ML20248B409
| ML20248B409 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/29/1989 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-89-04, GL-89-4, NUDOCS 8910030189 | |
| Download: ML20248B409 (32) | |
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@MERCH Consumers P0W8f x
in w s.,ry Director Nuclear iJceming AMN0GAN5 NEDGRESS General OfSces: 1946 West Pernett Road, Jackson, MI 49201 e (517) 788-1636 September 29, 1989 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
GUIDANCE ON DEVELOPING ACCEPTABLE INSERVICE TESTING PROGRAMS - RESPONSE TO GENERIC LETTER 89-04 Nuclear Regulatory Commission Generic Letter 89-04, Guidance on Developing Acceptable Inservice Testing Programs, dated April 3, 1989, approved all pump and valve Inservice Test'ag Programs and associated relief requests which were being reviewed by the NRC staff at the time Generic Letter 89-04 was issued.
The approval was granted under the provision that licensees would review their most recently submitted IST Programs and implementation procedures against the NRC positions delineated in Attachment I of the Generic Letter and confirm in writing to the NRC conformance with the stated positions. This submittal confirms Big Rock Point Plant commitment to conform with the Generic Letter 89-04 positions.
A detailed review of Big Rock Point Plant's Inservice _ Testing Program has been performed to ensure compliance with NRC Generic Letter 89-04.
The following changes are being made to the IST program in accordance with the positions stated in GL 89-04:
1.
The relief request for pump flow measurement has been withdrawn and Big Rock Point will install flow meters for the fire pumps and:the core spray pumps during the 1990 refueling outage.
This will allow for flow
'l measurement as required by ASME Eection XI IWP-4600. The installation of these flow meters will also provide assurance of full flow testing of check valves VPI-300, VPI-301, VPI-302, VPI-306 and VPI-307 as required by j
l to GL 89-04.
l 2.
The relief request for scram valves (CV-NC09 and CV-NC10) will be changed to reflect testing of these valves in accordance with Position 7 of j
Attachment I to GL 89-04.
f 3.
A procedure shall be writt,+s to test the demineralized inlet-check valve VMU-300 with full accident flow, i
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8910030189 890929 i
PDR ADOCK 0500015,5 A C4tS ENE7?GYCOMPANY j
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Nuclear Regulatory Commission 2
j Big Rock Point Plant
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ResponFe to GL 89-04 September 29, 1989 1
4.
Liquid poison check valve VP-300 shall be disassembled and inspected each j
refueling outage in accordance with Position 2 of Attachment 1 to GL 89-04.
5.
A relief request has been added to indicate that the reactor depressurizing valves (SV-4984 SV-4985, SV-4986 and SV-4987) shall be timed in accordance j
with Position 6 of Attachment I to GL 89-04.
6.
The limiting stroke time values for CV-4094, CV-4095, CV-4096, CV-NC11, CV-NC11A, CV-NC12, CV-NC12A, MO-7053 and MO-7063 shall be changed in l
accordance with Position 5 of Attachment I to GL 89-04.
It is believed that these changes to the Pig Rock Point Plant's IST program will bring the program into compliance with the requirements of GL 89-04.
Attached is a complete file of Big Rock Point's relief requests as revised in accordance with the above and supersedes our previous relief request submittals of June 24, 1988 and July 5, 1988. All of the changes made as a result of this review are itemized in the attachment.
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Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC URC Resident Inspector - Big Rock Point Attachment OC0989-00ll-NLO2
4 ATTACHMENT Consumers Power Company Big Rock Point Plant Docket 50-155 BIG ROCK POINT INSERVICE TESTING PROGRAM RELIEF REQUEST GENERIC LETTER 89-04 September 29, 1989 l
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29 Pages OC0989-0011-NLO2
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INSERVICE TESTING PROGRAM RELIEF REQUESTS j
The following is a complete listing of the current relief requests applicable to Big Rock Point's IST Program and includes changes that have been made since our June 24, 1988 submittal.
Core Spray Pumps Relief Request unchangad from 1988 submittal.
Electric and Diesel Fire Pump Test Frequency l
Relief Request unchanged from 1988 submittal.
j Core Spray Pumps, Electric Fire Pump and Diesel Driven Fire Pump Bearing Temperature Measurement Relief Request unchanged from 1988 submittal.
Control Rod Drive (VCRD-301 and VCRD-311)
Relief Request unchanged from 1988 submittal. Valve description changed to reflect correct bound ules.
Emergency Condenser (MO-7052, MO-7053, MO-7062 and MO-7063)
Relief Request unchanged from 1988 sec.ittal.
Containment Isolation Valves CV-4091, CV-4092, and CV-4093 Relief Request unchanged from 1988 submittal.
Liquid Poison System (CV-4020)
Relief Request unchanged from 1988 submittal.
j Liquid Poison System (VP-300)
Added requirement to disassemble and inspect each reactor shutdown for refueling.
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Shutdor Cooling System (MO-7056, MO-7057, MO-7058 and MO-7059) l Relief Request unchanged from 1988 submittal.
Treated Waste Return (CV-4049) and VRW-313)
Relief Request unchanged from 1988 submittal.
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Demineralized Water Supply (VMU-300)
Relief Request unchanged from 1988 submittal.
I Liquid Poison System (CV-4050) 1 Relief Request unchanged from 1988 submittal.
Liquid Poison Supply to Reactor Vessel (VP-301 & VP-302)
Relief request unchanged from 1988 submittal.
Main Steam Line Drain Isolation Valve (MO-7065)
Relief Request unchanged from 1988 submittal.
j Feedwater (VFW-304 & VFW-9)
Relief Request unchanged from 1988 submittal.
Feedwater (VFW-305)
Relief Request unchanged from 1988 submittal.
I Control Rod Drive (CVNC09's & CVNC10's)
Changed Relief Request to reflect testing in accordance with Technical Specification requirements.
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Enclosure Spray System (MO-7064 & MO-7068)
Relief Request unchanged from 1988 submittal.
Core Spray System (VPI-300, VPI-306, VPI-307)
Relief Request unchanged from 1988 submittal.
Core Spray System (VPI-303 & VPI-304) l Relief Request unchanged from 1988 submittal.
1 Core Spray Sytem (VPI-301 & VPI-302) l Relief Request unchanged from 1988 submittal.
Core Spray System (MO-7072)
Relief Request unchanged from 1988 submittal.
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l Core Spray System (MO-7071) l-Relief Request unchanged from 1988 submittal.
i Reactor Depressurization System (SV-4984_- SV-4987) i Relief Request on valve testing frequency unchanged from July 5, 1988 submittal (Relief request previously approved by NRC letter dated November 4, j
1988). Added Relief request to assign a maximum stroke time limit..
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RELIEF REQUEST l
Item:
Relief request for Core Spray Pumps Test Requirement: Monthly during plant operation and within one week after plant startup if not tested during the shutdown.
Basis for Relief: These pumps are part of the Emergency Core Cooling System.
Testing during power operations would require a valve lineup which would preclude their performing their required-function after a loss of coolant accident (LOCA). In the event of a LOCA, areas which must be entered to change this valve Ifneup would be untenable.
In addition, testing during power operation would require personnel entry into the very high radiation area directly beneath the reactor vessel.
Alternative Testing: Once per reactor cold shutdown and each refueling (but not more frequently than once every three months).
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RELIEF REQUEST Item:
Relief request for Electric and Diesel Driven Fire Pump Test Frequency.
Test Requirement: Monthly during plant operation and within one week after plant startup if not tested during the shutdown.
Basis for Relief: These fire pumps must be tested on a monthly basis as required by ASME Section XI IWP testing. To perform the test would require fire water flow through the shell side of the core spray heat exchanger. This fire water is then discharged back to the lake.
This flow test, which is the only valid test, will reduce-the flow available to the ECC to below that calculated as j
necessary. Thus, to prevent degradation of the Emergency Core Cooling System, relief is requested to allow testing each reactor shutdown. The granting of this relief request will insure there will be adequate flow available to the Emergency Core Cooling System.
This relief request will also apply to the fire pump discharge check valves, VFP-304 cnd VFP-309.
Alternative Testing: Once per reactor cold shutdown and each refueling (but not more frequently than once every three months)..
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RELIEF REQUEST 1
Item:
Relief request for Core Spray Pumps, Electric Fire Pump and the Diesel Driven Fire Pump Bearing Temperature Measurement i
Test Requirement: Measure pump bearing temperature Basis for Relief: The bearings in these pumps are cooled and lubricated by the water being pumped. Due to water temperature variations and bearing inaccessibility, there is no method that will establish a meaningful bearing reference temperature.
Alternative Testing: None, the other pump parameters will be used:for determination of pump condition.
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RELIEF REQUEST System: Control Rod Drive (Print M-106)
Valve: VCRD-310 and VCRD-311 Category: A/C ASME Class: 2 Function: To prevent backflow from containment through the CRD-supply line.
Test Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.
I Basis for Relief: The closing function cannot be verified except during times of local leak rate testing which is performed each I
reactor shutdown for refueling per 10CFR50, Appendix J.
Alternative Testing: Local leak rate test each reactor shutdown for refueling.
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RELIEF REQUEST System: Emergency Condenser (Print M-107)
Valve: M0-7052, M0-7053, MO-7062, MO-7063 Category: B ASME Class:
1 Function: Emergency Condenser Inlet and Discharge Isolation Valves Test Requirement: Exercise valves for operability every three months.
Basis for Relief: The exercising of these valves at power would admit steam to the emergency condenser. This action would cause unnecessary thermal stresses in the tube bundles. The l
proposed alternate testing will minimize thermal cycles.
l Alternative Testing: Once each cold shutdown (but not more frequently than once every three months) or when one loop becomes isolated.
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RELIEF REQUEST System: Containment Isolation Valves (Prints M-107, M-108) l l
Valve: CV-4091, CV-4092, CV-4093-Category: A ASME Class:
1 for CV-4092, CV-4093' 2 for CV-4091 Function: To isolate containment Test Requirement:
Exercise valves every three months.
Basis for Relief: These valves are interlocked and cannot be opened at a system pressure above 100 psig and therefore they can't be exercised at power. These valves are normally in their-required position to perform their containment isolation function.
Alternative Testing: Exercise valves each cold shutdown (but not more frequently than once every three months).
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RELIEF REQUEST System: Liquid Poison System (Print M-107)
Valve: CV-4020 Category: B ASME Class:
1 Function: Liquid poison tank discharge isolation valve Test Requirement: Exercise valve for operability every three months.
Basis for Relief: Closing this ' valve prevents injection of liquid poison and d
prevents system from being available for operation as required by Technical Specifications. Testing can only occur during cold shutdown.
Alternative Testing: Exercise valve each cold shutdown (but not more frequently than once every three months).
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q 11 RELIEF REQUEST System: Liquid Poison System (Priat M-107).
Valve: Check Valve VP-300 Category: C ASME Class:
1 Func ?. ion : Once system is actuated, check' valve prevents nitrogen from escaping to the steam drum while establishing a siphon.
Test Requirement: Exercise valve for operability every three weeks.
Basis for Relief: The. valve has no operator. In addition, pressure cannot be applied to test valve operation without breaching primary boundary.
Alternative Testing: Exercise valves each cold shutdown (but not more frequently than once every three months). Also, disassemble and inspect each reactor shutdown for refueling.
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RELIEF REQUEST System: Shutdown Cooling System (Print M-107)
Valve: M0-7056, M0-7057, MD-7058, MO-7059 Category: A 1
ASME Class: 1 Function: Shutdown cooling system inlet and discharge isolation valves Test Requirement: Exercise valves for operability every three months.
Basis for Relief: Exercising these valves while the reactor is at operating pressure would overpressurize the shutdown cooling system (design pressure 300 psig).
In addition, amendment 28 to the Technical Specifications require opening of the valve breakers at system pressure greater than 300 psig.
Alternative Testing: Exercise valves each cold shutdown (but not more frequently than once every three months).
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13-RELIEF REQUEST.
System: Treated Waste Return (Print M-108)
' Valve: Isolation Valve CV-4049 and Check Valve VRW-313 Category: A & A/C ASME Class: 2 Function: To isolate containment Test Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.
Basis for Relief: The valves are' passive valves that are in,the position that will perform their intended function.
Thus,. exercising will not provide any additional margin of safety.
Alternative Testing: Local leak rate test at each reactor shutdown for refueling.
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.R 14 RELIEF REQUEST System: Demineralized Water Supply (Print M-110)
Valve: Inlet Check Valve (VMU-300)
Category: A/C' ASME-Class: 2 Function: To isolate containment
-Test Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.
Basis for Kelief: There is no means to verify closure of the check valve except during a local leak rate test. Thus, the local leak rate test will be the only means of testing.
Alternative Testing: Local leak rate test at each reactor shutdown for refueling.
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15 RELIEF REQUEST System: Liquid Poison System (Print M-121).
Valve: CV-4050 Category: B ASME Class:
1 Function:
Isolate flow of liquid poison to recirculation pump suction-Test Requirement: Exercise valve for operability every three months.
Basis for Relief: An interlock opens this valve automatically when either recirculating pump is in service. Thus, exercising this valve requires taking both recirculating pumps out of service.
Alternative Testing: Exercise valve and verify position indication once during any shutdown in which both recirculation pumps are secured, or as a minimum, each reactor shutdown for refueling.
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16 RELIEF REQUEST System: Liquid Poison Supply to Reactor Vessel (Print M-121)
Valve: Check Valve in liquid poison supply line to reactor vessel (VP-302) and Check Valve in liquid poison supply line to recirculating pumps (VP-301).
Category: C ASME Class:
1 Function: To prevent reactor water backflow through liquid poison line.
Test Requirement: Exercise valve for operability every three months.
Basis for Relief: The check valves have no operators. Exercising these valves by initiating flow in the system would introduce liquid poison into the reactor during operation or shutdown.
Alternative Testing: Visually inspect valves.each reactor shutdown for refueling by removing valve internals.
Discussion:
The liquid poison check valves are a Chapman Type V tilting disc check valve which has a three piece body construction. The seat ring, disc and pivot pins are located in the center section which is secured between two flanges with twelve studs.
This type of check valve construction lends itself to ease of disassembly, inspection and reassembly and the check valves are isolable from the reactor vessel.
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RELIEF REQUEST System: Main Steam Line Drain Isolation Valve (Print M-121)
Valve: MO-7065 Category: A ASME Class:
1 Function: To isolate main steam line drain to condenser Test Requirement:
Exercise valve for operability every three months and leak l
test each reactor shutdown for refueling.
Basis for Relief: The valve is electrically disabled in the closed position l
and does not have to change position to perform its intended function; thus, no exercising of the valve will be performed.
Alternative Testing: Note leakage rate through the valve during each NSSS hydrostatic test associated with a reactor shutdown for refueling.
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18 RELIEF REQUEST System: Feedwater Valve: Feedwater Check Valve VFW-304; and Feedwater Stop Check Valve VFW-9; Plug Type 1
Category: C ASME Class:
1 Function: Primary coolant pressure boundary Test Requirement: ASME Section XI 1977, summer 1978 addendum IWV-3520 - Valve exercising ia not possible during power operation, therefore full stroke test during cold shutdowns is required. Testing at every shutdown if intervals are 2 3 months or if testing has been completed within the last 3 months testing is not required. Valve disk movement shall be determined by an appropriate indicator.
Alternate Testing: Close valve VFW-9 via hand wheel during each refueling outage.
Basis for Relief:
The valves cannot be exercised during power operation because feedwater flow cannot be interrupted during this time. The valves each close when feedwater flow is stopped.
Valve disk movement to the closed position for VFW-304 cannot be determined as there are no direct or indirect indications available to make the determination. Valve disk l
movement to the closed position for VFW-9 can be determined by turning the valve stem into the seat. VFW-9 is a stop I
check valve equipped with a hand wheel and stem which can be turned into the valve disk. The stem and disk are not connected however, so raising the stem will not raise the disk.
1 The determination of both VFW-304 and VFW-9 being open is made by verifying proper feedwater flow exists when return-ing the system to service after shutdown.
1 The frcquency interval, for closing the valve VFW-9, of each i
refueling outage is requested due to the high radiation area that exists in the vicinity of the valve.
It requires two operators, in an approximate 350 to 500 mr/hr and return it to the full open position. The accumulated exposure for one exercise operation amounts to 0.7 to 1 man-rem.
Consumers Power Company's position is that the benefit derived from exercising the valve stem would be minimal from a valve reliability standpoint and would not off-set the OC0989-0011-NLO2
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additional radiation exposure involved. Because this area is frequented often during a refueling outage, the exercis-ing of the valve stem to verify valve closure during a refueling outage can be more easily justified.
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3 20 RELIEF REQUEST System: Feedwater Valve: Feedwater Check Valve VFW-305; Swing Type Category: A/C ASME Class: 2 Function: Containment isolation valve Test Requirement: ASME Section XI 1977, summer 1978 addendum IWV-3410 - Valve exercising is not possible during power operation, therefore full stroke test during cold shutdowns is required. Testing at every shutdown if intervals are 2 3 months or if testing has been completed within the last 3 months testing is not required. Valve disk movement shall be determined by an appropriate indicator.
IVW-3420 - Valves shall be leak tested every two years.
IVW-3520 - Valve exercising per category C requirements are met by fulfilling requirements of category A IWV-3410 requirements.
Alternate Testing: Perform a 10CFR50 Appendix J 1eak rate test during each refueling.
l Basis for Relief: The valves cannot be exercised during power operation because feedwater flow cannot be interrupted during this time. The check valve seats (closes) when feedwater flow is l
stopped. Valve disk movement to the closed pocition cannot be determined as there are no direct or indirect indications available to make the determination. Disk movement to the open position is only possible when feedwater flow is-initiated. Indication of feedwater flow provides the required indication the valve is open. Valve exercise testing therefore cannot be accomplished except to verify the valve is open by indication of proper feedwater flow.
l As a containment isolation valve the valve will be leak rate tested each refueling outage in accordance with 10CFR50 Appendix J requirements.
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RELIEF REQUEST System: Control Rod Drive (Print M-122)
Valve: Scram Inlet (CVNC09) and Outlet (CVNC10) Isolation Valves (32 sets of 2 valves)
Category: B ASME Class: 2 Function: To cause a control rod drive to insert rapidly Test Requirement: Exercise valve for operability every three months.
Basis for Relief: Exercising these valves would cause the associated control rod to scram.
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Alternative Testing: Exercise valves in accordance with Technical l
Specifications requirements (this is in accordance with
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22 RELIEF REQUEST System: Enclosure Spray System (Print M-123)
Valve: MO-7064, MO-7068 Category: B ASME Class: 2 Function: Enclosure spray isolation valves Test Requirement: Exercise valve for operability every three months.
Basis for Relief: Exercising these valves during power operation would result in spraying watt on energized electrical equipment inside containment.
MO-7064 and MO-7068 cannot be exercised during cold shutdowns because the fire system header must be taken out of service and drained to allow the exercising of the valves. This will pose an unwarranted fire hazard if the fire system is not available in the containment. Testing during each reactor shutdown for refueling presents a more acceptable risk as far as fire suppression capabilities in the containment.
Alternative Testing:. Exercise valves each reactor shutdown for. refueling.
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23 RELIEF REQUEST System: Core Spray System (Print M-123)
Valve: Core Spray Pump Discharge Check Valves (VPI-306, VPI-307) and Core Spray Test Tank Inlet Check Valve (VPI-300)
Category: C ASME Class: 3 Function: To prevent backflow in the Core Spray System Test Requirement: Exercise valve fer operability every three months.
Basis for Relief: The valves have no operators. They cannot be exercised by initiating flow in the system during power operation because the core spray pumps cannot be operated for test during power operations.
Alternative Testing: Once each reactor cold shutdown and each refueling -(but not more frequently than once every three months).
(See Core Spray Pump Relief' Request. These valves can only be tested when the pump is tested.)
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RELIEF REQUEST System: Core Spray System (Print M-123)
Valve: Primary Check Valves (VPI-303 and VPI-304)
Category: A/C ASME Class: 1 Function: Primary check valves in the core spray lines to prevent reactor pressure from pressurizing lines if the isolation valves were opened.
Test Requirement: Exercise valve for operability every three months.
Basis for Relief: The primary check valves have no operators. The valves cannot be opened against operating reactor pressure by initiating flow through these lines, because core spray system pressure is much less than operating reactor-pressure. During shutdown, the initiation of flow through these lines would introduce non-reactor grade water into the core. The only means to insure proper valve operation is to disassemble and inspect the valve during each reactor shutdown for refueling. There exists no method to insure disc movement torque requirements are met.
The. valve will be inspected and verified that the disc is free to move.
Alternative Testing: Disassemble and inspect each reactor shutdown for refueling.
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i RELIEF REQUEST l
System: Core Spray System (Print M-123) l
.I Valve: Secondary Check Valves.(VPI-301 and VPI-302)
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Category: C ASME Class:
1 Function: To prevent water backflow from the reactor to the Fire Water System.
Test Requirement: Exercise valve for operability every three months.
Basis for Relief: The secondary check valves have no operators. Testing of the valves will take the core spray system out of service.
Thus a flow test will be performed by allowing the fire water to enter the service water system and then be discharged to the canal.
(Note that proper sampling and analysis of the fire water will be performed to insure no uncontrolled release.) This flow testing vill be scheduled each reactor cold shutdown (but not more frequently than three mo ths).
Alternative Testing: Flow test the check valves each reactor cold shutdown (but not more frequently than once every three months).
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26 RELIEF REQUEST System: Core Spray System Valve: M0-7072 i
i Category: B ASME Class: 2
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Function: To provide a third path of fire water to the containment Test Requirement: Exercise quarterly Basis for Relief: Exercising this valve will introduce fire water into the inhibited water of the core spray pump piping. Exercising during each shutdown will minimize the amount of fire water that enters the core spray pump piping.
Alternative Testing:
Each reactor cold shutdown but not more frequently than once every three months.
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RELIEF REQUEST 1
i System: Back-up Core Spray Valve: M0-7071
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Function: Isolation valve between primary system and core spray system.
l Test Requirement: Local leak rate test each reactor shutdown for refueling.
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1 Basis for Relief: The back-up core spray system has three valves in series
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MO-7070, VPI-303 and MO-7071 which perform as isolation I
valves between the lower pressure core spray system (150 psig) and the primary coolant system (1335 psig). There.is a telltale located between MO-7070 and VPI-303 which would indicate leakage past VPI-303 and MO-7071.
MO-7070 and MO-7071 are full stroked every month during
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plant operation. During this test the operat.or is cautioned l
to ensure that core spray pressure does not increase above l
170 psig which would indicate leakage through the valves.
When MD-7070 is stroked the flow through the telltale is checked and when MO-7071 is stroked check valve VPI-303 is checked to show that it is adequately seated. By having these three valves in series and performing the montly stroke testing of MO-7070 and MO-7071 there is adequate insurance that there is proper isolation between the two systems.
Alternative Testing: None i
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28 RELIEF REQUEST System: Reactor Depressurization System (Print A-203) i Valve: SV-4984, SV-4985, SV-4986 and SV-4987 Category: B ASME Class:
1 Function: Depressurizing Valve Test Requirement: Exercise valve for operability every three months.
Basis for Relief: ~ The valve cannot be full stroke exercised unless continuous primary system pressure is applied. With the isolation valve closed, pressure in the spool piece between the isolation valve and the depressurizing valve is relieved before the depressurizing valve reaches the full stroked q
position. With the isolation valve open a continuous steam blowdown of the primary system into containment would i
result. Partial stroke axercising of the valve has been demonstrated to be a significant contributor to chronic pilot valve seat leakage.
Alternative Testing: Full stroke exercise the depressurizing valve each.
refueling outage, but not to exceed eighteen months.
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- 4' 29 RELIEF REQUEST System: ' Reactor Depressurization System (Print A-203)
Valve: SV-4984, SV-4985, SV-4986 &'SV-4987 Category: B ASME Class:.1 Function: Depressurizing Valve Test Requirement: Time power operated valves in accordance with IWV-3413 Basis for Relief: The reactor depressurizing valves are Target Rock solenoid valves which stroke in less than one second. In accordance with Position 6 of Attachment 1 of NRC Generie Letter 89-04, variations in stroke times for this type of fast acting valve is not a meaningful measurement of valve degradation.
Alternative Testing: These valves shall be assigned a maximum stroke time limit of 2 seconds.
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