ML20214Q740
| ML20214Q740 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/28/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| ULNRC-1519, NUDOCS 8706050140 | |
| Download: ML20214Q740 (4) | |
Text
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UNION ELECTRIC COMPANY 1901 Grotiot Street, St. Louis Donald F.Schnell Vice President May 28, 1987 Mr. Harold R.
Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
ULNRC-1519 DOCKET NUMBER 50-483 CALLAWAY PLANT CALLAWAY PUMP AND VALVE INSERVICE TESTING PROGRAM
References:
1)
ULNRC-738 dated January 31, 1984 2)
ULNRC-833 dated May 29, 1984 3)
ULNRC-1039 dated February 11, 1985 4)
ULNRC-1127 dated June 28, 1985 5)
ULNRC-1152 dated August 9, 1985 6)
ULNRC-1267 dated June 28, 1986 7)
ULNRC-1426 dated January 14, 1987 8)
ULNRC-1484 dated April 14, 1987 Reference 1 transmitted the Callaway Pump and Valve Inservice Testing Program.
References 2 through 8 transmitted updates to this same program.
Attached is a one-time relief request associated with the Inservice Testing Program for your review.
This relief is necessary to avoid a potential unit shutdown.
As such, expedited handling of this request would be appreciated.
If there are any questions, please contact us.-
Very truly yours, k$
b onald F. Schnell D
WAW:kac Attachments h83 0
PDR do41 Mailing Address RQ Box 149. St. Louis, MO 3166 lh
cc:
Gerald Charnoff, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, DC 20037 Dr. J. O. Cermak CFA, Inc.
4 Professional Drive (Suite 110)
Gaithersburg, MD 20879 R. F. Warnick Chief, Reactor Project Branch 1 U.
S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Bruce Little Callaway Resident Office U.
S. Nuclear Regulatory Commission RR#1 Steedman, MO 65077 Tom Alexion (2)
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102
ATTACHMENT to ULNRC-1519 Pago 1 of 2 ONE TIME SECTION XI RELIEF REQUEST VALVES:
BB-8949B,C, EJ-8841A,B FUNCTION:
Open on flow from the residual heat (RHR) pumps to reactor coolant hot legs.
TEST REQUIREMENT:
Per IWV-3520 of ASME Section XI; " Check valves shall be exercised at least once every three months, except as provided by IWV-3522.
IWV-3522. Exercis-ing Procedure; Check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.... Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full-stroke exercised during cold shutdowns...."
The Callaway Nuclear Plant Inservice Testing Program specifically identifies these valves to be tested on a cold shutdown fre-quency.
REQUESTED RELIEF:
Contrary to the above requirement, the above valves may not have been tested.in the open direction during the Mode 5 (Cold Shutdown) outage _recently completed at Callaway, even through sufficient time was available to perform the tests.
At present we are reviewing documentation to identify if these valves were tested.
In the event documentation is not found, we request,one time approval to not perform the specified tests until the next plant outage to cold shutdown or refueling conditions.
BASIS FOR RELIEF:
a)
Similar valves (BB-8949A D, EM-V001,002,003 and 004) from the safety injection pumps to the reactor coolant hot legs are tested on a refuel-ing frequency per Relief Request EM-2 and BB-2 of the Inservice Testing Program.
These Relief Requests were based on the conditions needed to test the safety injection valves.
The additional risk associated with not testing the RHR valves at this time is no greater than the additional risk associated with not testing the safety injection valves, b) We have had no history of failures or problems with these valves.
The valves were tested satisfactorily prior to startup of the plant (5/84) and during Refuel I (4/86).
There has been no indication of degration of these valves.
' ATTACHMENT to ULNRC-1519
- Pigs 2 of 2 c)- Since no failures or; problems have. occurred, che added margin ofl safety which might be gain'ed by performing.this test does not justify-the-possible expense, hardship, and additional risks-
~
associated with the transients of shutting.down and starting up the unit to perform the tests.
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