ML20211G942
| ML20211G942 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/19/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 5211-87-2020, NUDOCS 8702260010 | |
| Download: ML20211G942 (8) | |
Text
GPU Nuclear Corporation U Nuclear
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Middletown, Pennsylvania 17057-0191 717 944-7621 TELEX 84 2386 Writer's Direct Dial Nurnber:
February 19, 1987 5211-87-2020 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear Sir:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Inservice Testing (IST) of Punps and Valves GPUN's letter of December 24, 1986 provided a response in Attachment 1 to each of the open issues which were identified in the NRC's October 3,1986 Safety Evaluation Report (SER) regarding IST for the second ten-year IST interval.
Our letter was in response to the meeting in Bethesda on October 27, 1986 where we had discussed the SER open issues with the NRC staff.
As a result of our conference call with the NRC and EG8G Idaho on January 15,1987, it appears that additional commitments are required in order to resolve four of these issues (I. through IV., which are discussed below) prior to startup for Cycle 6 operation.
One additional issue involves some disagreement over the frequency of check valve disassembly for inspection purposes. However, the disassenbly inspections that are being performed during the current outage i
will ensure conpliance with the SER for Cycle 6 operation.
A report of the l
inspection results will be submitted to the NRC for further consideration.
These results should provide additional information to strengthen the position that a longer inspection interval should be granted for future inspections.
The purpose of this letter is to provide additional commitments and to request interim relief for a reasonable amount of time sufficient to implement l
procedures and complete modifications.
As requested by NRC in the conference call on January 15, 1987, GPUN acknowledges the apparent inconsistency in our December 24, 1986 submittal regarding the PORY, RC-RV2. This valve was listed as a Category C valve in one location of the transmittal while it appeared in a list where the limiting stroke times of power operated valves were given. We had not considered RC-RV2 a Category B valve since it does not fit the definition of a Category B valve.
RC-RV2 is power actuated but not power operated.
We understand that GPUN's test program as described in our letter of December 24, 1986, which is essentially a test program for a Category B valve, is acceptable to the NRC.
If the test program which has been inplemented is acceptable, then the question of valve category is purely academic.
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5211-87-2020 February 19, 1987 It should be noted that GPUN has installed a spectacle flange between EF-V4 and EF-V5. Therefore, the relief requested from quarterly testing for EF-V4 and EF-V5 is no longer needed. Attachment 1 includes the revised pages from our Decenber 24, 1986 submittal which reflect the deletion of this request.
The four issues which need to be resolved are addressed as follows:
ISSUES I. & II. - Quarterly flow test of the four Boric Acid and Boric Acid Recycle pungs (CA-Pl A/B and WDL-P13A/B)
Ref.: SER Appendix D, Items D.l.2 and D.l.4 GPUN's IST program includes tests of CA-Pl A/B and WDL-P13A/B each refueling interval. Therefore, this issue amounts to the frequency of punp testing.
We have been unable to resolve this issue because we have maintained that the determination of practicality in accordance with 10 CFR 50.55a should not require plant modifications in order to perform the tests in question. We also believe that we had previously achieved technical resolution on this issue by commiting to additional testing of WDL-P13A/B.
Although the NRC has pointed out that alternative test methods might be acceptable in lieu of plant modifications, we have been unable to determine an alternate test method that would not result in undesirable changes in boron concentration, power reduction, or excessive radwaste generation. Therefore, in order to resolve this issue, GPUN intends to complete the modifications necessary to perform quarterly tests of CA-PlA/B and WDL-P13A/B.
GPUN requests interim relief from the quarterly test frequency for these punps until such time that these modifications can be conpleted.
GPUN intends to complete these modifications as discussed below.
In the interim the current test program is adequate to ensure operability.
ISSUE III. - Sper.t Fuel Cooling System Yalves Ref.:
SER Appendix D, Item D.1.20 NRC has stated that providing a safety grade source of makeup water to i
the spent fuel pools would be an acceptable alternative to adding these valves to the IST program. GPUN believes that sufficient redundant and diverse (non-safety related) means are available for makeup to the Spent Fuel Pool. We also believe that the tests of additional Spent Fuel Cooling System valves will present an unnecessary burden on the operator. However, in order to resolve this issue, GPUN is including i
tests of the Spent Fuel Cooling System valves in the IST program as shown on the revised page 36 of 38 from Table B-1 of GPUN's submittal dated December 24,1986 (See Attachment 1). The addition of these valves to l
the IST program will be sufficient to resolve this issue.
l
5211-87-2020 February 19, 1987 ISSUE IV. - Diesel Generator Fuel Oil Transfer Pugs Ref.: SER Appendix D, Item D.l.23 NRC's letter of October 3,1986 raised this. issue for the first time in the SER. ' We do not believe that the' ASME Section XI Code was intended to he applied to air and fuel oil systems. However,' in order to resolve this issue, GPUN intends to either install flow instrumentation or tank level indication that will allow the calculation of flow rate.
This will allow quarterly flow tests of the Diesel Generator Fuel Oil Transfer Pumps. As discussed in the October 27, 1986 meeting with the NRC staff, we request that the NRC's safety evaluation grant relief from the Code requirements for measuring A P, Pj, and testing for a 5 minute run time.
l GPUN requests interim relief from flow testing these pumps in accordance with the Code until such time that this modification can be cogleted.
GPUN intends to complete this modification as discussed below.
GPUN's operational surveillance program includes a weekly test to ensure that the Diesel Generator Fuel Oil Transfer pumps will start. This is in addition to the monthly Diesel Generator testing which proves the ability j
to maintain the level in tLe day tank.
In the interim, these tests should be adequate to ensre operability of the Diesel Generator Fuel Oil Transfer pumps.
i IMPLEMENTATION SCHEDUI E F OR ISSUES I, II, AND IV Recognizing the des'.re by the NRC to have these modifications installed as soon as practicil, JPUN has begun to evaluate the specifics of these l
cha nges.
In orde, to be ready for Cycle 7R installation, which is scheduled for miJ 1988, the.GPlW planning process (which enbodies the elements of the Integrated Living Schedule Program) requires engineering to be complete six months prior to the outage so detailed planning and procurement can be performed.
It does not appear reasonable therefore to expect these projects to be defined, specf*kations prepared, the projects estimated and funded, englicering totally cogleted, long lead materials procured, and installation packages released for detailed planning and implementation all by the end of 1987 to support 7R.
GPUN therefore plans to iglement the changes associated with satisfying Issues I, II and IV by the end of refueling outage Cycle 8R.
If, as further details develop, it becomes apparent an earlier schedule is l
feasible and is consistent with other planned effort, this work would be accelerated.
As stated in our letter of December 24, 1986, a period of six months is needed in order to incorporate procedural changes necessary to implement changes to the IST program. Therefore, interim relief for a period of six months from the date of this letter is requested in order to iglement the test program for Spent Fuel Cooling System valves.
~
5211-87-2020 February 19, 1987 We believe that the commitments contained in this letter in addition to the commitments and additional infornation which have already been provided to the NRC is sufficient to resolve the NRC staff's concerns regarding IST for the second ten-year IST interval.
In light of these new commitments, GPUN requests a supplement to the SER granting that relief requested in our letter of December 24, 1986, except for the items discussed above and granting the relief requested in this letter.
Sincerely, s
. D.
ukill Vice President & Director, TMI-l HDH/MRK/spb Attachment cc:
J. Stolz, USNRC T. Murley, USNRC F. Young, USNRC J. Thoma, USNRC 0765A
5211-87-2020 ATTACMENT 1 Revised 2/87
~
TABLE B-1 THREE MILE ISLAND UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)
PAGE 36 of 38 SYSTEM /
TYPE TEST (ISI DRAWING NO.)
VALVE NO. TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FRE0VENCY SPENT FUEL SF-V1 DIAPH.
8" DIAPH.
3 B
T Q
COOLING SYSTEM SF-V2 DIAPH.
8" DIAPH.
3 B
T Q
(lD-ISI-FD-018)
SF-V4 DIAPH.
8" DIAPH.
3 B
T Q
SF-V5 DIAPH.
8" DIAPH.
3 B
T Q
SF-V7 CHECK 8"
3 C
F Q
SF-V8 CHECK 8"
3 C
F Q
SF-Vll DIAPH.
8" DIAPH.
3 B
T Q
SF-V12 DIAPH.
8" DIAPH.
3 8
T Q
SF-V14 DIAPH.
8" DIAPH.
3 B
T Q
SF-V15 DIAPH.
8" DIAPH.
3 B
T Q
SF-V23 GATE 8"
MANUAL 2
A L/ II)
R/-
SF-V50 CHECK 8"
3 C
F Q
SF-V51 CHECK 8"
3 C
F Q
Footnote:
(I)
This CIV is passive (a closed valve whose function is to remin closed). Therefore, this valve is exenpted from the quarterly functional stroke requireent of IWV-3412 per NRC staff guidelines since no maningful inforation would be gained.
5211-87-2020 ATTACMENT 1 Revised 2/87 TABLE B-1 THREE MILE ISLAND UNIT N0.1 PERIODIC INSERVICE INSPECTION PROGRAM - (VALVES)
PAGE 10 of 38 SYSTEM /
TYPE TEST (ISI DRAWING NO.)
VALVE NO. TYPE SIZE OPERATOR CLASS CATEGORY OF TEST FREQUENCY EMERG. FEED EF-V3IlI WATER SYSTEM (1 D-ISI-FD-009 )
EF-V4 GATE 6"
MOTOR 3
B T
Q (l D-ISI-FD-010)
EF-V5 GATE 6"
MOTOR 3
B T
Q EF-VllA/B CHECK 4"
3 C
F RCI2)(II)
EF-V12A/B CHECK 6"
2 C
F RC(II)
EF-V13 CHECK 6"
3 C
P/F Q/RC(II)
EF-Vl9A/B CHECK 1-1/2"-----
3 C
F Q
EF-Y21 CHECK 2"
3 C
F Q
EF-V30A-D(3) CONTROL 3"
PNEU.
3 B
T/FS Q/Q Footnote:
III The internals of EF-V3 have been removed by DRF 039002 during the Eddy Current Outage in March 1986.
Therefore, EF-Y3 has been deleted from the IST Program.
(2)
EF-Vll A/B are the discharge check valves on EF-P2A/B.
EF-P2A/B is tested on recirculation with the OTSGs flow through EF-d.2A/B by EF-V10A/B.
isolated from EF-P The recirculation line is upstream of EF-Vll A/B; therefore, there is no lA/B.
It is not possible to initiate flow through EF-Vll A/B on a quarterly frequency due to the limited nunber of thermal cycles allowed for the Auxiliary Feedwater Nozzles.
l (3)
TMI-l is adding redundant EF-V30 control valves. Therefore, EF-Y30C and D are being added to the IST program upon their placement into service.
5211-87-2020 ATTACINENT 1 Revised 2/87 TABLE B-2 THREE MILE ISLAND - UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS PAGE 3 of 20 SPECIFIC REQUESTS FOR RELIEF I.
Category B - Valves That Will Be Tested Only During Refueling Outages A.
Valve Identification Valve Name and Function Valve Number Reactor B1dg. Sump Recirc. Suction DH-V6A/B i
B.
ASME Code Section XI Requirement From Which Relief is Requested Paragraph IWY-3412(a) states that valves that cannot be operated during noral plant operation shall be full-stroke exercised during each cold shutdown. In case of frequent cold shutdowns these valves need not be exercised mre of ten than once every three mnths.
C.
Basis for Requesting Relief Prior to cycling DH-V6A and B the Reactor Building Sump must be drained, then blank flanges weighing ~ 140 lbs. must be installed in the sump on the piping leading to DH-V6A/B.
In order to install the blank flange, considerable time and effort is required (i.e., mintenance personnel must enter the sunp to install the blank flanges. After the test the blank flanges must be removed. There are no isolation valves other than DH-V6A/B that isolate the Reactor Building Sump from the DH System. The blank flanges are installed to prevent water in the DH piping from flooding the Reactor Building when DH-V6A/B is opened for stroke timing.
If the blank flanges were not installed, water would flow through the 14" line for ~ 140 seconds while DH-V6A/B is opened and then closed.
Because of ALARA concerns (~ 300 MR for installation and remval of the flanges), the proper frequency for stroke timing DH-V6A/B is ref ueli ng.
Therefore, it is impractical to test DH-V6A/B on a cold shutdown frequency.
In addition, a refueling interval stroke tie test since 1978 has not shown any problem with DH-V6A/B.
t l
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5211-87-2020 ATTACMENT 1 Revised 2/87 TABLE B-2 THREE MILE ISLAND - UNIT NO. 1 PERIODIC INSERVICE INSPECTION PROGRAM - VALVES REQUEST FOR RELIEF FROM ASME CODE SECTION XI REQUIREMENTS PAGE 4 of 20 II. Category C - Valves Which Will be Full Stroke Tested Following A Refueling or A Cold Shutdown When Cold Shutdown Exceeds 30 Days.
A.
Valve Identification Valve Name and Function Valve Number Condensate Storage Tank to EF Water Punps CO-V16A/B Motor Driven EF Water Pump Discharge EF-VllA/B EF Water Punps to OTSG EF-V12A/B Turbine Driven EF Water Pump Discharge EF-V13 B.
ASME Code Section XI Requirement From Which Relief is Requested Paragraph IWV-3522 states that check valves that cannot be operated during nornal plant operation shall be full-stroke exercised during each cold shutdown.
In case of frequent cold shutdowns these valves need not be exercised more of ten than once every three months.