ML20216C794
| ML20216C794 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/06/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9804150041 | |
| Download: ML20216C794 (16) | |
Text
f Ca'ye Morey Southern Nuclear t l , Vice President 0 pirating Compa:y I l Fadey Preject P,0. Box 1295 l Bkmingham. Alabama 35201
. Tel 205.992.5131 l
SOUTHERN h April 6,1998 COM M ,
Enery to Serve YourWorld** l Docket Nos.: 50-348 50-364 U. S. Nuclear Regulatory Conunission
- ATTN: Document Control Desk .
i Washington, DC 20555
)
Joseph M. Farley Nuclear Plant
, Inservice Testing (IST) Program Valve Relief Requests Submitted as Part of the 10 Year IST Update Ladies and Gentlemen:
Southern Nuclear Company (SNC) submitted on July 3,1997, updated IST programs for Joseph M. Farley Nuclear Plant (FNP) Units I and 2, in accordance with the requirements of 10CFR50.55a(f)(4)(ii). He updated programs contained pump and valve relief requests which l SNC submitted for approval. NRC and SNC have discussed these relief requests on two occasions j (November 18,1997 and h.bsr 17,1997). As a result of NRC questions and comments SNC submitted on January 22,1998 additional information, certain revised reliefs and withdrew certain other reliefs.
SNC is now submitting for approval three additional valve relief requests (Attachment I and Attachment 2). He need for these three relief requests was identified during the IST update effort and they are being submitted as part of the 10 year IST Program update. Under the provisions of 1 10 CFR 50.55a(f)(5)(iv), these reliefs are considered to have interim approval until December 31, 1998. Herefore, SNC is requesting formal approval of the requested relief by that date. %ese relief requests document the burden and justification for grouping of similar check valves for the !
purpose ofimplementing a disassembly and inspection program based on Generic Letter 8944 ,
guidance The basis of the burden andjustification for these relief requests is the same as the basis l for those check valve relief requests previously submitted and referenced above. In all cases a good inspection history for the valve group is h*ated which does not support the additional burden of having to disassemble and inspect each valve every outage.
In the discussions cited above, NRC asked SNC to address the feasibility of using non-intrusive .
y testmg techniques instead of valve disassembly in all check valve relief requests. He following discussion addresses this issue. 1 Non-intrusive techniques have not been attempted on the diesel generator senice water return I check valves which are the subject of Q1(2)P16-RR-V-4. He mim*d flow rate required to insure that the check valve disc opens fully such that an acceptable acoustic signal is generated is l
unattainable due to the normal restrictions through the diesel generators cooling components.
9804150041 980406 PDR ADOCK 05000340
, p PDR 1
U. S. Nuclear Regulatory Commission Page 2 Service water to containment cooler check valves and service water supply to diesel generator check valves which are the subject of Q1(2)P16-RR-V-2 and Q1(2)P16-RR-V-3 respectively are part of both the INPO SOER 86-03, Check Valve Failures or Degradation, program and the IST program. In order to mmimize the cost and burden of testing, the testing technique employed for these valves must meet the requirements of both programs. To meet the intent of the SOER 86-03
{
program, a non-intrusive technique would have to be able to provide a reliable indication of a valve's internal condition and not simply a full open or full closed verification as would be I sufficient for IST purposes. Results from non-intrusive (ultrasonic) check valve testing done at FNP have not been conclusive in ascertaining the internal condition or degree of degradation.
These inconclusive results make the use of non-intrusive technique, unattractive compared to the disassembly and inspection option which meets the requirements of both the SOER and IST Programs.
SNC has b:en actively following and participating in non-intrusive check valve technology since 1990 and will continue to do so with a goal of reducing the number of valves disassembled. SNC plans to disassemble the subject valves per the submitted relief requests. Since valve disassembly and inspection is a code allowed technique, these relief requests are submitted only to present the
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burden and justification for the grouping and sampling for the disassembly and inspection plan.
In the January 22,1998 letter cited above, the NRC was advised that the SNC response to one relief request, Q1(2)E21-RR-V-1 for the Accumulator check valves, was being prepared as non- ,
intrusive techniques for this application were being evalusted. In the meantime, under the l provisions of 10CFR50.55a(f)(5)(iv), these reliefs are considered to have interim approval until December 31,1998. The relief request has been revised (See enclosures) to include justification ,
for the valve disassembly sampling plan being proposed. SNC is also requesting formal granting J of the relief by December 31,1998, in case the attemate testing being evaluated proves to be .
I unfeasible.
In a phone call on April 3,1998, the NRC requested clarification on certain details of Auxiliary Feedwater Pump relief request RR-P-5. As a result, SNC has revised the relief request for both units and is submitting them with this letter. 'Ihe revision clarifies that cold shutdown pump testing will be performed at each cold shutdown and deletes the discussion of comparing measured )
pump parameters to a curve of teference values.
Should you have any questions please contact this office. ,
Respectfully sabmitted, SOUTHERN NUCLEAR OPERATING COMPANY l
f flh Dave Morey AJP:maf newrelf2. doc l Attachments I cc: Mr. L. A. Reyes, Region II Administrator l Mr. J.1. Zimmerman, NRR Project Manager Mr. T. M. Ross, FNP Sr. Resident inspector 4
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l ATTACIIMENT I Unit 1 RELIEF REQUESTS l
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FNP 1 M-094 I RELIEF REQUEST l
i QlP16-RR-V-2 Valve: QV206A, B, C, D Other Valve No: NA Drawing /Coord: D-175003 Sht 1/A-7, C-7, E-7, F-7 l System: Senice Water (P16)
' Category: C Class: 2 Function: SW To CTMT Coolers Check Valves.
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OM Code Test Disassemble cach check valve every refueling outage in accordance with ISTC 4.5.4(c).
l Requirements:
Basis for These check valves are located inside containment and are not equipped with any Relief: instrumentation that can be utilized to verify reverse flow closure quarterly, at cold shutdown or refueling outage. Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operability. No reliefis required for the above per OM ISTC 4.5.4(c) if r ach valve is disassembled every refueling outage.
These valves a.c the u.ne design (manufacturer, size, model number and material of construction) and havt the same service conditions including valve orientation, thus they meet the guidance ui' NRC Generic Letter 89-04, Position 2 for valve grouping for purposes of implementing a disassembly / inspection sampling plan. The burden justification for the proposed ahernate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection of all four valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past sixteen inspections of these valves (total both units) dating back to 1991 have detected only one case of restricted valve disc movement (Unit 2) due to mud and scale build up. All other inspections have been satisfactory. On average, the disassembly / inspection of these valves requires 9.5 man-hours. Additional costs associated with planning, scheduling, supenision, documentation, etc. are also required for this task.
Alternate The alternate testing described below is based on GL 89-04 guidance for valve grouping Testing: and check valve disassembly.
Two of these valves will be disassembled and manually full stroke exercised each refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded parts) and the disk will be manually exercised to verify full stroke capability, if either of the disassembled valves is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valves of the group will also be disassembled, inspected and manually full stroke exercised during the same outage. The valves will be part stroked with flow aller reassembly. The necessary valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring desices.
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FNP-1-M-094
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I RELIEF REQUEST t
QlP16-RR-V-3 J
Valve: QV0659, QV0660, QV0661 j Other Valve No: NA Drawing /Coord: D-170019 Sht. 3/C-3, C-8, C-10 System: Service Water (P16)
Category: C Class: 3 Function: Unit 1 Service Water Supply To DG 2C, IC,1-2A.
OM Code Test Disassemble cach check valve every refueling outage in accordance with ISTC 4.5.4(c).
Requirements:
1 Basis for There are no system design previsions to verify valve reverse flow clemre quarterly, at cold )
Relief: shutdown or refueling outage. Therefore, per ISTC 4.5.Q) Gvse valves will be I disassembled at refueling outages to verify operability. No reliefis required for the above !
per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
These valves are the same design (manufacturer, size (with exception stated below), model number and material of construction) and have the same senice conditions including valve orientation, thus they meet the guidance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes of implementing a disassembly / inspection sampling plan. Valve QV0661 is an 8 inch valve while the remaining valves in the group are 6 inch. Since these valves are identical in all other respects and are installed in the same system, the size difference is inconsequential. The burden justification for the proposed alternate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection of all three valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past nineteen inspections of these valves (total both units) dating back to 1984 have not detected any unsatisfactory conditions. On average, the disassembly / inspection of these valves requires 6 man-hours. Additional costs associated with planning, scheduling, supenision, documentation, etc. are also required for this task.
Alternate The alternate testing described below is based on GL 89-04 guidance for valve grouping Testing: and check valve disassembly.
One valve will be disassembled and manually full stroke exercised each refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded parts) and the disk will be manually exercised to verify full stroke capability, if the disassembled valve is not capable of being full stroke exercised or there is binding or )'
failure of valve internals, the remaining valves in the group will also be disassembled, inspected and mam Jy full stroke exercised during the same outage. The valve will be part stroked with flow aner reassembly. The necessary valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring desices.
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FNP-1 M-094 l
k RELIEF REQUEST QIP16-RR-V-4 j Valve: QV564, QV565 l 1
Other Valve No: NA l
' Drawing /Coord: D-170019 Sht.3/G-2 System: Service Water (P16)
Category: C Class: 3 Function: Unit 1 Diesel Generator Scnice Water Train Return Check Valves l
OM Code Test Disassemble each check valve every refueling outage in accordance with ISTC 4.5.4(c).
l Requirements:
l Basis for There are no system design provisions to verify valve full forward flow quarterly, at cold Relief: shutdown or refueling outage. Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operability. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
! These valves are the same design (manufacturer, size, model number and material of construction) and have the same service conditions including valve orientation, thus they meet the guidance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes ofimplementing a disassembly / inspection sampling plan. The burden justification for the proposed alternate testing sampling plan is detailed below.
The inspection histo:y of these v tives suggests there is no need for disassembly / inspection both valves each outage, thus any additional expense in doing so would be an unnecessary I burdcn. The past twelve inspctions of these valves (total both units) dating back to 1989 l have not detected any unsatisfactory conditions. On average, the disassembly / inspection of j these valves requires 13 man-hours. Additional costs associated with planning, scheduling,
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supervision, documentation, etc. are also required for this task. 1 Alternate The alternate testing described below is based on GL 89-04 guidance for valve grouping Testing: and check valve disassembly.
One valve will be disassembled and manually full stroke exercised each refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded puts) and the disk will be manually exercised to verify full stroke capability. If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valve in the group will alr.o be disassembled, inspected and manually full stroke exercised during the same outage. The valve will be part stroked with flow aAer reassembly. The necessary valve obturator movement, ,
verifying part stroke exercising, will tu confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring desices.
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. . FNP-1-M-094 RELIEF REQUEST QlE21-RR-V-1 Valve: Group 1 - QV032A, B, C Group 2 - QV037A, B, C Other Valve No: Group 1 - 8948A, B, C Group 2 - 8956A, B, C Drawing /Coord: Group 1 - D 175038 Sht. 2/D 2, D 2, E-2 Group 2 - D-175038 Sht. 2/D-3, D-6, D-8 System: SI/CVCS Category: AC Class: 1 Function: Accumulator Tank Discharge to RCS (CL) Check Valves.
OM Code Test Disassemble each check valve every refueling outage in accordance with ISTC 4.5.4(c).
Requirements:
Basis for The safety injection systern accumulator tanks are isolated from the RCS by these normally Relief: closed check valves. Each accumulator is charged with a nitrogen blanket from 600 to 650 psig. This pressure is insuflicient during operation to inject into the RCS. If these valves were to be full or part exercised at cold shutdown, the contents of the tank would be dumped into the RCS at the charge pressure of 600 to 650 psig which could result in overpressurization of the RHR suction lines resulting in lifting the RHR suction relief valves. Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operability. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
The valves within each group are the same design (manufacturer, size, model number and material of construction) and have the same senice conditions including valve orientation, thus they meet the guidance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes of implementing a disassembly / inspection sampling plan. The burden justification for the proposed alternate testing sampling plan is detailed below.
The irtspection history of these valves suggests tiere is no need for disassembly / inspection of each valve in each group every outage, thus any additional expense in doing so would be '
an unnecessary burden. ' The past 10 inspections of these valves (total both groups) dating back to 1989 have not detected any unsatisfactory conditions. On average, tie j
disassembly / inspection of these valves requires 22 man-hours. Additional costs associated i with planning, scheduling, supenision, documentation, etc. are also required for this task.
(continued on next page) i I
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r FNP-1-M-094
[ RELIEF REQUEST
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Q1E21-RR V-1 (continued)
Alternate Testing: One valve of each group will be disassembled and manually full stroke exercised each refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded parts) and the disk will be manually exercised to verify full stroke capability. If the disassembled valve is not capable of being full stroke exercised or l there is binding or failure of valve internals, the remaining valves in that group will also be l disassembled, inspected and manually full stroke exercised during the same outage. The l valve will be part stroked with flow aAct reassembly. The necessary valve obturator l movement, verifying part stroke exercising, will be conf;rmed by changes in system i pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measming devices. Alternately, full stroke exercising will be confirmed by use on non-intrusive check valve testing technology during l refueling.
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FNP-1-M 094 I
PUMP RELIEF REQUEST RR-P-5 System: Auxiliary Feedwater(N23) i Pump: P001A, B j
Class: 3 Drawing /Coord: D-175007/ B-5, E-5 Function: Provide auxiliary feedwater to the steam generators on loss of main feedwater. Proside feedwater to the steam generators during startup and shutdown.
Test Requirement: Quarterly measurement of pump flow rate per ISTB 5.1 and 5.2.
Basis f( r Relief: Sections ISTB 5.1 and 5.2 require quarterly pump testing to be performed by varying the system resistance until either the measured differential pressure or tle measured flow rate equals the corresponding reference value, or by using a fixed resistance test flow path.
Testing the auxiliary feedwater pumps by varying system resistance is not a practical method, because to do so would hiject cold water into the steam generators. The introduction of cold water into the hot steam generator would result in a large thermal shock and could result in nozzle cracking. Use of the minimum flow line restricts the test flow rate of these 350 gpm pumps to approximately 50 gpm. Consequently, flow rate measurements using the minimum flow path would not provide any useful information to monitor pump operability or degradation.
Alternate Testing: Differential pressure and vibration will be .Taoid quarterly. Pump flow rate, differential pressure, and vibration measurements will be taken at cold shutdown.
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ATTACllMENT II Unit 2 RELIEF REQUESTS I
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FNP-2-M-094 RELIEF REQUEST
, , Q2P16-RR-Y-2 Valve: QV206A, B, C, D Other Valve No: NA Drawing /Coord: D-205003 Sht 1/A-7, C-7, E-7, F 7 System: Senice Water (P16) ,
Category: C Class: 2 Function: SW To CfMT Coolers Check Valves.
OM Code Test Disassemble each check valve every refueling outage in accordance with ISTC 4.5.4(c).
Requirements:
Basis for These check valves are located inside containment and are not equipped with any Relief: instrumentation that can be utilized to verify reverse flow closure quanctly, at cold shutdown or refueling outage. Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operability. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
These valves are the same design (manufacturer, size, model number and material of construction) and have the same senice conditions including valve orientation, thus they meet the guidance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes of irnplementing a disassembly / inspection sampling plan. The burden justification for the proposed alternate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection of all four valves each outage, thus eny additional expense in doing so would be an unnecessary burden. The past sixteen inspections of these valves (total both units) dating back to 1991 have detected only one case of restricted valve disc movement (Unit 2) due to mud and scale build up. All other inspections have been satisfactory. On average, the disassembly / inspection of these valves requires 9.5 man-hours. Additional costs associated with planning, scheduling, supenision, documentation, etc. are also required for this task.
Alternate The alternate testing described below is based on GL 89-04 guidance for valve grouping Testing: and check valve disassembly.
Two of these valves will be disassembled and manually full stroke exercised each refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded parts) and the disk will be manually exercised to verify full stroke capability. If either of the disassembled valves is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valves of the group will also be disassembled, inspected and manually full stroke exercised during the same outage. The valves will be part stroked with flow aAcr reassembly. The necessary va've obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring desices.
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FNP-2-M-094 RELIEF REQUEST
, Q2P16-RR-V-3 Valve: QV0659, QV0660, QV0661 Other Valve No: NA Drawing /Coord: D-200013 Sht. 3/C-3, C 10, C-12 System: Service Water (P16)
Category: C Class: 3 Function: Unit 2 Scr, ice V*ater Supply To DG 2C,1C,12A, OM Code Test Disassemble cach check valve every refueling outage in accordance with ISTC 4.5.4(c).
Requirements:
Basis for There are no system design provisions to verify valve reverse flow closure quarterly, at cold Relief: shutdown or refueling outage. Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operability. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
These valves are the same design (manufacturer, size (with exception stated below), model number and material of construction) and have the sante senice conditions including valve orientation, thus they meet the guidance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes of implementing a disassembly / inspection sampling plan. Valve QV0661 is an 8 inch valve while the remaining valves in the group are 6 inch. Since these valves are identical in all other respects and are installed in the same system, the size difference is inconsequential. The burden justification for the proposed alternate testing sampling pisn is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection of all three valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past ninctcen inspections of these valves (total both units) dating back to 1984 have not detected any unsatisfactory conditions. On average, the disassembly / inspection of these valves requires 6 man-hours. Additional costs associated with planning, scheduling, supenision, documentation, etc. are also required for this task.
Alternate The alternate testing described below is based on GL 89-04 guidance for valve grouping Testing: and check valve disassembly.
, One valve will be disassembled and manually full stroke exercised cach refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded parts) and the disk will be manually exercised to verify full stroke capability. If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valves in the group will also be disassembled, inspected and manually full stroke exercised during the same outage. The valve will be part stroked with flow after reassembly. The necessaiy valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or through the use of l ultrasonic (or similar) flow measuring desices.
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FNP-2-M-094
, RELIEF REQUEST Q2P16-RR-V-4 Valve: QV564, QV565 Other Valve No: NA Drawing /Coord: D-200013 Sht.3/G-2 System: Service Water (P16)
Category: C Class: 3 Function: Unit 2 Diesel Generator Service Water Train Return Check Valves l
OM Code Test Disassemble cach check valve every refueling outage in accordance with ISTC 4.5.4(c). l Requirements:
Basis for There are no system design provisions to verify valve full forward flow quarterly, at cold Relief: shutdown or refueling outage. Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operability. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
These valves are the same design (manufacturer, size, model number and material of construction) and have the same service conditions including valve orientation, thus they meet the guidance of NRC Generic Letter 89-04, Position 2 for valve grouping for purposes ofimplementing a disassembly / inspection sampling plan. The burden justification for the proposed alternate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection both valves each outage, thus any additional expense in doing so would be an unnecessary burden. The past twelve inspections of these valves (total both units) dating back to 1989 have not detected any unsatisfactory conditions. On average, the disassembly / inspection of these valves requires 13 man-hours. Additional costs associated with planning, scheduling, supervision, documentation, etc. are also required for this task.
AltemateTesting: The alternate testing described below is based on GL 89-04 guidance for valve grouping and check valve disassembly.
One valve will be disassembled and manually full stroke exercised each refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded parts) and the disk will be manually exercised to verify full stroke capability. If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valve in the group will also be disassembled, inspected and manually full stroke exercised during the same outage. The valve will be part stroked with flow after reassembly. The necessary valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, scat leakage testing or other positive means or through the use of ultrasonic (or similar) flow measuring devices.
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FNP-2-M 094 RELIEF REQUEST Q2E21-RR-V-1 Valve: Group 1 - QV032A, B, C Group 2 - QV037A, B, C Other Valve No: Group 1 - 8948A, B, C Group 2 - 8956A B, C -
Drawing /Coord: Group 1 - D-205038 Sht. 2/D-2, D-2, E-2 Group 2 - D-205038 Sht. 2/D-3, D 6, D-8 System: SI/CVCS Category: AC Class: 1 Function: Accumulator tank discharge to RCS (CL) check valves.
OM Code Test Disassemble cach check valve every refueling outage in accordance with ISTC 4.5.4(c).
Requirements:
Basis for The safety injection system accumulator tanks are isolated from the RCS by these normally Relief: closed check valves. Each accumulator is charged with a nitrogen blanket from 600 to 650 ,
psig. This pressure is insufficient during operation to inject into the RCS. If these valves !
were to be full or part exercised at cold shutdown, the contents of the tank would be dumped into the RCS at the charge pressure of 600 to 650 psig which could result in overpressurization of the RHR suction lines resulting in liAing the RHR suction relief valves. Therefore, per ISTC 4.5.4(c) these valves will be disassembled at refueling outages to verify operability. No reliefis required for the above per OM ISTC 4.5.4(c) if each valve is disassembled every refueling outage.
The valves within each group are the same design (manufacturer, size, model number and ,
material of construction) and have the same service conditions including valve orientation, I thus they meet the guidance of NRC Generic Letter 89 04, Position 2 for valve grouping for purposes of implementing a disassembly / inspection sampling plan. The burden justification for the proposed alternate testing sampling plan is detailed below.
The inspection history of these valves suggests there is no need for disassembly / inspection of each valve in each group every outage, thus any additional expense in doing so would be an unnecessary burden. The past 10 insprxtions of these valves (total both groups) dating back to 1987 have not detected any unsatisfactory conditions. On average, the disassembly / inspection of these valves requires 20 man-hours. Additional costs associated with planning, scheduling, supervision, documentation, etc. are also required for this task.
(continued on next page)
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FNP-2-M 094 ,
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l RELIEF REQUEST l
, Q2E21-RR-V-1 (continued) i Alternate Testing: One valve of each group will be disassembled and manually full stroke exercised each refueling outage on a staggered basis. The valve internals will be verified to be structurally sound (no loose or corroded parts) and the disk will be manually exercised to verify full stroke capability. If the disassembled valve is not capable of being full stroke exercised or there is binding or failure of valve internals, the remaining valves in that group will also be disassembled, inspected and manually full stroke exercised during the same outage. Tlw valve will be part stroked with flow aAct reassembly. The necessary valve obturator movement, verifying part stroke exercising, will be confirmed by changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means or i through the use of ultrasonic (or similar) flow measuring devices. Alternately, full stroke exercising will be confirmed by use on non-intrusive check valve testing technology during refueling.
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FNP-2-M-094 l l
PUMP RELIEF REQUEST RR-P-5 1 System: Auxiliary Feedwater(N23)
Pump: P001A, B Class: 3 Drawlag/Coord: D-205007/ B-5, E-5 Function: Provide auxiliary feedwater to the steam generators on loss of main feedwater. Proside feedwater to the steam generators during startup and shutdown.
Test Requirement: Quarterly measurement of pump flow rate per ISTB 5.1 and 5.2.
Basis for Relief: Sections ISTB 5.1 and 5.2 require quarterly pump testirig to be perforned by varying the I system resistance until either the measured differential pressure or the measured flow rate equals the corresponding reference value, or by using a fixed resistance test flow path.
Testing the auxiliary feedwater pumps by varying system resistance is not a practical method, because to do so would inject cold water into the steam generators. The l
introduction of cold water into the hot steam genera'.or would result in a large thermal shock and could result in nozzle cracking. Use of the minimum flow line restricts the test flow rate of these 350 gpm pumps to approximately 50 gpm. Consequently, flow rate measurements using the minimum flow path would not provide any useful information to monitor pump operability or degradation.
Alternate Testing: Differential pressure and vibration will be av:asured quarterly. Pump flow rate, differential pressure and vibration measurements will be taken at cold shutdown.
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