ML20207H675
| ML20207H675 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/22/1986 |
| From: | Agosti F DETROIT EDISON CO. |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| TAC-63529, VP-86-0081, VP-86-81, NUDOCS 8607250002 | |
| Download: ML20207H675 (4) | |
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- nt Nuclear Operations Fermi 2 On Inf?"
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VP-86-0081 Director of nuclear Reactor Regulation
!!s. -Elinor G. Adensam, Director Project Directorate No. 3 Division of EUR Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Deat !!s. Adensam:
Reference:
1)
Fermi 2 MRC Docket No. 50-341 URO License No. NPF-43 2)
Detroit Edison to NRC Letter, "Submitt:l of Revision 2 of Report on Inservice Testing of Pumps and Valves, Including VR-20", dated October 4, 1983
Subject:
Relief Request to Inservice Testing Program for Purns and Valves Relief request VR-20-R1, uhich supersedes VR-20, to the Fermi 2 Inservice Testing Program (IST) for pumps and valves is attached in accordance with 10 CFR 50.55a(g) ( 5) (iii).
The enclosed relief request provides an achievable method to test standoy liquid control check valves C41-F006 and C41-F007 and reduces radiation exposures to personnel performing these tests.
If you have any questions concerning this rrlief request, please contact !!r. Frank Sondgeroth at (313) 586-4203.
Sinceroly,
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cc:
lir.
M. D. Lynch
!!r. U. G. Rogers USNFC Document Control Desk Unshington, D.C.
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Attachment to VP-86-0081 Relief Request No. VR-20-R1 SYSTEM:
Standby Liquid Control COMPOMENT:
C41-F006 (VR4-2036)
C41-F007 (VR4-2037)
CATEGORY:
A/C FUDCTION:
The cafety function of thece check valves is to open upon system injection and to close for containment icolation.
TEST RFOUTREMEUTS:
Exercice valven every three (3) nonths CT-0 (open)
& CT-C (closed).
Type-C Air Leak Test (10CFR50-App. J) AT-1 every Reactor Refueling.
These valves serve as Primary Containment Isolation Valves.
Position Indication Test (PIT) every 2-years.
EASIS FOR RELIEF:
Exercise Testino Every Three (3) months -
(C41-P006 & C41-F007)
Thece. check valvec cannot be exercised during plant operation becauce they are cubjected to a reactor coolant cystem precsure of 1000 psig, ac previously stated in Relief Request VR-20.
In addition these valves have a tentability feature which utilizcc a shaft which penetrates the preccure boundary via a packing and stuffing l
box arrangement.
Thece packing and stuffing boxes are a major cource of leakage when cubjected to i
10CFR50, App. J Local Leak Fate Testing (LLRT).
The design is such that when the packing ic tightened to reduce leakage, the friction on the chaft is sufficiently increased that the operator vill no longer exercice the valve.
Subcequent loosening of the packing to pass the exercice tect resulted in failing the LLRT test.
The required tightening and loosening of valve packing to caticfy multiple tecting requirements resulted in exceccive nanhourc being expended incide primary containnent and raiced ALARA concernc.
A In an effort to alleviate this problem and reduce personnel exposure, the air operators on these check valves will be removed and new valve shafts and end bushings will be installed.
Uith the deletion of these air operators it will no longer be feasible to exercise these check valves during plant cold shutdowns as allowed by Relief Request VR-20.
Removal of these air operators neither compromises the aperation nor the safety function of the subject check valves.
Position Indication Test (PIT) every 2-years -
C4]-F007 Only:
Position indication for C41-F007 is being removed to reduce personnel exposure during calibration and repair work on the suitchen uithin primary containment (ALARA).
Position indication for l
check valve C41-F007 is not required in the i
control room for system operation or plant safety.
ALTERNATIVE TESTIMG: Exercise Testino everv three (3) months -
(C41-F006 & C41-F007):
These check valves vill be c::crcised every eighteen (18) months during reactor refueling.
These valves will be verified to stroke open (CT-0) by performance of the "SLC Hanual Initiation and Storage Tank Heater Operability Test".
Successful injection of domineralized water into the neactor vessel verifies these valves stroke open.
These valves will be verified closed by performance of the Local Leak Rate Tests (LLRT).
These testa pressurice a test volume in which the subject check valves form a pressure boundary.
If the valves are not fully closed and seated, the test volumes will not pressurize and LLRT test vill fail.
Successful LLRT testing will prove that the cubject valves are closed (CT-C).
Both of the above tests are performed at a Reactor.
Refueling Outage frequency (every 18 months).
^
Pocition Indication Tect (PIT) every 2-yearc -
C41-F007 on1v:
Standby Liquid Control System' inboard injection check valve C41-P007 no longer requires position indication verification-testing an stated in ASME Section XI, 1980 Edition W'80 Addenda,. paragraph INV-3300.
Via thic Relief Request the PIT testing requirement for C41-F007 is being deleted from the program.
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