ML21011A082

Pre-Submittal Meeting January 12, 2021, Revision to VRR-01, Full Stroke Testing of Safety/Relief Valves - Presentation Material

ML21011A082
Person / Time
Site:	Brunswick
Issue date:	01/12/2021
From:	Duke Energy Progress
To:	Andrew Hon NRC/NRR/DORL/LPL2-2
Hon A
References
EPID L-2021-LRM-0006
Download: ML21011A082 (5)

Text

Duke Energy Pre-Submittal Meeting - January 12, 2021 Revision to VRR-01, Full Stroke Testing of Safety/Relief Valves

Revision to VRR-01, Full Stroke Testing of Safety/Relief Valves Participants Art Zaremba, Fleet Licensing Manager Mike Fiorino, BNP Director Nuclear Engineering Sam Melton, BNP Lead Nuclear Engineer Ryan Miller, BNP Senior Nuclear Engineer Mark Turkal, Fleet Lead Nuclear Engineer Key Goals Brief NRC on Dukes proposed revision to VRR-01.

Ensure common understanding of issue.

Obtain NRC feedback prior to formal submittal.

Discuss precedent Timing of submittal 2

Revision to VRR-01, Full Stroke Testing of Safety/Relief Valves

Background

On June 16, 2017, the NRC approved Relief Request VRR-01 for the Fifth 10-Year IST program interval at Brunswick Units 1 and 2. (ML17129A507)

• Pursuant to 10 CFR 50.55a(z)(1), VRR-01 requested a proposed alternative from stroke time requirements of the ASME OM Code for Safety/Relief Valves (SRVs). The proposed alternative provides an acceptable level of quality and safety.

• In lieu of stroke time testing, the SRVs were to be exercised open and closed, and proper operation ascertained by observing the response and changes in main steam parameters within a specified time period and observation of the outputs of the downstream temperature and acoustic sensors. Specific as-found stroke times, visual inspections, set pressure and leakage testing were to be measured by the vendor.

• VRR-01 conforms to the recommendations presented in NUREG-1482, Revision 2, Guidelines for Inservice Testing at Nuclear Power Plants On January 8, 2020, the NRC approved Amendments 297 and 325 to the Brunswick Unit 1 and 2 Technical Specifications, respectively. (ML19316B057)

• These amendments revised SR 3.4.3.2 and SR 3.5.1.11 to require verification that each SRV/Automatic Depressurization System (ADS) valve is capable of being opened.

• Two methods of performing the SRs were described. Method 1 involves overlap testing and is intended to eliminate the need for manual actuation of the SRVs during plant operation to satisfy the SRs. Method 2 consists of the manual SRV actuation as had traditionally been performed to satisfy SRs 3.4.3.2 and 3.5.1.11.

A revision to VRR-01 is needed in order to take full advantage of Amendments 297 and 325.

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Revision to VRR-01, Full Stroke Testing of Safety/Relief Valves Proposed Revision to VRR-01 Expand the relief request SRVs are capable of being opened in lieu of verifying the SRVs will open when manually actuated. Relief is necessary from code requirements for both full stroke exercise and stroke time testing to be performed at least every outage. The previously approved VRR-01 addressed only stroke time testing requirements and identified outage valve stroking in its basis. For completeness, this relief request also captures the previously approved extension of main body testing from 5 years to 6 years per Code Case OMN-17.

Proposed Alternative The SRV main bodies will be removed at intervals of six years and tested at a vendor test facility for as-found testing in accordance with Appendix I Section I-3310. This as-found testing will include full stroke exercising and stroke time testing. After refurbishment, the main valve bodies will be certified for full stroke exercising, stroke time, and leak tightness. Prior to installation, the main bodies will be visually inspected. The main body joint will be inspected as part of the ISI pressure test prior to startup.

The SRV pilot valves for all SRVs will be removed each outage and tested in accordance with I-3310 at a vendor test facility for as-found testing. After refurbishment, the pilot valves will be tested in accordance with I-3310. Prior to installation, the pilot valves will be visually inspected.

Satisfactory performance of solenoid operation and pneumatic connections will be demonstrated by bench test or in-situ test.

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Revision to VRR-01, Full Stroke Testing of Safety/Relief Valves Justification The certification of both main body and pilot valves ensures the capability for full stroke exercising. The cumulative testing described above to comply with I-3410 requirements will test all aspects of the valve design that support the ability to open without requiring the use of reactor steam to operate the main disc, which could lead to seat leakage.

The same justification provided in support of Amendments 297 and 325 is applicable to the proposed revision to VRR-01.

Precedent Nine Mile Pint Unit 1, Relief Request ADS-VR-01, ERV Power Operated Valves Tested Each Cycle. Approved November 13, 2018. (ML18275A139)

Schedule Duke Planned Submittal to the NRC - January 19, 2021 Requested Approval - March 1, 2021 5