ML20212A945
| ML20212A945 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/23/1997 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-97-0036, W3F1-97-36, NUDOCS 9710270104 | |
| Download: ML20212A945 (17) | |
Text
1 Entergy Operations,Inc.
Of Kmona. LA 700ff; Tel 504 739 6242 e
Ear C. Ewing, lit ay,anevaav uan
'W3M-97-0036 A4 ns PR October 23,1997 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Correction of Information Provided for Inservice Test Plan Gentlemen:
By letter dated August 19,1993, Entergy Operations submitted Revision 7, Change 4, to the Waterford 3 Inservice Testing (IST) Plan - Pumps and Valves. That letter provided incorrect information to the NRC Staff regarding Relief Requests 3.1.73 and 3.1.74. The incorrect information concerned the configuration and characteristics of valves SI-107A and SI-107B, which are check valves in the outlet piping from the Refueling Water Storage Pool (RWSP).
10CFR50.9 requires that information provided by licensees to the commission be complete and accurate in all material aspects. Therefore, the purpose of this letter is to: 1) retract relief request 3.1.73 because relief is not necessary; 2) submit revised relief request 3.1.74 in order to correct the information for the current 10-year Inservice Test (IST) Plan; 3) describe w:.y Waterford 3 believes SI-107A(B) are currently acceptable; and 4) describe actions being taken to identify other instances, if any, of incorrect IST information and address the quality of Waterford 3 submittals in general.
To preclude any confusion for the staff, please note Waterford 3 will submit a new 10-year IST Plan to the NRC in December 1997. The information contained in that submittal will supersede the relief request contained in this correspondence.
I AoC,
pao # *au Va?nea llllillill![lll;llfilpy e
Correction of Information Provided for Inservice Test Plan W3F1-97-0036 Page 2 October 23,1997 Watenord 3 regrets any inconvenience caused by the incorrect information in the previous submittal and believes the actions described in Attachment A should prevent future errors of this nature in the IST program.
4 Attachment B contains the revised relief request 3.1,74 and Attachment C contains copies of sections of the referenced code and NUREG.
Should you have any questions or comments concerning this submittal, please contact me at (504) 739-6242.
Very truly yours, L
/
d 0
E. C. Ewing
. Director Nuclear Safety & Regulatory Affairs 3
ECE/ECE/ssf Attachments:
Attachment A - Background and Discussion Attachment B - Revised Relief Request 3.1.74 Attachment C - Copies of Referenced Code and NUREG cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR J. Smith -
N.S. Reynolds NRC Resident Inspectors Office 1
I ATTACHMENT A Background and Discussion
Att:chment A to-W3F197-0036i Page 1 of 5 BACKGROUND-By letter dated August 19,1993, Entergy Operations submitted Revision 7, Change 4, to the Waterford 3 Inservice Testing (IST) Plan - Pumps and Valves.-
That letter provided incorrect information to the NRC Staff regarding the -
characteristics of valves SI-107A and SI 107B, which are check valves in the outlet piping from the Refueling Water Storage Pool (RWSP). - Specifical'y, the
- letter stated these valves were installed in a vertical section of piping and normally held open by gravity. In actuality, the valves are installed in nestly horizontal piping and are spring-loaded check valves,- The incorrect information was contained in Items 3.1.73 and 3.1.74 of Attachment 6.6 in the August 19, 1993,' submittal. The relief request, including the incorrect information, was approved by the NRC in a Safety Evaluation Report dated February 8,1994.
- On January 21,1994 it was discovered that Relief Requests 3.1.73 and 3.1.74 contained inaccurate information. A Condition Report (CR) was generated to document this adverse condition and establish corrective action. Subsequently :
the Waterford 3 NRR Project Manager was contacted by phone and informed of this condition. On August 31,1995, the CR was closed indicating that a revision to the IST Plan (Revision 7, Change 10) provided the correct valve orientation for
- Sl-107 A(B). However, on April 23,1996, it_was discovered that Revision 7,-
Change 10 of the IST Plan did not provide the correct valve orientation and that the CR had been closed in error. Another CR was written and corrective action -
will include a requirement to docket a letter to the NRC to resolve this issue.-
.1)
RETRACTION OF RELIEF REQUEST 3.1.73 Testing Requirement -
lWV-3521 requires that " check valves shall be exercised at least once every 3 months...". IWV-3522(a) requires that " Valves...whose function is to prevent reversed flow shall be tested in a raanner that proves that the disk travels to the seat promptly on cessation or reversal of flow."
-l Basis for Original Relief Request Waterford 3 submitted Relief Request 3.1.73 because of the inability to meet the Code testing requirement. Check valves SI-107A(B) are in the outlet piping of the Refueling Water Storage Pool (RWSP) and allow.
suction for the High Pressure Safety injection (HPSI), Low Pressure Safety
Attachm:nt A to W3F1-97-0036 Page 2 of 5 Injection (LPSI), and Containment Spray (CS) pumps. The valves also perform a safety function in the closed direction because they must close after the suction sorce shifts to the Safety injection Sump (SIS) to prevent contaminated sump water from entering the RWSP which is vented to the Reactor Auxiliary Building.
These check valves have no external position indication for determining obturator position, it is not possible to pass full accident flow through these check valves on a quarterly or cold shutdown schedule. To pass full accident flow through these check valves requires simultaneous operation of the HPSI pump, LPSI pump and CS pump at maximum accident flow rates. This would require the Reactor Coolant System (RCS) to be depressurized and the reactor head removed. Coordination of the operation of all three pumps at the same time and the controlling of RCS level would be difficult.
Although partial stroke exercising of these valves is possible on a quarterly i
basis, it is not possible to detect the closure of these check viuves using l
non-intrusive methods following the cessation of flow during the quarterly l
partial stroking. Because the valves have soft seats and only open partially, there is insJffiClent impact upon Closing to detect valve Closure using non-intrusive acoustic monitoring.
Current Test Methodology For their open and close function, SI-107A(B) are disassembled and visually inspected during each refueling outage and are partially stroked after reassembly. This is done on a staggered basis. In addition, the valves are partially stroked every three months.
Basis for Relief Request Not Being Required While reviewing NUREG-1482 in preparation for submitting a revised relief request, it became apparent that relief is not needed from the requirements of IWV-3521 and IWV-3522(a). In NUREG-1482, Appendix A, NRC Staff Position 2, in the response to Question Group 16, the NRC states "For those cases where full stroke exercising cannot be performed quarterly, during cold shutdown, or during refueling outages, disassembly and inspection in conformance with Position 2 of Generic Letter 89-04 is allowed as an alternative. If the provisions of Position 2 are followed, a relief request need not be submitted for NRC review but this deviation from the ASME Code should be documented."
i
Attachm:nt A to W3F1-97-0036 Page 3 of 5 NUREG-_1482, Appendix A, Position 2, states the NRC staff position is that valve disassembly and inspection can be used as a positive means of determining that a valve's disk will full-stroke exercise open or of verifying closure capability, as permitted by IWV-3522, SI-107A(B) qualify for the alternative to full-flow testing of check valves described in GL 89-04, Position 2. As described in the Question Group 16 response mentioned earlier, relief is not required and the Waterford 3 IST Program will be revised to describe alternate testing of SI-107A(B) in accordance with Position 2. Because these valves cannot be full stroked quarterly, during cold shutdown, or refueling, alternate testing will consist of disassembly and inspection on a staggered basis. Therefore, Waterford 3 requests Relief Request 3.1.73 be withdrawn.
2)
RELIEF REQUEST 3.1.74 Technical Specification Surveillance Requirement 4.0.5.a requires inservice testing of ASME Code Class 1,2 and 3 pumps and valves to be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10CFR50, Section 50.55a(g),
except where specific written relief has been granted by the Commission pursuant to 10CFR50, Section 50.55a(g)(6)(i).
Specifically, the inservice testing of safety-related ASME Boiler and Pressure Vessel Code Class 1,2, and 3 Pumps and Valves is conducted in accordance with the requirements of subsections IWP and IWV of the ASME Boiler and Pressure Vessel Code Section XI,1980 Edition through the Winter 1981 Addenda as required by 10 CFR 50, Section 50.55a(g).
Subsection IWV provides the rules and requirements for inservice testing of certain Class 1,2, and 3 valves which are required to perform a specific function in shutting down the reactor to cold shutdown conditions or in mitigating the consequences of an accident. Subsection IWV-2200 defines Category A valves as those for which seat leakage is limited to a specific maximum amount in the closed position of fulfillment of their function. SI-107A(B) are spring-loaded check valves which do perform an accident mitigation function and do have specific seat leakage criteria; therefore, they should be leak tested in accordance with subsection IWV. The leak test frequency criteria for Category A valves is at least once every two years as required by IWV 3422.
1
i m_
.7 Attachment A to W3F1-97-0036 Page 4 of 5
- Waterford 3 cannot meet this requirement to leak test SI-107A(B) every two
. years and requests relief as described in Attachment B. There are no connections between 107A(B) and their corresponding isolation valves to allow for collection of leakage past these check valves and measurement of leakage rate. The Refueling Water Storage Pool (RWSP) is located upstream of the isolation valves making it impractical to measure leakage.
upstream of the isolation valves.
It is extremely difficult to remove these check valves from the system to leak test them on a test stand. Because of this difficulty and scheduling restraints of system outages during refueling outages, it is impractical to.
leak test both valves during the same refueling outage. - Therefore, Waterford 3 proposes to leak test the valves on a staggered basis during i
each refueling outage. One valve will be removed and leak tested on a test stand in the same orientation as installed in the plant. If that valve fails the -
leak test, the remaining valve will also be leak-tested during the same -
outage prior to startup.
l Revised Relief Request 3.1,74 is given in Attachment B of this submittal.
L
~3)
BASIS FOR CURRENT ACCEPTABILITY OF SI-107A(B)
SI-107A(B) are check valves located in the outlet piping of the Refueling Water Storage Pool (RWSP) which allow suction for the Safety injection and Containment Spray pumps. The valves also perform a safety function in the closed direction after the suction scurce shifts to the SIS Sump _to -
- prevent contaminated sump water from entering the RWSP which is vented -
to the Reactor Auxiliary Building and provides a potential pathway to the -
environment.
In order to ensure these valves will perform their open and close function, SI-107A(B) are disassembled and visually inspected during each refueling outage and are partially stroked after reassembly. This is done on a staggered basis. In addition, the vslves are partially stroked every three months. Waterford 3 believes these actions demonstrate the ability of SI-107A(B) to perform their open and close functions.
Att:chment A to W3F1-97-0036 Page 5 of 5 4)
ACTIONS TAKEN IN REGARD TO WATERFORD 3 SUBMITTALS Waterford 3 has taken several actioas relative to the error in the August 19, 1993 submittal, the IST Plan, and NRC submittals in general.
The error regarding SI-107A(B) has been documented in the Waterford 3 corrective action program. In addition, the issue of quality of Waterford 3 submittals to the NRC has been addressed in a separate root cause analysis and has been identified as an adverse trend.
All Waterford 3 IST relief requests are being evaluated and either updated or deleted as part of preparation for submission of a new 10-year IST Plan to be submitted in December 1997. This review of relief requests will be completed by December 1,1997. A review of existing Cold Shutdown Justifications and Relief Requests is being conducted to ensure deferred testing activities are not required to be performed for reasons other than IST, which may invalidate the justifications provided or relief granted. This review is being performed as part of the December 1997 planned 10-year IST Program submittal.
Procedure NOECP-258," Control of the Waterford 3 Pump and Valve Inservice Test Plan", will be revised to require a review of operating procedures and non-IST test requirements for valves proposed to be tested at cold shutdowns in the IST program. The due date for this revision is December 9,1997, l,
l l
ATTACHMENTB Revised Relief Request 3.1.74
Attachment B to W3F197 0036
} age 1c'2 3.1.74 Test Requirement IWV 3422 requires that Category A valves shall be leak tested at least once every 2 years.
Basis for Relief These ch3ck valves are located in the outlet piping of the Refueling l
Water Storage Pool (RWSP) and allow suction for the Safety l
Injection and Containment Spray pumps. The valves also perform a I
safety function in the closed direction after the suction source shifts to the SIS Sump to prevent contaminated sump water from entering the RWSP which is vented to the Reactor Auxillary Building and provides a potential pathway to the environment.
There are no connections installed between either of these check valven and their corresponding isolation valves just upstream that would allow collection of leakage past these check valves for measurement of leakage rate. Because there is a large open ended tank (RWSP) located just upstream of the isolation valves, it is impractical to measure the leakage rate at a point upstream of tne Isolation valves.
Removing these check valves from the system in order to leak test them on a test stand requires the use of temporary scaffolding.
Because of the difficulty in removing these large check valves from the system and the scheduling constraints of system outages during refueling outages, it is impractical to perform leakage testing on both of these check valves during the same refueling outage.
Alternate Testing One of the two check valves (SI 107A and SI-1078) will be removed and leak rate tested on a test stand in the same or!entation as installed in the plant during each refueling outage on a staggered
- basis, in the event a valve fails the leak-rate test, the remaining valve in the group will also be leak-rate tested during the same outage prior to startup.
P v
)
Att:chment B to W3F197-0036 Page 2 of 2 4
Comments Original approval per NRC SE dated February 8,1994.
Valves 1
SI-107A i
Sl1078 l
l
(
ATTACHMENT C Copies of Referenced Codes and Standards
ARTICLE IWV 2000 DEFINITIONS IW%2100 ACnVE AND PASSIVE resposes to some syenes characteristic, och as VALVES P' essure (relief valves) or Sow direction (check valves).
(a) Aestw mlar - valves which m required to changs @ to acom@ a species h (4) Casspory D - valve which m actuated by an (6) flasshe wher - valves which are not respaired energy sourse onpable of only one operation, such as rupture disks or --
- valves, to change position to r - ;"* a species hansosos.
-IW%2200 CATEGORIES OF VALVES IW%2300 OntER DEFINITIONS Valves within the scope of this subenedos shan he (a) Krwalsdag-the % based on dhset placed is one or more of the toucwing ostegones.
or indirest viemal or other poestive indicadon that the When more than one disdagm.%ng category charac-moving parts of a valve Anastion satisfactorily.
tenstic is applicable, au requirassets.of each of the (6) Inservder fylr - the pened of time installation ladividual ensegories are appdesble, although depilon-and asseptamos untu retired froen servica.
' tion or repetition of common tesdag.J
_is (c) Inservder test - a special test procedure for act nec4eenry.
obtaining leformados through meneurement or obser.
(a) Category A - valves for widch sent leakage is vation to de armine the operadonal rd-of 'a liadted to a spes Ac maaimm assomat in the closed valve.
pondon of falitheast of their tuaction.
(4) W-
- routine valve servicing or work (6) Categosy 5 - valves for which sent leakage is on a valve undertakaa to correct or prevent na the closed position is I--dal for fIslalkaest of abaonaal or -
aaadie'a=
^
their fusodos.
(e) C.--
- ! reedhiser - the capabdity of a c
(c) Category C - valves which are self esameting is valve to Aden its fhastion.
Igo y
r
sw v.sel.b4wV.M13 SgCTION XI - DiebtON to the* actuating signal to the end of the actuating cycle.
corrective action shall be k dated immartiately. If the (6) The stroke time of all poww operated valva condition is aw. ~
mot be, mrrected within 24 hr, shall be measured to the nearest second, for stroke the valve shall be de.;lared inor..stive. When correc.
times 10 see or less, or 10% of the speeded limiting tiw action is required as a result of tests made during stroke tiaw for th114troke tienes longer than 10 ses cold shutdown, the condidon shall be corrected before whenever such a valve is full 4troke toted.
startup. A retest showing avd!: operation shall be run following any requieed co.rective action before the valve is returned to service.
TWV4414 Valves la Regnier Use Valve which operate in the course of plant opera.
!WV.MN VAI.VE N M'I'E 'I'ES'I' tion at a frequency which would satiety the esercang l
requira-amen of this Subsection need not be addition.
!WY.M21 Seepe any eM prwidd that se observadons othw.
wies requirai tw tesdag are e and a4W Category A valva shall be leak toted eacept that duririg such operados and are recorded in the plant valve which function la the course of plant operation g,,
g
,, 7 y
record at latervals no greater than apa, aad n IWY.
i 34II' sent tightness need not be leak tested. In such cases, the valw record shall provide the basis for the conclusion that operational observations constitute IWV. Mis FellSafe Valves When practical, valves with fail-sete actuators shall be tested by observing the operatica of the valves upon IWY.M22 Fregosary
- '"*'*'P'*"
once every 3 months,'they shall be tested during each Tats shall be conoucted at least once evwy 2 yars.
cold shutdown; la case of frequent r.old shutdowns, these valves need not be tested more rAsa than omas' evay 3 months.
IWV.M23 M Tut h Valve sent leakage tests shall be made with the pressure diferential in the same direction as when the IWY.Mle Valves la Spetems Ou* et Servios valve is performing its fhaction, with the following For a valve in a system declared !=:nd!: or not eacepdons, rainited to be operable, the esercisinglest schedule (a) Obype valves may be toted with pressure under se mat.
need not be followed. Withia 30 days prior to esturn of the system to operable status, the valves shall be (6) Butter 9y valve may be tested in either direc.
esercised and the schedule resumed la h tica, provided their seat construction is designed for with requirements of this Ardele.
seab; agaanst pressure on either nde.
(c) Gate valves with two. piece disks may be tested by pressurtains theat between the ersta.
!WV.MU Ce m (d) Valve (easept check valves) may be tated in either direction if the function diferentici pressure is (a) If, for power operated valves, as increase in 15 poi (100 kfa)or less, stroke time of 25% or more from the previous test for
(#1 !.eakage tests involving pressure d:Serentials valves with full stroke thmen greater then 10 see or lower than fonction pressure diferentials are pwmit.
50% or amore for valve with full stroke thmes less ted in thces types of valves in which service pressure than or equal to 10 see is observed, test frwp scy shall will tend to diminish the overan leakage channel
- be increased to once each month until werective opening, as by preseirsg the disk into or onto the seat action is taken, at which tiene the original tot with greater force. Oate valva, check valva, and frequency shall be resumed In any case, any abnor.
globe type valves, having function pressure diferential mality or erratic action shall be reported.
applied ove: the seat, are examples of valve applica.
(6) If a valve fails to uhibit the required change of tions satisfying this requirement. When leakage tats valve steni or disk position or uceeds its speci8ed are made la such cases using pressures loww than limidng value of full stroke time by thie tatint;, thm; function maximum pressure diferential, the observed 182
I,WV.)S36tCV.)S23 SEC rire' "
LetsloN I TAtt i IWV.)$101 (a) yorme//y open Valeen Valves that are normally CATEGORY C: SAFETY AND RELIEF val.VES open during plant operation and whose function is to Tntisg Sem err e.it revevoed now shall be tested in k manner that proves that me disk trawls to % sent promptly on cessation or reversal of now. ConArmation that the ed.oue Min. mum of No 60 = totas nem in m,,
disk is on its seat shall be by visust observation. by an lit rewung uwoorr (Now tail electncal signal initiated by a position indicating tit rewhg amitieaal n'* to m** cumulatn* tatd device, by obewvation of appropriate pressure indica.
mroue 2nd M least NelW = total valves in mis tions in the systest, or by other positive means.
- rewna, caw,wy (Now tt:1 (6) Normally Closed Velves. Yalves that are not.
2nd rewnne aseitional aim to mae cumulatw tawd mally closed during plant operation and whose func.
meove 3rd at ient Nr 60 = total aim in mis cow.
tion is to open on reversal of pressure diferential shall rewong, etc.
gory, etc. lNow (111 be tested by proving that & disk moves promptly away from the sent when the closing pressure NOTt diferential is removed and Sow through b valve is iti N., N, N, etc., are a nummes of menes from starse to fint initiated, or when a mechanical opening force is i
Nm M [ t N,) Infm Ycn Y a s n"t M applied to the disk. Canarmation that the disk moves suring w precwing s rear perees mesi se uswd. The folio no away froen the sent shall be by visual observation. by perios irwi wa to consieww to to a same m " start e to fint electrical signal initiated by a position Indicating N,1,',*hE[,.Tc "d" ",',oNQino,"
devios, by observation of shaatially free now enn tutw ouring a preemine s ren swies wi tw inus. The through the valw as laha=8 by appropriate pressure tuoleouent period will be contioerw me lame m the f6rst refue4*
Indications in the systein, or by other positive means.
monN i)tEio*[ " '"'""'"" h * """'
This test may be made with or without now through the valve. Ifit is mad without Sow through the valve, a mechanical eserciser shall be used to inove % disk.
The force or torque deHvwed to the disk by the esercuer must be limited to less than 10% of the equivalent force or torque represented by the mini.
IWV.3830 1 TTS FOR CHECE VALVES mum emergency condition pressure diferential acting on the dick, or to 200% of the actual obsernd force or IWV.3521 Te6 Frognoney torque required to perform the esercise on the valve Check valves shall be esercued at least once every 3 when b valw b new and in good opwating condi.
months, encept as provided by IWV.3522.
tion, whichever is less, encept that for vacuum breaker valves the eserciser force or torque dehvaed to the disk may be equivalent to the desired functional IWV.3522 Esercising Precedure pressure diferential force. The disk movement shall be Check valves shall be exercised to the position sudBeient to prove that the disk moves freely of the required to fulAll their function unless such operation seat. For swing or tilting disk valus, if the test is made is not practical during plant operation. If only thnited by une of Guld Sow through the valve, the pressure operation is practical, during plant operation the difwential fw aquivalent Sow shall be no greater than check valve shall be.part stroke esercised during plant that observed dunas the preoperational tese. For other opwation and Ml streke esercised during cold shut.
types of check valves, it shall be shown that disk downs. Valves that cannot be esercised during plant monment is sht to prede a Sow area at least operation shall be speiaScally identiend by the Cwner 50% of the area of the nest port, w to pwmit now and ; hall be full stroke esercised during cold shut.
adequate tw the % of the valw.
downs. Full stroke esercuing during cold shutdowns for all valves not full stroke exercued during plant operation shall be on a frequency detennined by the IWY.3823 Correedte Acties mtervals betwevn shutdowns as follows: for lutavals of 3 months or longw, esercise during each shutdown; if a check valve fails to exhibit the required change for intervals of less than 3 months, full stroke exercise of disk position by this testing, corrective action shall is not required unless 3 months have passed since the be initiated immediately, if the condition is not, or can last t,hutdown exercise.
not be, corrected within 24 hr, the check valve shall be 164
NRC STAFF POSITION 2 ALTERNATIVE TO FULL-FLOW TESTING OF CHECK VALVES The most common method to fbu-stroke operating restrictimg vaNo disassembly eustrise a check vaNo open (where disk and inspection may be perfonned during position is not observable) is to pass the reactor reibeling outages. Since this 95 maxinann required accident Sow through the quency differs tom the Code required vehe. However, fbr some check valves, Aequency, this deviation must be licensees cannot prutloany establish or verify spectScany noted in theist program.
sul5 sset flow to ibl.etroke energies the valves open. Some examples of such valves (c) Where the licenses determines that k is are, in PWRa, the containment sprey header bunionsome to disassemble and inspect a5 check valves and combined LPSI(low -
applicable vehe each reibeling outage, a pressure safety iriection) and safety isiection sample disassembly and inspe: tion plan
--i-- heder eh ek viive end, in ihryoups ofm hein simaer v
BWRa, the HPCI or RCIC check valves in the appilandons say be employed. The NRC pump sustion ihna the suppression pool, la guidsEnos ihr this plan are explained most commamiel ibsilities, establishing design below; accidern Sow through these valves ibr needng could resuk in damage to nedor piant T1 mmpledimmemblyandinspection equipment.
progmainvokes youping simuar valves and testing one vehein each The NRC maffpositionis that valve poup during each reibeEng outage.
disassembly and inspection can be used as a The sampling technique requires that positive means of determining that a valve's sesh valvein the group be the asme disk wiB dbu.etroke ensreise open or of desipi(manulbsturer, sian, model verifying closure espebuity, a permitted by number, and materials rf consevedon)
IWW3522. If possible, penial valve semidas and have the sees servios condklons quarterly or during acid shutdowns, or ener insinding velve orientados.
reassembly must be perfbnned.
Addidensay, at enA disassembly the assasse amat verifythat the di 1he staff has enablished the fotowing assambled valve is espable ofib5-porinons reganling teming cheek valves by stroldsg and that the internals of the valve are structurally sound (no loose or sorroded parts). Also,if the (a) During velve testing by dina==adly, the disassembly is to verify the fbikstroke vaheintamais should be visueBy capability of the vah J, the disk should inspected for worn or comuled parts, and be annuaBy surcised.
the valve disk should be manuaBy enercised.
A diSusut valve ofeach youpis to be "- -M'O W (b) Due to the scope of this testing. the and manuanyib5-stroke exercised at personnel hazards involved and system each successive refueling outage, untu
/
A7 NUREG 1482
methods to d==aaserete the g"'N of using Sow (or a mechanical eneroiser) to be check wives.
performed quarterly. Where fhil stroke euroisins osanot be partbreed quarterty, tem Carrent Comoidersticas Code allows the performance of this test during oold shutdowns. Full aroke snarcising Redbr in NRC Information Notice 89 42, during redheling outages may be an anospeable "Malfbnetion of Borg-Warner Pressure Seal ahomasive if the test cannot be perforened at Bonast Cbsok Valves Caused by Vertical cold %.., but this appmemb would Mienlignment of Disk," for an example of a require =d=i==iaa of a relief request. For valve disk installation problem.
those osses where ibil stroke ausreising cannot be partbrmed quarterly, during ooid shutdown, Questlee Group 16 or during redheling outages, a=====edy and inspeadon in osedbemance with Position 2 of Quentless Genericloner 3904 is alkrwed as as abernative. If the provisions ofPoshion 2 are Even though the check valve flow testing can ibliowed, a relief reguest need not be be peribrmed as required by ASME Se ion ad-inad for NRC review but this devistica XI, may the valve ten be partbreed by som the ASME Code should be a====ead disassembly as pennhead by Position 2 in (See also the resposes to Question 15).
Generic Imter 8944 when k is considered by tow anky the tudng by disassembly wB Comme t'a==ad-atises pmvide the same or greater assurance that the valve wB dhnesion property? (Note: If A relief reguest is no longer required Air Possible, partial valve aroking quartedy, or a dedhrrel of tenhus to reemiing outages.
cold shutdown, or aAer re assembly would be However,if teming een be premienBy peribuned.) If the answer is yes, (a) can the paribemed, but spacine situations occur that tem esquency, esepin, me., as desamied is sound osum daisys or other problems during Generic Lemer 3904 Posiden 2 be used in lieu renseling outages making a test in.t: n of ASME Semion XI requirement-even if the the licenses may request resisttom performing Section XI test could be partened, i.e., et disassembly and inspeadon during that one cold shutdown; (b) aust a reusf reguest be redheling outags. (See Sectica 3.1.1).
processed or may this " test by disassaml&' be noted in the valve IST pmgrum submittal to Qassdes Group 17 the NRC; and (c) must a relief reguest be pmommed or may *be toquency ample, etc.,
Quesdes be noted in the valve IST program submittal to the NRC7 May the valve testing by "-
' '//n' inspendon haeinad in Poshion 2 of Generic
Response
- 1. meter 3904 be applied to reverse Sow testing ofcheck valves?
The vedous methods aimed at evalundng the operabilky of check valves are not equaty m;d': to the NRC maE At the outset, the ASME Code requires a ibB stroke enerties s
NUREG 1482 A.12 J