ML20212P923
| ML20212P923 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/06/1987 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-62871, TAC-62942, NUDOCS 8703160353 | |
| Download: ML20212P923 (8) | |
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'Af Telephone (412) 393-G000 Nuclear Group hh$pYgport, PA 15077-0004 0
U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 2 Docket No. 50-412 Pressure Isolation Valve (PIV) Testing Gentlemen:
As per the conference call on February 6,
1987 between K.
D. Grada of Duquesne Light Company and members of the NRC staff, a revised copy of the subject technical specification is attached.
Our justifications for excluding certain PIVs from testing are also included.
Our proposed specification does not include the Revision 5, Standard Technical Specification items 4.4.6.2.2(b) and (d) for the following reasons:
1.
Excessive leakage through the Residual Heat Removal Valves (2RHR-MOV-701A, B,
702A, B, 720A, B) would be detected by a high pressure alarm on the RHR
- System, actuation of the installed relief valves and pressure indication in the control room for the RHR system.
The valves are also interlocked to preclude opening if RCS pressure is above 425 psig with automatic closure at 750 psig.
2.
Excessive leakage through the SIS Accumulator Check Valves (2 SIS-141,
- 142, 145,
- 147, 148, 151) would be detected by installed high pressure and high level alarms on the accumulators.
Each accumulator has two pressure and level transmitters that provide this function.
3.
SIS Check valves (2 SIS-128, 129 and 130) are isolated from low pressure piping by a normally closed valve (2 SIS-MOV8889).
This piping between the
' check valves up to this MOV is high pressure piping.
Leakage through this MOV would be detected by operation of relief valve (2 SIS-RV8865) which is located between (2 SIS-MOV8889) and (2 SIS-MOV8887A and B).
This relief valve has a capacity of 25 gpm at a lift pressure of 220 psig.
Operation of the check valves in this line is not expected on an inadvertent SIS signal because the normally closed MOV (2 SIS-MOV8889) does not open on an SIS signal.
Low Head SI flow through this
- line, under accident conditions, would not occur until 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> after a
significant
8703160353 870306 PDR ADOCK 05000412 l
A PDR l(
Bacvsr Vellcy Powar Station, Unit No. 2 Dockst No. 50-412 Pressure Isolation Valve Testing Page 2 Please note that the high pressure coolant leakage through all of the afforementioned flow paths would also have to be quantified under RCS leakage testing.
This test is performed pursuant to BV-2 Technical Specification 4.4.6.2(d) on a 72-hour basis.
This would limit the integrated identified leakage to a maximum of 10 GPM.
Following the issuance of the approved BV-2 specifications, we will revise the BV-1 specifications, where appropriate, to correct any technical deficiencies identified during the Duquesne Light Company and NRC review process.
Very tr ly yours, J. J.
Carey Senior Vice President Nuclear Attachment cc: Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission Regional Administrator Region 1 631 Park Avenue King of Prussia, PA 19406 l
Mr. Peter S. Tam U. S. Nuclear Regulatory Commission Project Directorate No. 2 Division of PWR Licensing - A Washington, DC 20555
- Mail Stop 340 Addressee only Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza l
Richmond, VA 23261
4 3/4.4 REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES LIMITING CONDITION FOR OPERATION 3.4.6.3 Reactor coolant system pressure isolation valves as shown in Table 4.4-3 shall be operable.
APPLICABILITY:
MODES 1, 2, 3, and 4 ACTION:
1.
With any Reactor Coolant System Pressure Isolation Valve leakage greater than the above limit, isolate the high pressure portion of the affected system from the low pressure portion within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of closed manual or deactivated automatic valve, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUIDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.(*)
2.
The provision of Specification 4.0.4 is not applicable for entry into Mode 3 or 4.
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(*)
Motor operated valves shall be placed in the closed position and power supplies de-energized.
BEAVER VALLEY UNIT 2
5 TABLE 4.4-3 REACTOR COOLANT SYS'IT.M PRESSURE ISOLATION VALVES Leakage Rates (a)
System Valve No.
Allowable /Maximus Loop 21, Cold leg, LHSI 2 SIS-107 13.0/15.0 spe(b)(d)
Loop 22,-Cold leg, LHSI 2 SIS-108 53.0/15.0 spe(b)(d)
Loop 23, Cold leg, LHSI 2 SIS-109 53.0/15.0 spe(b)(d)
Common, Cold leg, LHSI 2 SIS-132 55.0/s5.0 spe(d) 2 SIS-133 55.0/15.0 gpe(d)
Loop 22, Hot leg, LHSI 2 SIS-128 13.0/55.0 gpe(b)
Loop 23, Hot leg, LHSI 2 SIS-129 13.0/15.0 spe(b)
Common, Hot leg, LHSI 2 SIS-130 15.0/15.0 spa Loop 21, Cold leg, SIACC 2 SIS-151 55.0/55.0 spe(b) 2 SIS-148 55.0/55.0 spe Loop 22, Cold leg, SIACC 2 SIS-145 55.0/55.0 spe(b) 2 SIS-147 55.0/15.0 gpa Loop 23, Cold leg, SIACC 2 SIS-141 55.0/15.0 spe(b) 2 SIS-142 15.0/55.0 spe Loop 21, Hot leg, RHS-A 2RHS-MOV702A 55.0/15.0 spe(b) 2RHS-MOV701A 15.0/55.0 spe(b)
Loop 22, Cold leg 2RHS-MOV720A 15.0/15.0 gpe(b)(c)
Loop 21, Not leg, RHS-B 2RHS-MOV702B 55.0/55.0 spe(b) 2RHS-MOV701B 55.0/15.0 gpm(b)
Loop 23, Cold leg 2RHS-MOV720B
$5.0/55.0 gpe(b)(c)
(a) At function pressure:
1.
Leakage rates less than or equal to 0.5 gpe/ inch diameter are acceptable.
JEAVER VALLEY UNIT 2
I e.
3/4.4 REACTOR COOLANT SYSTEM 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE SURVEILLANCE REQUIREMENT 4.4.6.3.1 Leakage testing (**) of each valve listed in Table 4.4-3 shall be accomplished prior to entering Mode 2 after every time the plant is placed in the cold shutdown condition for refueling and prior to returning the valve to service after each maintenance, repair or replacement work is performed.
4.4.6.3.2 Leakage testing of each WASH-1400 EVENT V valve listed in Table 4.4-3 shall be accomplished prior to entering Mode 2 after every time the plant is placed in the cold shutdown condition for refueling, after each time the plant is placed in a cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing has not been accomplished in the preceeding 9 months, and prior to returning the valve to service after maintenance, repair or replacement work is performed.
(**) To satisfy ALARA requirments, leakage may be measured indirectly (as from the performance of pressure indicators) if accomplished in accordance with approved procedures and supported by computations showing that the method is capable of demonstrating compliance within the valve leakage criteria.
BEAVER VALLEY UNIT 2
2.
Leakage rates greater than 0.5 gps / inch diameter but less than or equal to 5.0 gpa are considered acceptable if the latest measured rate has not exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpa by 50 percent or greater.
3.
Leakage rates greater than 0.5 gpm/ inch diameter but less than or equal to 5.0 gpa are considered unacceptable if the latest measured rate exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpa by 50 percent or greater.
4.
Leakage rates greater than 5.0 gpm are considered unacceptable.
(b) Minimum test differential pressure shall not be less than 150 psid and should ha scaled up in accordance with ASME XI IWV 3423.
(c) Leakage rate continuously monitored during plant operation, no'other leakage rate testing required.
(d) WASH-1400 EVENT V Valve J
l BEAVER VALLEY UNIT 2
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i COMMENTS ON NRC SUBMITTED LIST OF PIV'S 1.
Accumulator to cold leg checks:
2 SIS-1Ad!
2 SIS-142 2 SIS-145 2 SIS-147 2 SIS-148 2 SIS-151 Response: DLC agrees and these valves will be included as PIV's.
2.
Safety injection to cold leg checks:
2 SIS-107 2 SIS-108 2 SIS-109 2 SIS-548 2 SIS-550 2 SIS-552 2 SIS-134 2 SIS-135 2 SIS-136 2 SIS-137 2 SIS-138 2 SIS-139 Response: DLC considers 2 SIS-107, 2 SIS-108, 2 SIS-109, 2 SIS-132, and 2 SIS-133 as PIV's.
These valves provide 2 barrier protection against the high-pressure / low pressure interface with the low head safety injection system piping.
It should be noted that the safety class 1/ safety class 2 break does not occur at the high pressure / low-pressure, (i.e. class 1502/153),
interface which is the area of concern. DLC does not consider 2 SIS-l 134, 2 SIS-135, 2 SIS-136, 2 SIS-137, 2 SIS-138, and 2 SIS-139 to be PIV's since these valves do not have a
high-pressure / low-pressure interface with Low Head Safety Injection system piping. This group of check valves lead to High Head Safety Injection piping which is all high pressure class piping.
In addition, 2 SIS-548, 2 SIS-550 and 2 SIS-552 l
are not included as PIV's.
These 3 valves have the i
high pressure / low pressure interface, however, 2 barrier protection is provided by 2 SIS-107, 2 SIS-108, 2 SIS-109, 2 SIS-132, and 2 SIS-133.. As previously discussed and agreed to by the NRC, any two barriers may be chosen when several barriers exist, provided the interface is protected from the high pressure source. DLC feels its valve selection for PIV's will provide the required two barrier protection for the high-pressure / low pressure interface, and that no further valves are required.
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3.
Safety injection to hot leg checks:
2 SIS-122 2 SIS-123 2 SIS-124 2 SIS-125 2 SIS-126 2 SIS-127 2 SIS-128 2 SIS-129 2 SIS-545 2 SIS-546 2 SIS-547 Response: DLC considers 2 SIS-128, 2 SIS-129, and 2 SIS-130 as PIV's.
These valves will provide 2 barrier protection for the high pressure / low pressure interface with the Low Head Safety Injection system piping.
In addition, a third barrier is provided by 2 SIS-MOV8889, which is normally closed with its power removed in accordance with BV-2 Technical Specifications.
DLC feels these valves will provide the required 2 barrier protection, and that the remainder of the valves as submitted by the NRC are not required for two barrier protection.
4.
RHR suction and return isolations:
2RHS-MOV701A 2RHS-MOV701B 2RHS-MOV702A 2RHR-MOV702B 2RER-MOV720A 2RHS-MOV720B Response: DLC agrees and these valves will be included as PIV's.
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