdown capabilities preclude use during CSDs. Backseating ..
I this CV would require closure of FCV-63-1 and inoperability of both trains of low head SIS. This valve will be verified closed during CSDs and full-stroke exercised during refueling outages.
3.4.2.2 The licensee requested and was granted relief (SEP) from exercising
, valve 63-510, CV in suction line from RWST to safaty injection pumps, in accordance with the requirements of Section XI.
The SI pumps do not develop sufficient head to overcome normal RCS operating pressure. The recirculation line will not pass full flow. Letdown capabilities preclude full flow exercising at CSD.
This CV will be partial stroked quarterly during the SIS Section XI pump test and full flow exercised each refueling outage during the system performance tests.
3.4.2.3 The licensee requested and was granted relief (SER) from exercising i valves63-524 and 63-526, safety injection pump discharge CVs in accordance with the requirements of Section XI.
The SI pumps do not develop sufficient head to overcome normal RCS '
, cperating pressure. Letdown capabilities preclude full flow l exercising in CSD. These valves are in direct series line-up with
! the PIVs which require leak testing at a frequency not to exceed 1
nine months unless actuated. These CVs will be verified closed
, quarterly, partial stroke exercised during CSDs at a frequency not ,
j to exceed once per nine months, and full stroke exercised during '
d refueling outages. l l 3.4.2.4 The licensee requested and was granted relief (SER) from exercising
- valves63-581, 63-586,63-587, 63-588, and 63-589, check valves in i the lines from the boren injection tank to the reactor coolant system cold legs, in accordance with the requirements of Section XI.
Exercising these valves during power operation would result in discharging heavily borated water from the boron injection tank into the reactor, resulting in a reactivity transient and possible !
j reactor trip. These valves cannot be partial stroke exercised l J
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3.5 Containment Spray System (CS) 3.5.1 Category C Valves 3.5.1.1 The licensee requested and was granted relief (SER) from exercising valves 72-547, 72-548, 72-555, and 72-556, containment and residual heat removal spray header check valves, in accordance with the requirements of Section XI contingent upon providing a method for verifying full flow capability of the valves.
Testing these valves with water would deluge-containment, causing potential significant damage and cleanup requirements to equipment -
and structures. The licensee proposed testing these valves with air during the spra fheader nozzle test required by Technical Specification 4.6.2.1 at least once every five years. The NRC position stated that this method could not ensure full stroking of the CVs. As an alternate to full flow testing, one of these four CVs will be disassembled each refueling outage on a rotating basis. If any valve is found to be inoperable and the cause determined to be potentially generic, then the other valves must also be disassembled and inspected before being declared operable.
3.6 Dmergency Diesel System 3.6.1 Category B Valves 3.6.1.1 The licensee requested and was granted relief (SER) from measuring the stroke time of the diesel air start valves in accordance with the requirements of Section XI. The stroke time of the air start valves cannot be measured as there is no visible stem movement or indication. The stroke time is verified as acceptable by verifying the diesel comes up to speed in < 10 seconds as required by Technical Specifications.
3.7 Upper Head Injection System 3.7.1 Category A/C Valves The licensee requested and was granted relief (SER) from exercising valves87-558, 87-559,37-560, 87-561,87-562, and 87-563, check valves in the Upper Head Injection lines, in accordance with the requirements of Section XI, contingent upon providing a methed for verifying full flow capability of the valves.
The UHI system does not have sufficient head to overcome reactor coolant systen pressure. Use of the charging system would require removal of bath trains of UHI from service to prevent overpres-surization of the system, and could result in severe thermal shock problems. Full stroke exercising these valves with system flow during CSDs or refueling outages would require removing all fuel from tne reactor, removing the reactor internals, installing a temporary impingement plate, and draining the reactor coolant ;
system. plant instrumentation is not available to measure j individual branch flow rates. The valves are partial stroked in parallel combinations.
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~: t 3.7.1 Category A/C Valves (continued)
These valves will be verified to close on CSDs not to exceed once per nine months when the CVs are leak tested per Technical Specification 4.4.6.2.2, and partial stroke exercised in parallel combinations on CSDs not to exceed once per nine months so as not to impose an additional leak testing requirement on these valves per Technical Specification 4.4.6.2.2. As an alternate to full flow exercising, the 8-inch CVs will be manually stroked each refueling outage and one 12-inch CV will be disassembled each refueling outage, on a rotating basis. If any 12-inch valve is found to be inoperable then the other 12-inch valve must also be ,
disassembled and inspected before being declared operable.
3.8 Reactor Coolant System 3.8.1 Category B Valves The licensee requested and was granted relief (SER) from visually observing that the remote position indicators from pressurizer power operated relief valves PCV-68-340A and PCV-68-334 are accurately reflecting actual valve positions. The pressurizer PORVs are fast-acting, totally enclosed solenoid valves, preventing visual determination of valve position. As alternate testing, the licensee will verify the indicated valve positions by observing tailpipe temperature before and after stroking the PORVs at refueling outages, but not less than once every two years.
3.9 Additional Valve Testing Requirements The Sequoyah Units 1 and 2 SER provided an Appendix D listing of IST program additions and notes related to the previous submittal and subsequent review. The following provides the licensee proposed adaptation or omission of the additional requirements 4.nto the Sequoyah Units 1 and 2 IST program. Relief requests are identified accordingly. Additionally, several proposed changes to the IST valve program are submitted due to changes in system and/or valve configuration.
3.9.1 Pressurizer Auxiliary Spray Line Check Valve The licensee maintains CV 62-661 is not safety related and therefore should not be added to the IST program; additionally, the licensee maintains the auxiliary spray valve PCV-62-84 should also be deleted from the IST program. The following jus: #ication was presented to the NRC and concurrence reached (WM) th these valves need not be included in the IST program.
The IST program addresses valves which are safety related as defined in section 3.1.6 of the SER and this submittal. During the NRC-TVA working meeting held in 1982, the auxiliary spray valve PCV-62-84 was added to the IST program at the suggestion of the licensee; at that time, the licensee pressuriser PORVs were not 18
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