ML20215D565
| ML20215D565 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/12/1986 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8612160406 | |
| Download: ML20215D565 (5) | |
Text
s TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place IEC 12 986
-Director of Nuclear Reactor Regulation Attention:
Mr. B. Youngblood, Project Director PWR Project Directorate No. 4 Division of Pressurized Water Reactors (PWR)
Licensing A U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Youngblood:
In the Matter of.
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT - ADDITIONAL RELIEF REQUESTS TO SEQUOYAH'S IN-SERVICE TEST PROGRAM As a follow-up to Sequoyah's response to NRC's request for additional information. TVA is submitting three additional relief requests to Sequoyah's In-service Test (IST) Program. These relief requests consist of:
(1) updating requirements for testing safety and relief valves to later standards; (2) defining test methods for pumps in fixed resistance systems;
.and (3) providing flexibility from the impractical requirements for range and accuracy of specific test instrumentation.
In addition to these relief requests, Sequoyah is providing a statement of position in regard to a 1977 Code requirement for measuring pumped fluid temperature. A thorough description of these relief requests and Sequoyah's statement of position is included as enclosure 1 and enclosure 2, respectively.
These additional relief requests are in line with current code practice and provide sequoyah with a better IST program.
If these relief requests significantly hinder NRC's preparation of a revised SER, a written response doctunenting NRC review and concurrence with Sequoyah's pump and valve program would be beneficial for Sequoyah restart. Upon receipt of either a revised SER or written NRC concurrence, Sequoyah will change its pump and valve j
program to be consistent with NRC's approved position.
If you have any questions regarding this subject, pleaso call M. J. Burzynski at extension (615) 870-6172.
/
Very truly yours, 8612160406 861212 TENNESSEE VA LEY AUTHORITY PDR ADOCK 05000327 P
PDR j
R. Gridley, rector Nuclear Safety and Licensing Enclosures
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cc: See Page 2 047 An Equal Opportunity Employer
. Director of Nuclear Reactor Regulation DEC 12 W cc (Enclosures):
U.S. Nuclear Regulatory Comission Region II Attn:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Carl Stahle, Sequoyah Project Manager U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue Bethesda, Maryland 20814 Mr. G. G. Zech Director, TVA Projects U. S. Nuclear Regulatory Conunission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 i
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ENCLOSURE 1
-RELIEF REQUESTS FOR SEQUOYAM'S IN-SERVICE TEST (IST) PROGRAM x
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-1.
SAFETY AND RELIEF VALVES Relief is requested to update ANSI /ASME OH-1-1981 for-testing of safety and relief valves for units 1 and 2.
ANSI /ASME OM-1-1981 was adopted by the Winter 1985 Addenda to the 1983 edition of the ASME Section XI Code.
The use of OH-1 is also endorsed by Revision 5 of Regulatory Guide 1.147 under Code Case N-415.
Sequoyah's present unit 1 requirements are listed in IWV-3510 (1974 edition; Summer 1975 Addenda) which requires testing in accordance with the ASME Power Test Code 25.22-1966.
Sequoyah's unit 2 requirements are listed in IWV-3512 (1977 edition; Summer 1978 Addenda) which re pires testing in accordance with the ASME Power Test Code 25.3-1976.
ANSI /ASME OH-1-1981 provides clearer guidance and will allow using the same requirements for both units.~ This relief request will provide Sequoyah with a better program and, therefore, should be granted.
2.
PUMP IN-SERVICE TEST PROCEDURE Relief is requested for Article IWP-3100 (1977 edition; Summer 1978) that requires adjusting the system resistance until either the differential pressure or flow rate is equal to the referenced value.
Presently, Sequoyah's auxiliary feedwater, centrifugal charging, safety injection, and residual heat removal pumps are tested using a fixed resistance miniflow circuit.
The boric acid transfer pumps are also tested using a fixed resistance system.
This practice of using a fixed resistance circuit meets the intent of the code and provides adequate evaluation of pump performance. Additionally, throttling of a miniflow line could potentially degrade plant equipment, since the miniflow line is required to be fully open to provide pump cooling flow.
Sequoyah, therefore, requests that the subject pumps tested in fixed resistance systems be exempted from setting one parameter to the reference value as required by IWP-3100. These pumps will be operated in their fixed resistance systems and both differential pressure and flow rate will be compared to reference values as required.
3.
TEST EQUIPMENT - ACCURACY AND RANGE IWP-4120 (1977 edition; Fummer 1978 Addenda: Sequoyah unit 2) and IWP-4111 (1974 edition; Summer 1975 Addenda: Sequoyah unit 1) require that the range of each test instrument be within three or four times the reference value respectively.
In certain cases, it is either
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. impossible or impractical to always meet this requirement; and, therefore, Sequoyah requests relief to use test equipment as outlined below.
Certain pumps have low suction pressure requirements, such as the a.
boric acid transfer pumps, where pressures as low as 1.5 psig have been recorded. To meet the requirements of IWP-4120 and IWP-4111, a pressure gauge of 4.5 psig or less is required.
This is not practical and would require purchase and installation of specially made low range pressure gauges. Also, the maximum allowable error for a 4.5-psig gauge is two percent of full scale or 0.09 psi.
The maximum allowable error for a 15-psig gauge is two percent of full scale or 0.30 psi.
The difference in accuracy of the two gauges is only 0.21 psi which is negligible considering the error allowed by the discharge gauge. Sequoyah, therefore, requests relief to use no lower than a 15-psis pressure gauge for all section XI pumps, b.
A second area where the IWP-4111 and IWP-4120 range requirements become impractical or impossible to meet is instrumentation such as vibration equipment; thermocouples, tachometero, and differential pressure transmitters.
Vibration equipment, for example, have standard scales of 1, 3, 10, 30, and 100 mils.
A reading of 3.1 mils could not meet the range requirement of four times the reference value (IWP-4111). Another example involves differential pressure transmitters with available accuracies of 0.25 percent and a range of 0-125 inches of water. A WP reading of 20 inches (a normal reading for an ERCW pump at Sequoyah) would not meet the IWP-4111 required range upper limit of 80 inches. The actual error for the Sequoyah instrument would be 125" x 0.25% or 0.3175 inches of water, while the code allows up to 80" x 2% or 1.6 inches of water.
Sequoyah's actual overall accuracy is clearly better than what the code requires.
The intent of IWP-4111 and IWP-4120 is to limit the maximum test instrument error to four or three times the values of table IWP-4110-1.
Test instrumentation used by Sequoyah will have overall accuracies that meet or exceed that required by IWP-4111 and IWP-4110-1 or IWP-4120 and IWP-4110-1, as applicable.
To allow flexibility while still meeting the overall accuracy required by the code, Sequoyah requests relief from meeting the range requirements of IWP-4111 and IWP-4120 for vibration equipment, thermocouples, tachometers, and differential pressure transmitters.
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e-ENCLOSURE 2 STATEMENT OF POSITION REGARDING PUMP FLUID TEMPERATURE Sequoyah would like to state its position on IWP-4320 (1977 edition; Sunner 1978 Addenda). Pumped fluid temperature is not one of the in-service test parameters listed in table IWP-3100-1.
Also, IWP-4320 is not in the 1974, 1980, or 1983 edition of the code. Considering the above, it is Sequoyah's position that the pumped fluid temperature is not a required test.
parameter.
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