NRC-94-0090, Forwards Relief Request VR-59 for IST Program for Pumps & Valves to Resolve Listed Inspector follow-up Item Noted in Insp Rept 50-341/94-09.ISI Program Revised to Include Relief Request
| ML20079A497 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/27/1994 |
| From: | Gipson D DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-94-0090, CON-NRC-94-90 NUDOCS 9501030097 | |
| Download: ML20079A497 (3) | |
Text
g, Dougt s H. Gipson Senor V(a PresvJent Nuclear Generat on Detroit r.-
6400 North Dixie Highway Edison
~(313)58&f249
~~~
i December 27, 1994 NRC-94-0090 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) NRC Inspection Report No. 50-341/94009, dated August 12, 1994
Subject:
Relief Request for Inservice Testing Program for Pemps and Valves Detroit Edison is submitting Relief Request VR-59 in accordance with 10CFR50.55a(g)(5)(iii).
While closing violation 50-341/89024-01J concerning full stroke testing of two testable check valves (E1100F050A and B, residual heat removal system inboard isolation testable check valves), the NRC identified an inspector follow-up item 50-341/94009-01 (Reference 2).
Detroit Edison is submitting this relief request to resolve this item.
Relief Request VR-59 involves the substitution of calculations for the measurement of actual observed force in meeting the alternate testing requirements in ASME Section XI per IWV-3522 for stroke testing of check valves E1100F050A and B.
At the time the actuators were installed, the actual torque to perform the exercise was not observed.
Detroit Edison requests approval of this relief request because removal of the actuator and measurement of the actual torque required to lift the disc would result in an unnecessary excessive radiation exposure. The actuator is of the rack and pinion type and would require a significant amount of time to remove and then to reinstall and align, only to affirm the validity of the calculations. The full stroke actuators are installed on E1100F050A and B, and alternate testing previously described 10. Relief Request VR-8 is being used.
i Approval of Relief Request VR-59 will allow Detroit Edison to use calculated torque in lieu of the actual observed force.
Fermi is currently utilizing the proposed relief requested in VR-59 The ISI program has been revised to include the relief request.
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~Page-2 If you have any-questions on this matter, please contact Mr. Hari 0.
Arora at (313) 586-4213
' Sincerely, i
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T. G. Colburn
'J. B. Martin M. P. Phillips'
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Page 1 RELIEF REXXIEST NO. VR-59 SYSTEM:
Residual Heat Removal COMPONENT:
E1100F050A E1100F050B CATEGORY:
A/C FUNCTION:
These valves are designed as pressure isolation valves (PIVs). Pressore isolation valves are defined as valves-which isolate the portions of a system designed for low pressure service from the portions of a system connected to the Reactor Coolant Pressure Boundary (RCPB) which are designed for high pressure service.
TEST REQUIREMENTS: As stated in Relief Request VR-8, valves E1100F050A and E1100F050B will be full stroke tested in the open direction using a mechanical full stroke actuator during refueling outages. This test must meet the requirements of paragraph IWV-3522(b).
BASIS FOR RELIEF: Paragraph IWV-3522(b) states that "... The force or torque delivered to the disk by the exerciser must be limited to less than 10% of the equivalent force or torque represented by the minimum emergency condition pressure differential acting on the disk, or to 2005 of the actual observed force or torque required to perform the i
I exercise on the valve when the valve is new and in good operating condition, whichever is less..." At the time the actuators were installed, the actual torque to perform the exercise was not observed. The valves were, however, exercised numerous times while new and in good operating condition. Subsequently, it was determined by calculation that the latter force is the lessor of the two and that this torque should have been observed. This calculation also demonstrated that the actuator provides 172.86% of the force that would have been observed to exercise the valve when it was new. Thus, the actuator meets the intent of the code in that the valve will not be over stressed, and it does provide the margin to monitor for degradation. To remove the actuator and measure the actual torque to lift the disc would pose an undue hardship on Fermi. Excessive f
radiation exposure would result because the actuator is of the rack and pinion type and would require much time to remove and then reinstall and align, only to affirm the validity of the calculations.
ALTERNATE TESTING: The calculated torque to lift the disc will be used as the test basis in lieu of the actual observed force.
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