ML20234D049
| ML20234D049 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/28/1987 |
| From: | Whittier G Maine Yankee |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GDW-87-294, MN-87-142, NUDOCS 8801060424 | |
| Download: ML20234D049 (5) | |
Text
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MaineYankee RELIABLE ELECTRICITY FOR MAINE SINCE 1972 EDISON DRIVE. AUGUSTA, MAINE 04330. (207) 622 4868 December 28, 1987 l10CFR50.55al MN-87-142 GDH-87-294 l
l United States Nuclear Pegulatory Commission Attention:
Document Control Desk Hashington, D. C.
20555 1
References:
(a) License No. DPR-36 (Docket No. 50-309) 1 (b) MYAPCo Letter to USNRC dated August 8, 1983 (MN-83-165) -
1 Maine Yankee Inservice Testing Program j
l
Subject:
Inservice Testing Program
]
Gentlemen:
I l
In accordance with the provisions of 10 CFR 50.55a(g), Maine Yankee 'has 1
determined that certain tests required by the 1980 ASME Code,Section XI, are l
impractical. Accordingly, requests for relief from the code requirements and the basis for the relief are attached.
Please contact us if you have any questions.
Very truly yours, MAINE YANKEE khAY G. D. Whittier, Manager Nuclear Engineering and Licensing GDH/bjp l
Attachment cc: Mr. Richard H. Hessman Mr. Hilliam T. Russell Mr. Pat Sears Mr. Cornelius F. Holden BBRR88MF#ojige MC G
Ifl 9437L-SDE I
MaineYankee VALVE RELIEF REQUEST CR-24 NUMBER: V-41 4
SYSTEM: Chemical and Volume Control a
VALVE: CH-40 DRAWING N0:
FM-31A/91A CATEGORY: C CLASS: 2 FUNCTION: Containment Isolation Check Valve EXEMPT TEST:
Q, Qp, C, Cp, L BASIS FOR RELIEF:
This valve must be open durlog normal plant operation and cold shutdowns to provide volume control to the-reactor ccolant system.
Exercising of this valve must be done during refueling outages when.the system is not required to operate.
Testing this valve may be done by either providing reverse flow to the valve and by measuring leakage past the seat, or by disassembling the valve and ensuring that the disc is free to move.
Because of the physical arrangement of the system, the reverse flow test is impractical.
The only place to.
provide reverse flow to this check valve is through the vent of the regenerative heat exchanger.
This vent valve is located in a very high radiation area, i.e.
10R/Hr.
Performing this. test would result in high levels of radiation exposure.. Maine Yankee deems it more practical to disassemble this check valve and physically verify that the valve operates freely.
This would reduce radiation exposure and provide a better idea of the reliability of this valve.
This valve is exempt from.10CRF 50 App. J testing.
Reference NRC letter to Maine Yankee dated' Hay 23, 1986.
ALTERNATE TEST:
(D) This valve will be disassembled and exercised every refueling outage.
MaineYankee VALVE RELIEF REQUEST CR-24 NUMBER: V-64
- SYSTEM: Auxiliary Feedwater VALVE:
EFW-39, EFH-40 DRAWING N0:
FM-12A/73A CATEGORY: C CLASS: 2 FUNCTION:
Emergency Feedwater to Auxiliary Feedwater isolation checks EXEMPT TEST:
Q, C, Qp, Cp, R BASIS FOR RELIEF:
Testing these valves while at power would require pressurizing the common Auxiliary Feedwater discharge header and measuring any leakage by the valves. One method of pressurizing this header would be by running 3
an Emergency Feedwater pump in its normal operating mode.
This, however, would inject cold Auxiliary Feedwater into the steam generators causing a thermal j
shock and possible damage.
To avoid injecting cold I
water into the steam generators, the three Emerg. Feed.
I trip' valves could be closed.
Closing these valves would completely isolate both trains of emergency feedwater from the steam generators'.
This would violate the Tech.
Spec. requirement for automatic alignment capabilities of Emergency Feed to the steam generators.
Another method of pressurizing this header.would be by l
using the primary water system.
This would provide a pressure of approximately 170 psig to the header and i
would not inject cold water into the steam generators which are at approximately 800 psig.
This,.however, entails connecting nonseismic, non nuclear safety class.
equipment to the Emergency Feedwater. System.
If in the unlikely event of an earthquake, this non seismic test equipment may fail and both emergency feedwater trains would be impaired.
The amount of leakage that would occur exceeds that allowed in the safety analysis.
Testing these valves requires isolating the steam driven auxiliary feedwater pump.
This pump is required to be operable in the event of loss of AC power to provide feedwater to the steam generators ~.
There is a proposed Tech. Spec. and Appendix "R" requirement stating =that-this pump shall be operable during normal plant operation, if not, remedial action is' required.
...m
MaineYankee CR-24 1
V-64 (Cont'd) l i
BASIS FOR RELIEF:
Since these two check valves are installed adjacent to each other, reverse flow tests would only verify that j
one valve is' performing its~ function. One valve could be stuck wide open and it would go undetected.
6 Testing these valves with. primary water requires running a hose outside and leaving an alarmed door open.
This
-could cause freezing problems in the winter.
This test will require at least five people, three of which would be plant operators.
It is undesirable to-pull three operators away from there normal. duties to perform a surveillance of this type.
These valves were disassembled and. inspected after thirteen years of service and were found to be in-perfect operating condition.
For the reasons.above, Maine Yankee fee's'it impractical I
to test these valves on a quarterly basis as required by ASME XI.
4 ALTERNATE TEST: (D)
Alternately, one valve will be disassembled and exercised every refueling outage.
If a-degraded condition is found, the other valve shall be disassembled and exercised.
This method will ensure that each valve is operating satisfactorily.
1 i
l 1
MaineYankee VALVE RELIEF REQUEST 3
i CR-24 j
,l NUMBER: V-65 i
SYSTEM:
Primary Component Coolant-l VALVE:
PCC-245, PCC-261, and PCC-280
.l DRAWING NO:
FM-34C/94C I
CATEGORY:
A,. C CLASS: 2 FUNCTION: Containment Isolation EXEMPT TES1:
Q, Qp, C, Cp BASIS FOR RELIEF:
These valves must be in their open position during normal plant operation and cold shutdowns to provide coolant to equipment inside containment. -. Testing these valves would mean isolating coolant to many.important components, such as, the Reactor Coolant Pumps, HP Drain Cooler, Neutron Shield Tank Coolers, CEDM Air Coolers, and the Pressurizer Quench Tank Cooler.
ALTERNATE TEST:
(L) These valves will be exercised to the closed position and verified closed during their Appendix J leakage tests each refueling outage, u____ _ _: _