ML20212H152

Correction to Page 7 of SE Re Relief Request for Third 10-yr Interval Pump & Valve IST Program for Plant

ML20212H152
Person / Time
Site:	Vermont Yankee
Issue date:	03/06/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20212H151	List: ML20212H146 ML20212H152
References
NUDOCS 9803120175
Download: ML20212H152 (1)

Text

d 7

test interval allowed by the Paragraph 4.3.2.4(c) of OM-10. and. therefore, provides adequate assurance of valve operability. Given tb d Code compliance would result in hardship or unsual difficulity without a compensating increase in the level of quality or safety, the staff authorizes the licensee's proposed alternative frequency of testing as described in relief request RR-V13 pursuant to 10 CFR 50.55a(a)(3)(11).

4.0 RELIEF REQUEST RR-V14 RR-V14 requests relief from the test method and frequency requirements of OM-10.

Paragraph 4.3.2. for verifying the closure capability of check valves. V14-22A,

-228. -23A and -238. These valves' are the Condensate Transfer (CT) system to CS flushing line check valves. These valves have a safety function to close to isolate safety class piping from the lower pressure non-safety grade piping in the event of a CS system actuation. In lieu of performing the test at the refueling outage. the licensee proposes to perform non-intrusive testing (radiography) on each check valve once each operating cycle within two months of the scheduled start of the next refueling outage.

4.1 Licensee's Basis For The Relief Request  !

These valves are Safety Class 2 2-inch lift check valves located in the flushing lines between the CS system and the CT system. These valves are arranged in series-pairs in each flushing line. During normal power operation, these flushing lines are isolated. There are no test connections between the check valves or in either flushing lines. Individual check valve closure capability verification is presently accomplished by performing quarterly non-intrusive (radiography) testing.

3- Indication of valve closure has been conclusive. However, this quarterly non-intrusive testing of the subject valves during power operation has proven to be ,

burdensome. The burden imposed by this test method and more frequent testing '

during power operation includes increased personnel radiation exposure, large i manpower requirements extensive test equipment setup. and increased potential for unexpected challenges to plant safety systems. It is expected that the performance of radiography during cold shutdowns would present the additional burden of obtaining contract services on short notice. It is also expected that performing radiography during refueling outages will present added risk of increased radiation '

exposure to personnel during refueling outages. Testing once each operating cycle but not during refueling outage will reduce the risk of increased radiation exposure to personnel as fewer people will be subject to possible exposure.

i 4.2 Alternate Testing In lieu of the alternative " disassembly and inspection" methods described in GL 89-04 Position 2. the licensee proposes to perform non-intrusive testing '

(radiography) on each check valve once each operating cycle within two months of the scheduled start of the next refueling outage.

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