ML20210M641

Forwards Request for Relief 99-03 from Requirements of ASME Boiler & Pressure Vessel Code,In Order to Seek Relief from Performing Individual Valve Testing for Certain Valves in DG Starting Air (Vg) Sys

ML20210M641
Person / Time
Site:	Catawba
Issue date:	07/29/1999
From:	Gordon Peterson DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9908100136
Download: ML20210M641 (5)

Text

, l fS Duke Power Catawba Nudcar Station b "

4800 Concord Road

"'N**

York. SC 29745 (803) 831-425i OFFICE

, ',"" (803) 831-3426Mx July 29,.1999 U.S. Nuclear Regulatory Commission Attention: . Document Control Desk Washington, D.C. 20555 -

Subject:

Duke Energy Corporation

. Catawba Nuclear Station, Units 1 and 2 Docket. Numbers 50-413 and-50-414 '

Request for Relief Number 99-03 Relief Request from Performing Full Stroke Testing for Diesel Generator Starting Air (VG) System Valves Pursuant to 10 CFR 50.55a(f) (5) (iii) and (iv), please find attached Request for Relief 99-03 f a n the requirements of the ASME Boiler and Pressure Vessel Co<e. This request is being submitted in order to seek relief from performing individual valve testing for certain va.'a es in the diesel generator starting air (VG) system.

The attachment to this relief request includes all information necessary to ensure timely processing of this request. If you have any questions concerning this material, please call L.J.

Rudy at (803) 831-3084.

l Very truly yours

/ /

i --

'dary.R. Peterson l' LJR/s Attachment

,jo 9908100136 990729 PDR ADOCK 03000413 P PDR 100n20

57 E

Document Control Desk

.. Page 2 July 29, 1999 i

xc.(with attachments):

L.A..Reyes, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 D'J. Roberts, Senior Resident Inspector i

U.S. Nuclear Regulatory Commission Catawba Nuclear Station ,

i P.S. Tam, Senior Project Manager j U.S. Nuclear Regulatory Commission i Mail Stop 08-H12 Washington, D.C. 20555-0001 1

I I

l

=

5_ 4 Attachment 1

. . Request for Relief 99-03 Relief Request from Performing Full Stroke Testing for VG System Valves

! I. Identify the component for which relief is being requested:

a) Name and number given in the UFSAR:

IVG25, IVG27 (Diesel Generator I A Starting Air Inlet Solenoid Valves - l Right Bank) l IVG26, IVG28 (Diesel Generator I A Starting Air Inlet Solenoid Valves -

Left Bank) 1VG29, IVG31 (Diesel Generator I A Starting Air Inlet Check Valves -

Right Bank) l IVG30, IVG32 (Diesel Generator I A Starting Air Inlet Check Valves -

l Left Bank) l 1VG69, IVG71 (Diesel Generator 1B Starting Air Inlet Solenoid Valves -

l Right Bank) l IVG70, IVG72 (Diesel Generator IB Starting Air Inlet Solenoid Valves - j Left Bank) {

IVG73, IVG75 (Diesel Generator IB Starting Air Inlet Check Valves -

Right Bank)

IVG74, IVG76 (Diesel Generator IB Starting Air Inlet Check Valves -

Left Bank) 1 2VG25,2VG27 (Diesel Generator 2A Starting Air Inlet Solenoid Valves - l Right Bank) 2VG26,2VG28 (Diesel Generator 2A Starting Air Inlet Solenoid Valves -

Left Bank) l 2VG29,2VG31 (Diesel Generator 2A Starting Air Inlet Check Valves -

I Right Bank) 2VG30,2VG32 (Diesel Generator 2A Starting Air Inlet Check Valves -

Left Bank) 2VG69,2VG71 (Diesel Generator 2B Starting Air Inlet Solenoid Valves -

Right Bank) 2VG70,2VG72 (Diesel Generator 2B Starting Air Inlet Solenoid Valves -

, Left Bank) 2VG73,2VG75 (Diesel Generator 2B Starting Air Inlet Check Valves -

Right Bank) 2VG74,2VG76 (Diesel Generator 2B Starting Air Inlet Check Valves -

Left Bank) l L_.

p ,

b) Description of function of component:

Each solenoid valve receives an open signal upon D/G auto-start. Each check valve then opens to supply startmg air to the diesel. All valves are normally closed and shut upon successful diesel start. Only one solenoid valve and its corresponding check valve are required to open for a successful diesel start. The solenoid valves are 3" California Controls air valves and the check valves are 3" Williams Gauge Company flanged center guided valves. All are supplied as part of the D/G skid package.

c) ASME Section III Code Class or ASME Section XI Code Class ASME Section XI Code Class C d) ASME Section III:

No reliefis being sought from any ASME Section III requirements concerning these valves.

e) Valve Testing:

These valves are required to be full-stroke exercised every three months to the position required to fulfill their function.

II. Specifically identify the ASME Code requirement for which reliefis desired:

ASME Code requirements dictate that each valve be separately tested and be determined capable of fulfilling its design function. ASME/ ANSI OM-1987 Edition, Part 10, including Oma-1988, paragraph 4.3.2.2, specifies that each valve shall be exercised or examined in a manner which verifies obturator travel to the required position. Because the D/G can start off of one air line from one bank (right and left bank, two lines per bank, one solenoid and one check valve per line), Catawba has no means to separately verify each valve's ability to function.

Catawba therefore requests relief from the ASME Code requirement specifying that each valve be individually tested.

III. Provide information to support the determination that relief from the requirement in II above is necessary (ie. burden):

As indicated above, the D/G can start from one air line on either bank. Tests are being performed during cold shutdown which isolates each bank and starts the D/G. This test however, cannot verify that both solenoid valves and both check valves on one bank open. The alternate method utilized at Catawba is the application of" skid mounted" criteria as discussed in Section 3.4 of NUREG-1482," Guidelines for Inservice Testing at Nuclear Power Plants." By this l

method, successful demonstration of the starting air system is verified. '

I I

1 .

l IV. . Specify the alternate inservice testing / examination that will be performed in lieu of the ASME Section XI requirements:

Each D/G is operated once monthly per procedure PT/l(2)/A/4350/002A,B, "D/G Operability Test," to prove operability. A successful D/G start in the required time verifies the starting air system is functioning properly. During cold l

shutdown, isolating each bank verifies the starting air system is capable of starting the D/G in the required time and has suitable redundancy.

1 V. Provide an explanation as to why the alternate proposed inservice testing / examination will provide an acceptable level of quality and safety and not reduce the level of public health and safety:

l Radundancy has not been compromised. The D/G can start in the specified time utilizing one line from ene bank. While not being able to directly verify a stroke of each valve, isolating each bank and starting the D/G does verify system perfonnance. No adverse impact upon the public safety will be generated from a l radiological or other standpoint.

VI. Provide a schedule for implementation of the inservice inspection in IV above:

The testing which is being recommended is currently being performed. Monthly D/G operability tests are conducted as well as cold shutdown testing which isolates each starting air bank and starts the D/G.

1 i

I 1

L