PY-CEI-NRR-2290, Informs That IST Program for Pnpp Is Being Updated to Comply W/Requirements of Latest Edition & Addenda of ASME Code. Summary & Description of Proposed Relief Requests for Pump & Valve Testing Programs,Encl
| ML20236T961 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 07/22/1998 |
| From: | Myers L CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| PY-CEI-NRR-2290, NUDOCS 9807290200 | |
| Download: ML20236T961 (44) | |
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Perry Nuclear Power Plant 9""- -@ 10 Center Road E EE N PO. Box 97 m Perry Ohio 44081 Lew W. Myers 440-280-5915 Vice President Fax:440u280-8029 l
I July 22,1998 PY-CEl/NRR-2290L
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l United States Nucleu Pegulatory Commission l
. Document Control Desk Washington, DC 20555 Perry Nuclear Power Plant Docket No. 50-440 Submittal of inservice Pump and Valve Relief Requests for Second 120-month interval Ladies and Gentlemen:
In accordance with 10 CFR 50.55a (f)(4)(ii), the Inservice Test Program for the Perry Nuclear Power Plant is being updated to compiy with the requirements of the latest edition and addenda of the ASME Code incorporated by reference into 10 CFR 50.55a (b) twelve months prior to the start of the second 120 month interval. The second interval will start on November 18,1998. j Thus, the edition of the ASME Section XI Testing Code for the second interval is the 1989 i edition. Based on this edition thera are certain relief requests being submitted per 10 CFR 50.55a (f)(5)(iii) and (iv). Attachment 1 provides the summary and description of the proposed relief requests for the pump testing program, and Attachment 2 provides a summary and description of the proposed relief requests for the valve testing program. '
If you have questions or require additional information, please contact Mr. Henry L. Hegrat, !
Manager - Regulatory Affairs, at (440) 280-5606.
Very truly yours, Attachments ,
.auGsJ l cc: NRC Project Manager NRC Resident inspector NRC Region ill 9907290200 990722 l PDR ADOCK 05000440 p PDR 3 l
Attachm:nt i PY-CEl/NR-2290L Pag 31 of 13 f
CODE COMPLIANCE FOR THE 2"' INTERVAL INSERVICE PUMP TESTING PROGRAM l
Requirements for the selection of Code edition and addenda are established in 10CFR50.55a, codes and Standards. The edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, in use for the 1" interval is the 1983 Edition through the Summer 1983 Addenda. 10CFR50. 55a ( f) (4 ) (ii) determines the edition and addenda to be used in subsequent intervals:
" Inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, conducted during the successive 120-month inspection l intervals must comply with the requirements of the latest edition and addenda of the Code incorporated by reference l in paragraph (b). of this section 12 months prior to the start of the 120-month inspection interval, subject to the ,
limitations and modifications listed in paragraph (b) of !
this section."
The second inspection interval at PNPP will start on November 18, 1998.
The latest edition and addenda of the code incorporated by reference in 10CFR50. 55a (b) (2) , 12 months prior to the start of PNPP's 2"d inspection interval is the 1989 Edition of Section XI. Therefore, the 2"d interval I PNPP inservice pump testing program is being written to comply with the 1989 Edition of Section XI, Subsection IWP. In the 1989 edition of the Code, IWP-1100 states that " Pump testing shall be performed in accordance with the requirements stated in ASME/ ANSI OM (Part 6)." )
Limitations and modifications to the latest edition and addenda of the code incorporated by reference in 10CFR50.55a(b) (2), that are applicable to the inservice pump testing program, are as follows:
10CFR50. 55a (b) (2 ) (viii) , specifies that when using the 1989 Edition of ASME Section XI, the specified revision date or indicator for ASME/ ANSI OM Part 4, ASME/ ANSI OM Part 6, and ASME/ ANSI OM Part 10 shall be the ,
OMa-1988 Addenda to the OM-1987 Edition. ]
The 2"d interval inservice pump testiag program will observe the aforementioned rules with the following exception. Relief is being requested to implement the ASME OM Code 1995 Edition, Subsection ISTB, Paragraphs 6.2.2 and 4.6 (see PR-3). ;
10CFR50. 55a ( f) (5) (iii) states "If the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in S 50.4, information to support the determinations." The non-conformance issues are identified and submitted to the NRC as relief requests. Relief requests contain the applicable component (s),
the impractical Code requirement, and alternative requirements to be followed.
Attadyn:nt i PY-CEUNRR-2290L Pigs 2 of 13 SUte(ARY OF PROPOSED 2"' INTERVAL RELIEF REQUESTS PR-1 (Previously PR-2, l'" Interval) : This relief request would allow analysis of data within four working days (excluding weekends and holidays) vs. the 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> required by OM(6)-6.2. Relief was previously granted from IWP-3220, which is identical to OM(6)-6.2.
PR-2 (Previously PR-9, 1** Interval): The test frequency required by OM(6)-5.1 is nominally every three months. Relief from the quarterly testing requirements of IWP-3400 was granted for the waterleg pumps in the l'* Interval due to the hardship involved. Relief will still be required to perform IST testing of the water leg pumps at a cold shutdown frequency. This relief request has been revised to clarify the hardship, that the waterleg pumps have adequate margin beyond their required flow rates, and point out that the testing currently performed is in accordance with GL 89-04, Position 9.
PR-3, Declaring Pump Operability Using Analysis: IWP-3230(c) allowed corrective action for a deviation that fell within the required action range to be an analysis demonstrating that the condition did not impair pump operability and that the pump would still fulfill its function.
OM(6) removed the ability to analyze pump acceptability and establish new reference values when the required action range is reached. In OM-1995, ISTB Sections 4.6 and 6.2.2, this option was reinstated.
Approval of this relief request would allow analytical corrective action and the establishment of new reference values based on the newer edition of the code.
PR-4,5, Alert and Required Action Ranges for Smooth Running Pumps For pumps with very low reference values of vibration velocity, it is possible that using 2.5 and 6 times the reference value as a basis for the Alert and Required Action Ranges [OM(6)-5.2(d), 6.1, & Table 3) can lead to unnecessarily increasing test frequency or declaring a pump inoperable. Small changes due to instrument / test variations and not related to machine condition could result in a pump entering into the alert or required action range. An option, which has been granted to other plants, is to base the Alert and Required Action Range levels on a fixed minimum value of vibration velocity. The recommended minimum value is 0.02 inches per second (ips). Pumps with vibration velocity reference values below 0.02 ips would then have Alert and Required Action Ranges of >0.05 to 0.12 ips and >0.12 ips respectively. Use of fixed minimum values for vibration velocity Alert and Required Action Ranges would require trending and analysis of vibration velocity test data to enhance the ability to detect pump degradation. Furthermore, for standby pumps where the lack of run time complicates future performance prediction, an extra requirement is added to double a pump's test frequency if any vibration reading doubles from the
- previous test. PR-4 would be for continuously running pumps or pumps l in alternating service that could possibly meet the smooth running l criterion. PR-5 would be for standby pumps and contains the additional requirement that if any vibration measurement increases by a factor of i 2,5 from the previous test, then the pump test frequency will be doubled until a vibration trend has been established.
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AttachmGnt 1 PY-CEl/NRR-2290L Page 3 of 13
SUMMARY
OF PROPOSED 2" INTERVAL RELIEF REQUESTS (CONTINUED)
PR-6, Use of Digital Instruments Where Reading is > 70% of Range:
OM ( 6) -4. 6.1. 2 (b) requires that digital instruments be selected such that the reference value does not exceed 70% of the calibrated range of
.the instrument. Plant process computer (ERIS) points are used for instrumentation in numerous IST pump tests. Reference values for many of the parameters monitored by ERIS points are greater than 70% of the ERIS point range. In several cases, readings also exceed 70% of the range of temporary digital instruments used in IST testing. Relief is required to use the above instrumentation. Both the temporary digital-instruments and the ERIS points provide improved accuracy and readability over conventional analog instruments and thus increase the level of quality and safety.
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AttachmGnt 1 PY-CEl/NRR-2290L Page 4 of 13 i-l
( Pump Relief Request #
l l PR- 1
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System:- As Applicable l Pumps: . 1C41-C001A 1E21-C002 1P42-C001A 1R45-C001A j IC41-C001B lE22-C001 1P42-C001B 1R45-C001B lE12-C002A 1E22-C003 1P45-C001A 1R45-C001C lE12-C002B- 1E51-C001 1P45-C001B 1R45-C002A 1E12-C002C lE51-C003 1P45-C002 1R45-C002B lE12-C003 G41-C003A P47-C001A 1R45-C002C 1E21-C001 G41-C003B P47-C001B 1^
j, Class: ASME Class 2 and 3 Function: As Applicable l Code Requirement: OM(6)-6.2, Time Allowed for Analysis of Tests. All test data shall be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after completion of a test.
Basis'for Relief: The Inservice Testing (IST) personnel are not always readily available for the review effort. Test acceptance criteria are contained within the test procedures, and the initial approval of equipment operability is by on-Shift perronnel.- The on-Shift personnel declare pumps whose measured parameters enter the acceptance criteria required action range inoperable, in a timely manner. The analysis of results for degradation requiring increased testing or engineering evaluation will then occur when the IST personnel are available for reviewing the inservice pump-test data. Therefore, compliance with the duration required for performance of the analysis would result in a hardship without a compensating increase in the level of quality and safety.
A similar relief request (PR-2)-had been previously approved per an NRC Safety Evaluation Dated April 5, 1993 (Log No. PY-NRR/CEI-062 9L) .
l Alternative: Test data shall be reviewed within four (4) work i I
days following'the test, excluding weekends (Saturday & Sunday) and holidays.
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Attichm:nt 1 PY-CEl/NRR-2290L
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Pump Relief Request #
PR-2 I
System: Waterleg Fill Pumps (RHR, LPCS,'HPCS, and RCIC)
Pumps: 1E12-c003, lE21-C002, lE22-C003, and lE51-C003 l
l Class: 2 l . -
Function: Waterleg pumps maintain the discharge piping of safety-related systems full to expedite flow during initiation, and minimize the likelihood of system damage due to
,, waterhammer.
Code Requirement: OM(6)-5.1; Frequency of Inservice Tests. An inservice test shall be run on each-pump nominally every three months.
Basis for Relief: The waterleg pumps were designed to be inservice to maintain emergency standby systems pressurized. The waterleg pumps run continuously, with flow established through a recirculation line, in order to provide enough head to keep the applicable systems discharge piping full to the highest elevation. During safety-related pump testing, the waterleg pump normal discharge path must be redirected through drain lines to provide enough flow to establish the selected Code reference values. This requires taking the system out of service and racking out safety-related pump breakers (RHR, LPCS, and HPCS) or isolating the safety-
'related pump (RCIC) to prevent system danage due to waterhammer or cavitation upon receipt of an actuation signal. In addition, all of these pumps
.hr.ve adequate margin beyond the capacity required
- for them to fulfill their function.
Quarterly monitoring of discharge pressure (suction pressure is essentially constant) and bearing vibration in accordance with Position 9 of GL 89-04 will be performed to monitor for pump degradation.
The intent of ASME Code,Section XI is not to reduce the reliability of safety-related systems.
Quarterly full flow testing of the listed safety-related waterleg pumps would result in hardship without a compensating increase in the level of quality or safety.
A sindlar relief request (PR-9) had been previously approved per an NRC Safety Evaluation Dated April 5, 1993 (Log No. PY-NRR/CEI-062 9L) .
Attachm:nt 1 PY-CEl/NRR 2290L
- Pags 6 of 13 Pump Relief Request #
PR-2 (Continued)
Alternate Testing: Test in accordance with OM(6) during. cold shutdown.
In addition, these pumps shall be monitored on a quarterly basis, observing pump discharge pressure and bearing vibration. -These parameters will be evaluated to. adequately assess the. pump's performance.
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Anictuntnt i PY-CEUNRR-2290L Page 7 of 13 Pump Relief Request #
PR-3
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System:' As Applicable
. Pumps: 1C41-C001A 1E21-C002 1P42-C001A 1R45-C001A j 1C41-C001B lE22-C001 1P42-C001B 1R45-C001B lE12-C002A lE22-C003 1P45- 001A 1R45-C001C 1E12-C002B 1E51-C001 1P45-C001B 1R45-C002A lE12-C002C lE51-C003 1P45-C002 1R45-C002B lE12-C003 G41-C003A P47-C001A 1R45-C002C lE21-C001 G41-C003B P47-C001B Class: ASME Class 2 and 3 l Function: As Applicable Code Requirement: OM(6)-6.1. Acceptance Criteria. If deviations fall within the alert range of Table 3, the frequency of testing specified in para.-5.1 shall be doubled until the cause of the deviation is determined and i the condition corrected. If deviations fall within I the required action range of Table 3, the pump shall be declared inoperable until the cause of the .
deviation has been determined and the condition I corrected.
Basis for Relief: As stated above, OM(6) requires doubling of test frequency or declaring a pump inoperable upon reaching the Alert or Required Action Ranges, respectively. In some cases, where a pump has !
sufficient excess margin to its safety analysis j limits, and data trending and analysis only indicate a gradual decrease in pump performance, the requirements of OM(6) may result in taking unnecessary corrective' action.
The 1995 ASME OM Code allows the ability to perform an analysis of the pump and establish new reference values. Paragraph ISTB 6.2.2 states that if the measured test parameter salues fall within the required action range.the pump shall be declared inoperable until either the cause of the deviation L has been determined and the condition corrected, or L an analysis of the pump is performed and new L reference values are established in accordance with
[ Paragraph ISTB 4.6. Paragraph ISTB 4.6 requires that the analysis include both a pump level and a system Jevel evaluation of operational readiness, the cause of the change in pump performance, and an evaluation of all trends indicated by available data. If such an analysis supports establishing new reference values in lieu of correcting the condition, then using the requirements of ISTB 6.2.2
Attachment 1 ;
PY CEl/NRR-2290L !
Page 8 of 13 )
Pump Relief Request # l 1
PR l (Continued) i I
and . ISTB 4.6 as an alternative to OM(6)-6.1 would provide an acceptable level of quality and safety.
1 Notes: Where ISTB 4.6 and ISTB 6.2.2-refer to ISTB ;
tables, OM(6) Table 3 would be inserted. All '
references to ISTB in the preceding paragraphs refer to the 1995 ASME OM Code. i Alternative: If supported by an analysis that meets the- ,
requirements of ISTB 4.6, corrective action may be l to establish new reference values in accordance with ISTB 6.2.2 and ISTB 4.6.
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' Anachm:nt i PY-CEUNRR-2290L .
Page 9 of 13 Pump Relief Request #
PR-4
-System: As Applicable Pumps:
~
1E12-C003 1E22-C003 G41-C003A P47-C001A
'1E21-C002 1E51-C003 G41-C003B P47-C001B Class: ASME Class 2 and 3 Function: As Applicable Code Requirement: OM ( 6)-5.2 - (d) , Test Procedure. .. vibration (displacement or velocity) shall'be determined and compared with corresponding reference values. All deviations from the reference values shall be compared with the limits given in Table 3 and corrective action taken as specified in para. 6.1.
OM(6)-6.1, Acceptance Criteria. If. deviations fall within the alert range of Table 3, the . frequency of testing specified in para. 5.1 shall be doubled until the cause of the deviation is determined and the condition corrected. If devie.tions fall within the required action range of Table 3, the pump shall
.be declared inoperable until the cause of the deviation has been determined and the condition
. corrected.
Basis for Relief: For smooth running pumps with'very low values of vibration velocity, it'is possible that using 2.5 and 6 times the reference value to determine the Alert and Required Action ranges can lead to .
needlessly increasing test frequency or declaring a pump inoperable. Small indicated changes due to variations in test conditions, instrumentation, or personnel, and not related to machine condition could result in unnecessary testing or maintenance.
Fixed minimum reference values for the Alert and Required Action Ranges, if chosen low enough such as 0.02 inches per second - (ips), would still provide for timely corrective action. Data trending and anaYpis should be able to determine if there is a degraded condition even if the Alert or Required Action Ranges have not been reached.
l International Research and Development ' (IRD)
L characterizes pumps running at 0.0196 (~0,02) ips or less as smooth. 0.02 ips is as low or lower than other vibration instrument manufacturer's cutof f for their comparable category (NUREG/CP-0111). 0.02 ips i
would thus be an acceptable reference value to base the Alert and Required Action ranges on. For pumps with reference values below 0.02 ips, the Alert I
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Attachm:nt 1 PY-CEl/NRR-2290L '
Page 10 of 13 Pump Relief Request #
PR-4 (Continued) range would then be >0.05 to 0.12 ips and the Required Action range would be >0.12 ips.
The pumps covered by this relief request either run continuously or are in alternating service. The amount of run time that these pumps accumulate allows for excellent prediction of pump performance by analyzing and trending data gathered quarterly.
Therefore, use of a fixed minimum reference value for the above-listed pumps would provide an acceptable level of quality and safety.
Alternative: For pumps with one or more vibration velocity reference values less than 0.02 ips, an Alert Range of >0.05 to 0.12 ips and a Required Action Range of
>0.12 ips will be applied to those vibration measurements. Actions required by OM(6)-6.1 would take place at these values.
Attachm:nt i PY-CEUNRR-2290L Page 11 of 13
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Pump Relief Request #
PR-5 3 1
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l System: As Applicable !
Pumps: 1E12-C002A 1E51-C001 1P45-C002 1R45-C002A 1E12-C002B 1P42-C001A 1R45-C001A 1R45-C002B 1E12-C002C 1P42-C001B 1R45-C001B 1R45-C002C 1E21-C001 1P45-C001A 1R45-C001C 1E22-C001 1P45-C001B Class: ASME Class 2 and 3 Function: As Applicable Code Requirement: OM(6)-5.2 (d), Test Procedure, vibration (displacement or velocity) shall be determined and compared with corresponding reference values. All deviations from the reference values shall be compared with the limits given in Table 3 and corrective action taken as specified in para. 6.1.
OM(6)-6.1, Acceptance Criteria. If deviations fall within the alert range of Table 3, the frequency of testing specified in para. 5.1 shall be doubled until the cause of the deviation is detenmined and the condition corrected. If deviations fall within the required action range of Table 3, the pump shall be declared inoperable until the cause of the deviation has been determined and the condition corrected.
Basis for Relief: For smooth running pumps with very low values of vibration velocity, it is possible that using 2.5 and 6 times the reference value to determine the Alert and Required Action ranges can lead to needlessly increasing test frequency or declaring a pump inoperable. Small indicated changes due to variations in test conditions, instrumentation, or personnel, and not related to machine condition could result in unnecessary testing or maintenance.
Fixed udnimum values for the Alert and Required Action Ranges, if chosen low enough such as 0.02 inches per second (ips), would still provide for timely corrective action. Data trending and analysis should be able to determine if there is a degraded condition even if the Alert or Required Action Ranges have not been reached.
l-1 International Research and Development (IRD) l characterizes pumps running at 0.0196 (~ 0. 02 ) ips or less as smooth. 0.02 ips is as low or lower than other vibration instrument manufacturer's cutof f for their comparable category (NUREG/CP-0111). 0.02 ips would thus be an acceptable reference value to base
AttachnGnt i PYCEl/NRR-2290L Page 12 of 13 Pump Relief Request #
PR-5 (Continued) the Alert and Required Action ranges on. For pumps with reference values below 0.02 ips, the Alert range would then be >0.05 to 0.12 ips and the Required Action range would be >0.12 ips.
The pumps covered by this relief request are generally in the standby mode. Since these pumps do i not accumulate much run time, prediction of pump j performance by analyzing and trending data gathered quarterly will be supplemented by an additional requirement for placing a pump on an increased test frequency. For pumps with Alert and Required Action Ranges based on a fixed minimum reference value, if any vibration measurement increases by a factor of ,
2.5 from the previous test, the pump's test i frequency will be doubled until a trend can be !
established. This requirement, combined with data analysis and trending, will ensure that corrective action is taken in a timely manner. Therefore, use of a fixed ndnimum reference value for the above-listed pumps, combined with the requirement to l double a pump's test frequency if a vibration j reading increases by a factor of 2.5 from the '
previous test, would provide an acceptable level of quality and safety.
Alternative: For pumps with one or more vibration velocity reference values less than 0.02 ips, an Alert Range of >0.05 to 0.12 1ps and a Required Action Range of
>0.12 ips will be applied to those vibration measurements. Actions required by OM(6)-6.1 would take place at these values. In addition, for standb1 pumps with Alert and Required Action Ranges based on the fixed minimum reference value of 0.02 ips, if any vibration measurement increases by a factor of 2.5 from the previous test, the pump's test frequency will be doubled until a trend can be established.
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' Anidimtnt i i PY'-CEUNRR-2290L Page 13 of 13 Pump Relief Request # .l PR-6 Systems As Applicable Pumps: ,1C41-C001A lE21-C002 1P42-C001A 1R45-C001A 1C41-C001B lE22-C001 1P42-C001B 1R45-C001B lE12-C002A lE22-C003 1P45-C001A 1R45-C001C 1E12-C002B lE51-C001 1P45-C001B 1R45-C002A lE12-C002C lE51-C003 1P45-C002 1R45-C002B 1E12-C003 G41-C003A P47-C001A 1R45-C002C lE21-C001 G41-C003B P47-C001B Class: ASME Class 2'and 3 Function: 'As Applicable Code Requirement: .OM(6)-4.6.1.2 (b), Instrumentation Range (Digital).
Digital instruments shall be selected such that the reference value shall not exceed 70% of the calibrated range of the instrument.
Basis for Relief: Plant process computer (ERIS) points are used for instrumentation in numerous IST pump tests. The ERIS points are used in lieu of the associated analog indicators in order to meet ASME Code instrument loop accuracy requirements. As well as using ERIS points, temporary digital instruments (M&TE) are also used in IST. pump testing. In many cases the reference values exceed 70% of the ERIS point or temporary digital instrument range.
According to NUREG/CP-Olll, the basis for the 70%
requirement is to avoid overhanging an instrument if an unexpected situation is encountered. However, since the ERIS points utilize permanent plant instrumentation, the ranges are already selected to account for all expected operating conditions.
Overhanging is also not a concern with temporary digital instruments. Surveillance tests are written such that the temporary instrumentation would not be overranged, whether the instrument is digital or L. analog. In addition, digital instrumentation is significantly less susceptible to damage from overhanging. Furthermore, reading higher in the j instrument range results in greater accuracy since the instruments are calibrated as a percentage of full scale. Therefore, use of the ERIS points and tenporary digital instrumentation within their full calibrated range would provide an acceptable level of quality and safety.
Alternatives Digital instruments shall be selected such that the measured parameter does not exceed the calibrated range of the instrument.
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Attschment 2 PY-CEI/NRR-2290L Pagelof30 CODE COMPLIANCE FOR THE 2"8 INTERVAL INSERVICE VALVE TESTING PROGRAM 1
Requirements for the selection of Code edition and addenda are established in 10CFR50.55a, Codes and Standards. The edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, in use for the 1" interval is the 1983 Edition through the Summer 1983 Addenda. 10CFR50. 55a (f) ( 4 ) (ii) determines the edition and addenda to be used in subsequent intervals:
" Inservice tests r verify operational readiness of pumps and valves, whosc ;snction is required for safety, conducted during the successive 120-month inspection intervals must comply'witn the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of this section 12 months prior to the start of the 120-month insp(ction interval, subject to the limitations and modifications listed in paragraph (b) of~this section."
The second inspection interval at PNPP will start on November 18, 1998.
The latest edition and addenda of the Code incorporated by reference in 10CFR50. 55a (b) (2) 12 months prior to the start of PNPP's 2"' inspection interval is the 1989 Edition of Section XI. Therefore, the 2" interval
-PNPP inservice valve testing program is being written to comply with the 1989 Edition of Sectiun XI, Subsection IWV. In the 1989 edition of the Code, IWV-1100 states tvat " Valve testing shall be performed in l
accordance with the requirements stated in ASME/ ANSI OM (Part 10)."
[ Limitations and modifications to the latest edition and addenda of the l . Code incorporated by refereace in 10CFR50.55a (b) (2) that are applicable l to'the inservice valve testing program are as follows:
l
- 10CFR50. 55a (b) (2) (vii) , specifies that when using subsection IWV in the 1989 Edition of ASME Section XI, leakage rates for Category A containment isolation valves that do not provide a reactor coolant L system pressure isolation function must be analyzed in accordance L with paragraph 4.2.2.3(e) of Part 10, and corrective actions 1for i
these valves must be made in accordance with paragraph 4.2.2.3(f) of Part 10 of ASME/ ANSI OMa-1988 Addenda to ASME/ ANSI OM-1987.
- 10CFR50. 55a (b) (2 ) (viii) , specifies that when using the 1989 Edition of ASME Section XI, the specified revision date or indicator for ASME/ ANSI OM Part 4, ASME/ ANSI OM Part 6, and ASME/ ANSI OM Part 10 shall be the OMa-1988 Addenda to the OM-1987 Edition.
The' 2" interval inservice valve testing program will observe the aforementioned rules with the following exception. OM(10) invokes the use of OM(1) for testing safety and relief devices, however, PNPP has requested relief to implement the 1995 OM Code, using the provisics.s of Appendix I to satisfy testing safety and relief devices (see VR-6).
10CFR50. 55a ( f) (5) (iii) states "If the licensee has determined that conformance with certain code requirements is impractical for its
' facility, the licensee shall notify the Commission and submit, as specified in S 50.4, information to support the determinations." The non-conformance issues are identified and submitted to the NRC as relief requests. Relief requests contain the applicable component (s), the impractical Code requirement, and alternative requirements to be followed.
Attachmrnt 2 PY-CEI/NRR-2290L Page 2 of 30
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I St290LRY OF PROPOSED 2'*8 INTERVAL RELIEF REQUESTS I l
I VR-1 (Previously VR-6,1** Interval) : These valves, for the Control Rod Hydraulic System, are not directly stroke time tested but are considered operable when the control rod insertion time testing acceptance criteria is met. Relief is being requested from the requirements of OM(10)-4.2.1 and 4.3.2 since these valves do not have any position indication and verification that the valves exercise and fail safe is only dependent on an indirect measurement. Relief had been previously granted from the requirements of IWV-3411, IWV-3413 and IWV-3521, which are essentially the same as OM(10) requirements. The 1C11-ll5's alternate position testing will be performed every refueling outage, which is permitted by OM(10). However, this will require that a refueling outage justification be generated.
VR-2 (Previously VR-11, 1** Interval) : The requirements of OM(10)-4.2.1 cannot be directly met for these solenoid valves that provide air to the MSIV's operators. However, their operational readiness can be indirectly verified by testing of the Main Steam Isolation Valves, since failure of these solenoid valves would affect the tests performed on the MSIV's.
Relief had been previously granted from the requirements of INV-3411, IWV-3413, and IWV-3415, which are essentially identical to the requirements of OM(10).
VR-3 (Previously VR-20,1** Interval) : OM(10)-4.2.1 requires power operated valves to be exercise tested. This requirement cannot be directly met for these solenoid valves that provide air to the air operators of the nuclear boiler ADS and Safety / Relief valves. However, these solenoid valves will be proven operable, indirectly, by remotely actuating the SRV's open and closed prior to resumption of electric power generation. Relief had been previously granted from the requirements of IWV-3411, 3413, 3415 and 3300 which are essentially identical to the requirements of OMIl0)-4.2.1.
VR-4 (Previously VR-26,1** Interval) : OM(10)-4.3.2.4 allows, as an alternative to testing valves to verify obturator movement, disassembly every refueling outage to verify operability of check valves. Since the NRC has accepted valve disassembly on a sampling basis, as provided in Generic Letter 89-04, Attachment 1, Position 2, PNPP will adopt a similar plan to be used on these ECCS keep fill pump discharge check valves. As such, a minimum of 1 valve will be disassembled each refueling outage and all valves within the group will be disassembled within 4 refueling outages, i
Attrhment 2 PY-CEI/NRR-2290L Page 3 of 30 SIDG4ARY OF PROPOSED 2*8 INTERVAL RELIEF REQUESTS (cont.)
VR-5 (Previously VR-32,1" Interval) : OM(10)-4.2.1 requires power operated valves to be stroke time tested. This requirement cannot be directly met for the solenoid and air operated valves that supply starting air to the Div. 1 & 2 and HPCS diesel generators due to the valves being totally enclosed. However, the operability of these valves is indirectly verified during diesel generator surveillance testing, monitoring starting times, and conducting of monthly diesel generator j air rolls. Also, since these valves do not have any position indication, verification of valve exercise and fail safe testing are also dependent on an indirect measurement. Relief had been previously granted from the requirements of IWV-3411, IWV-3413, and IWV-3415, which are essentially identical to the requirements of OM(10).
VR-6 ' Adopt the mandatory appendix, ASME CH Code - 1995 Appendix I: The requirements for the selection of Code edition and addenda are established in 10CFR50.55a, Cades and Standards. The requirements of 10CFR50. 55a (f) ( 4 ) (ii) determine the edition and addenda te b. used in subsequent intervals. The applicable Code and Standard re"erenced are:
- 1)Section XI which includes addenda through the 1988 Addenda and editions through the 1989 Edition, subject to limitations and 2)
ASME/ ANSI Part 10, Oma-1988 Addenda to the OM-1987 Edition. Relief is Requested to adopt the ASME OM Code - 1995, Appendix I, Inservice Testing of Pressure Relief Devices in Light-Water Reactor Power Plants, as the mandatory Code for testing pressure relief devices.
VR-7 Containment Vacuum Breaker Leakage Testing: ASME OM Code 1995, Appendix I, 1 1.3.7 states that leak rate testing of the Containment Vacuum Breakers shall be. performed every 2-years. 10CFR50 Appendix J should be the governing document as to when leakage rate testing is required, not the OM Code. At present these valves are leakage tested every refuel due to problems with one set of these valves in the past, however, this frequency may be changed when this particular set of valves re-establishes a satisfactory performance history as is permitted by Option B to Appendix J. As a result of the aforementioned, this relief is being submitted to permit leakage rate testing to be performed in accordance with Appendix J Option B, Performance Based Requirements.
VR-8 HCU Rupture Disc Replacement Frequency: ASME OM Code-1995, Appendix I, i 1.3.6 requires Nonreclosing Pressure Relief Devices to be replaced every 5-years. This requirement applies to all Class 2 and 3 devices, which would also include the 177 rupture discs associated with the Hydraulic Control Units in the CRD system. These devices have a 40-year EQ Qualification and as such shoulc be replaced as deemed necessary by the manufacturer. Due to the high degree of reliability for these devices (only one failure in 1984 was documented in the Nuclear Plant Reliability Data System) replacement every 5 years would not have a significant increase in quality and safety but would present a hardship for the owner.
Attachmsnt 2 PY-CEI/NRR-2290L Page 4 of 30 SIR 4GLRY OF PROPOSED 2"d INTERVAL RELIEF REQUESTS (cont. )
VR-9 Classification of Check Valves as Series-Pair: OM (10 ) -4 . 3 . 2 requires check valves to be exercise tested. The RCIC Vacuum Breaker Check Valves act as an integral unit (i.e., series pair) thus ensuring the turbine exhaust steam line pressure remains equalized, and providing isolation of the containment atmosphere from the turbine's exhaust steam. Relief is requested to exercise open and closed these check valves as a series-pair on a refueling outage basis.
VR-10 Performance-Based Leakage Testing: OM (10 ) -4 . 2. 2. 3 requires that Category A valves, which perform a function other than containment isolation, be seat leakage tested to verify their leak tight integrity.
The testing frequency for this activity is every 2-years. This relief request provides for testing these valves based on their performance, rather than the prescriptive 2 year frequency. Optivn B to Appendix J allows for testing of containment isolation valves on an extended frequency if the performance history of a given component meets certain requirements. Good performing Category A valves that perform a function other than containment isolation, should be seat leakage tested on an extended interval, similar to how the good performing Containment
. Isolation Valves are.
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l AttachmInt 2 PY-CEl/NRR-2290L PageSof30 Valve Relief Request #
VR-1 System: Control Rod Drive Hydraulic System (C11)
Valves: IC11-114, IC11-115, 1Cll-126, IC11-127 (Typical of 177)'
Category: B.(1C11-126, 1C11-127).
Class: 2 Function: Control Rod Drive Scram Inlet, Exhaust, Scram' Discharge Header Check,' and. Accumulator Supply Check.
Test _ Requirements: OM(10) - 4.2.1, Valve Exercising Test' OM(10) - 4.3.2, Exercising Tests For Check Valves
' Basis-for Relief: These valves operate as an integral part of the hydraulic control unit to rapidly insert control rods. Valves will be tested in accordance with Technical Specifications (TS) (i.e., maximum scram insertion time). The TS surveillance required frequency of testingf(i.e., all control rods prior
=to thermal power exceeding 40% of rated. thermal power after fuel movement within the reactor pressure vessel, and after each reactor shutdown j 2120 days, and testing of a representative sample of the control rods at least.once per'120 days of
' operation in mode 1), assures the necessary quality of;the system and components is maintained, that facility operation will be within the safety limits and the Limiting Condition of Operation will be met.
-Therefore, compliance'would result in a hardship R without a compensating increase in the level of quality and safety.
LA similar relief request-(VR-6) had been previously approved'per GL 89-04, Position 7 as identified in NRC Safety. Evaluation Dated April 5, 1993 (Log No.
l PY-NRR/CEI-0629L)
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. Alternate Testing: Scram. insertion timing shall be substituted for individual valve testing.
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I Valve Relief Request #
VR-2 System: Nuclear Boiler (B21)
Valves: 1B21-F460, 1B21-F461, 1B21-F4 62, 1B21-F463, 1B21-F480, 1B21-F481, 1B21-F482, 1B21-F483 Category: B Class: 3 Function: Solenoid valves provide air to MSIV operators to cycle MSIV's.
Test Requirement: OM(10) - 4.2.1, Valve Exercising Test Basis for Relief: The solenoid valves are proven operable by cycling i performed on the MSIV's. The MSIV exercising is performed during cold shutdown.
f Satisfactory completion of the MSIV exercising verifies the exercising of the solenoid operated control valves.
If a MSIV fails to meet its stroke time acceptance criteria the associated solenoid valves will be evaluated to determine if corrective action should l be taken. Therefore, the alternative test provides j an acceptable level of quality and safety. j A similar relief request (VR-11) had been previously approved per an NRC Safety Evaluation Dated April 5, 1993 (Log No. PY-NRR/CEI-0629L).
Alternate Testing: Valves shall be exercised during the exercising of MSIV's.
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Valve Relief. Request #
VR-3 System: Nuclear Boiler (B21)
' Valves: IB21-F410A, 1B21-F410B, 1B21-F411A, 1B21-F411B, 1B21-F412A, 1B21-F412B, 1B21-F413A, 1B21-F413B,.1B21-F414A, 1B21-F414B,
- . -1B21-F415A, IB21-F415B, 1B21-F416A, 1B21-F416B, 1B21-F417A, L 1B21-F417B, 1B21-F420A, 1B21-F420B, 1B21-F421A, 1B21-F421B,
! '1B21-F422A, 1B21-F422B, 1B21-F423A, 1B21-F4238, 1B21-F424A, l~ 1821-F424B, 1B21-F425A, 1B21-F425B, 1B21-F440A, 1821-F440B, i IB21-F441A, 1B21-F441B, IB21-F442A, 1B21-F442B, 1B21-F443A, 1B21-F443B, 1B21-F444A, 1B21-F444B Category: B Class: 3 Function: Supply air to air operators of'the nuclear boiler ADS and Safety / Relief valves.
Test Requirement: OM(10) - 4.2.1, Valve Exercising Test Basis for Relief: These solenoid operated valves are proven operable during testing of the Nuclear Boiler ADS and Safety / Relief valves (SRV) . 'Also, in a study (BWR Owners Group Evaluation of NUREG-0737, Item II . K. 3.16 ) the number of ADS and safety relief valve openings-should be reduced as much as possible to-minimize LOCA risk. Based on this study, and the potential for causing a LOCA condition, exercising these valves is delayed to refueling.
The solenoid valves are proven operable by remotely actuating the SRV to verify open and close capability of the' relief valve prior to resumption of electric power generation. The design of PNPP provides two solenoid valves for.each SRV, with divisional separation of the solenoid valves, such that an SRV exercise only exercises ~one of the two solenoid valves. The solenoid operated valves will be tested at the Technical Specification Surveillance Required frequency of testing (i.e.,
every.18 months on a STAGGERED TEST BASIS for each valve solenoid). If a SRV fails to meet its-acceptance criteria during cycling, the associated SRV solenoid valves will be evaluated to determine if corrective action should be taken Therefore, the alternative test provides an ace ? table level of l; quality and safety.
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Attmhment 2 PY-CEI/NRR-2290L Page 8 of 30 Valve Relief Request #
VR-3 (Continued)
A similar relief request (VR-20) had been previously approved in NRC Safety Evaluation Dated April 5, 1993 (Log No. PY-NRR/CEI-0629L).
Alternate Testing: Solenoid operated valve exercise testing shall be performed on a refueling outage frequency, in accordance with the Technical Specification Surveillance Requirements prior to resumption of electric power, by exercising the SRV(s).
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Attachment 2 PY-CEI/NRR-2290L - i Page 9 of 30 i
~ Valve Relief Request 4 VR-4 System: Safety-related Keep Filt Systems Va]ves: 1E12-F084A, 1E12-F084B, lE12-F084C, 1E51-F061 Category: C' Class: 2 Function: These simple check valves are used as in-line check valves for the safety-related keep fill pumps discharge lines, for the Low Pressure Core Spray, Residual Heat Removal and React -
Core ' alation Cooling systems.
Test Requirements: OM(10) - 4.3.2, Exercising Tests For Check Valves Basis for Relief: These simple check valves are the outboard check of a series pair for the safety-related keep fill pump discharge. They provide the high to low pressure interface to' prevent overpressurization of the low pressure portion of the system.
Both the associated inboard and involved outboard check valves are in close proximity to each other.
At cold shutdown these valves are exercised open by verifying proper keep fill system flow. The associated inboard stop check valves can be verified closed using the manual handuheel (in accordance with the guidance provided in September 26, 1991, Supplement to the public meetings on Generic Letter 89-04). The system configuration does not include test connections between the involved outboard valves and their associated inboard stop check valves. Hence, the closure of the outboard check valves cannot be individually verified. The system would have to be redesigned and modified to 1
perform the code' required testing. Disassembly and inspection of'these valves on a campling basis to assess their closure capability provides a reasonable alternative to the Code test method.
The NRC staff previously accepted valve disassembly and inspection on a sampling basis as an siternative to full. flow testing in Generic Letter 89-04, Attachment 1, Position 2. Due to the scope of the
~ activity, the personnel hazards. involved and system operating restrictions, this valve disassembly will l be performed daring reactor refeeling cutages.
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PY CEl/NRR-2290L Pcge 10 of 30 l
Valve Relief Request #
VR-4 (Continued)
A similar relief request (VR-26) had been previously approved in NRC Safety Evaluation Dated April 14, 1994 (Log No. PY-NRR/CEI-0701L).
alternate Testing: A nample disassembly and inspection plan which is consistent with Generic Letter 89-04, Attachment 1, Position 2, will be utilized. Sample groups may consist of more than 4 valves; however, all valves within each group must be disassembled within a maximum of 4 refueling outages. These valves are exercised open following their assembly by verifying proper keep fill pump flow.
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Attachmsnt 2 PY-CEl/NRR-2290L Page ll of 30 Valve Relief Request #
VR-5 System: Division 1 and 2 Standby Diesel Generator Jtarting Air (1R44) and Division 3 HPCS Standby Diesel Generator Starting Air (1E22)
Valves: 1E22-F541A, 1E22-F541B, 1E22-F543A, 1E22-F543B, 1R44-F010A, 1R44-F011A, 1R44-F010B, 1R44-F011B, 1R44-F015A, 1R44-F016A, 1R44-F015B, 1R44-F016B, 1R44-F020A, 1R44-F021A, 1R44-F020B, IR44-F021B, 1R44-F025A, 1R44-7026A, 1R44-F025B, 1R44-F026B Category: B Class: 3 Function: Starting Air Valves supply starting air for Division 1 and 2 Standby Diesel Generators and the HPCS Standby Diesel Generator.
Test Requirements: OM(10) - 4.2.1, Valve Exercising Test Basis for Relief: It is impractical to measure the stroke times of these valves because they are totally enclosed solenoid / air operated valves which have no externally visible indication of valve position.
Failure of a valve to perform the required function will result in an increase in the starting time or the diesel generator or failure to secure starting air.
Division 3 HPCS requires both air start solenoids to epmn to satisfy its starting time for operability, thus normal monthly timing verifies operability.
Therefore, the proposed alternative provides an equal level of quality and safety.
Division 1 and Division 2 Standby Diesel Air Starting Systems have two independent air banks with each air bank having two parallel starting air coleneid valves. All four starting air solenoid valves are verified operable on a monthly basis during performance of the monthly diesel surveillance tests. During performance of monthly diesel surveillance tests, a pre-start air roll and ,
a post-shutdown air roll are performed on each I standby diesel. During performance of the pre-start i air roll, both air banks are operated and only one parallel starting air l
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Attachm:nt 2 PY-CEl/NRR 2290L Page l2 of 30 Valve Relief Request #
VR-5 (Continued) solenoid valve in each air bank is energized to roll the diesel. The two energized starting air solenoid valves (one in each air bank) are (1) verified open, by verification of a pressure decrease in each air bank accumulator and (2) verified closed by verification of air being secured upon termination of the air roll. Likewise, the alternate solenoid valves (i.e., the other of the two parallel starting air solenoids in each air bank) are tested in the same manner during performance of the post-shutdown air roll.
In accordance with plant procedures, the air roll portion of the monthly surveillance is not permitted to be performed on an operable standby diesel if the other standby diesel is inoperable, since performance of the air rolls on the operable diesel requires declaring the operable diesel inoperable, thus rendering both emergency diesel generators inoperable. Consequently, an extended diesel outage (i.e., greater than quarterly) may cause the operable diesel air start solenoids to exceed the quarterly test requirements. In such cases, the diesel starting air solenoid valves shall be verified operable by satisfactory performance of the monthly diesel runs.
In summary, performance of monthly diesel air rolls provides an acceptable means of verifying diesel starting air solenoid valve operability. In those situations where conformance to the Code is impracticable for the facility, such as where monthly diesel air rolls cannot practicably be performed, monthly diesel runs shall adequately demonstrate diesel air start solenoid valve operability. Therefore, the proposed alternatives provide an equivalent level of quality and safety.
A similar relief request (VR-32) had been previously approved per a NRC Safety Evaluation Dated April 5, 1993 (Log No. PY-NRR/CEI-0629L).
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Attachmird f PY-CEI/NRR-2290L Page 13 of 30 i Valve Relief Request #
VR-5 (Continued)
Alternate Testing: Diesel starting air valves shall be verified operable during monthly diesel generator surveillance testing.
The operability of HPCS starting air valves shall be l determined by monitoring HPCS diesel starting time.
Normally the operability of Div. 1 and Div. 2 starting air valves shall be determined during performance of monthly air rolls by using one solenoid from each air bank and verifying pressure decrease. However, air roll testing is not permitted to be performed on an operable standby diesel if the other standby diesel is already inoperable. Therefore, if one diesel remains inoperable for an extended period of time, the diesel starting air solenoid valves shell be verified operable by satisfactory performance of the monthly diesel run.
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Attachment 2 PY CEl/NRR-2290L . j Page l4 of 30 J l
Valve Relief Request-#
VR-6 Systems: As Applicable Valves: Applicable to all Pressure Relief Devices (i.e., safety
! valves, relief valves, pilot operated pressure relief valves, power actuated pressure relief valves, nonreclosing pressure relief devices and vacuum relief devices).
Category: C and AC l
Class: 1, 2 and 3 Function: These devices provide pressure relief in systems that function to shutdown the reactor, maintain the reactor in a safe shutdown condition, mitigate the consequence of~an accident, or provide overpressure protection for such systems.
Test Requirement:.The requirements for the selection of Code edition and addenda are established in 10CFR50.55a, Codes and Standards. The requirements of 10CFR50.55a (f) (4) (li) determine the edition and addenda to be used in subsequent intervals. Subsequent intervals are to comply with the Codes and Standards referenced in 10CFR50. 55a (b) (2) , 12 months prior to the start of the Inspection Interval. The applicable Code'and Standard referenced are: 1)Section XI which includes addenda through the 1988 Addenda and editions through the 1989 Edition, subject t limitations and 2) ASME/ ANSI Part 10, Oma-1988 Addc .a to the OM-1987 Edition. Section XI, IWV-1100 states that,'" Valve testing shall be performed in accordance with the requirements stated in'ASME/ ANSI OM (Part 10)". OM Part 10 invokes the use of OM Part 1 for testing of safety and relief valves.Section XI, IWA-1600 (Referenced Standards and Specifications) identifies the 1987 Edition of OM Part 1. ,
Basis for Relief: OM Part 1 has evolved over the past decade; such that it is now a Code (ASME OM C:'i -1995 Appendix I) as opposed to a Standard (ASME/AJSI OM Part 1 - 1987),
and now provides guidance on establishing acceptance g criteria, grouping of valves, and additional testing.
L Perry Nuclear Power Plant has evaluated the Standard OM Part l'- 1987 versus OM Code 1995 Appendix I and i
determined that the requirements of ASME OM Code, Edition 1995 are preferred for performance of inservice testing of nuclear power plant pressure relief devices.
4ttachment 2
?Y-CEI/NRR-2290L P3gelSof30 Valve Relief Request #
VR-6 (continued)
Therefore, PNPP is requesting the use of the mandatory appendix, ASME OM Code - 1995 Appendix I, Inservice Testing of Pressure Relief Devices in Light-Water -
Reactor Power Plants. I The use of this mandatory appendix is supported by the Proposed Rule Change to 10 CFR Part 50, dated December 3, 1997. The proposed amendment for IST would require licensees to implement the 1995 Edition of the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for Class 1, Class 2, and Class 3 pumps and valves prior to the start of a new 120 month interval.
Alternate Testing: Adopt the mandatory appendix, ASME OM Code -
1995 Appendix I, Inservice Testing of Pressure Relief Devices in Light-Water Reactor Power Plants as the mandatory Code for testing pressure relief devices.
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Attachmsnt 2 PY-CEI/NRR-2290L -
Ftge 16 of 30 4 Valve Relief Request #
VR-7
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i System: Containment Vacuum Relief.(M17) System {
Valves: .lM17-F010, 1M17-F020, 1M17-F030, IM17-F040 Category: AC.
. Class: 2 Function: These primary containment vacuum relief valves are designed to protect the containment from an adverse condition caused by a negative pressure. These valver maintain the containment approximately equal to ths outside environment by opening to permit the passage.of outside air into the containment whenever the differential pressure exceeds a predetermined value.
Test' Requirement: ASME OM Code, 1995, Appendix I,.1 1.3.7 (b): Leak tests'shall be perfocmed on all Class'2 and 3' containment vacuum re.ief valves at each refueling or every 2 years, whichever is sooner, unless historical data requires more fregtent . testing.
Basis for Relief: These vacuum breakers are functionally tested every 31' days ' (i.e. , full exercise) as required by Technical Specifications. In addition, Technical Specifications require that the opening pressure differential be verified for the vacuum breakers every 18 months. This testing ensures'that the vacuum breaker valves will perform their intended function when' required, which is to prevent a negative pressure inside the containment in' relationship to the outside environment.
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Attachmmt 2 PY-CEI/NRR-2290L Page l7 of 30 Valve Relief Request #
VR-7 (Continued)
In addition to their primary function of protecting the containment from an underpressure condition these valves also serve as primary containment isolation valves and are required to be tested for leakage on some periodic basis. 10CFR50 Appendix J, which sets forth the rules and conditions for containment leakage rate testing, has a section designated Option B-Performance Based Requirements. This section permits leakage rate testing to be performed at intervals of up to 5 years, based on the valves performance history. Option B eliminated the prescriptive requirements that were deemed marginal to safety, and allowed a components past performance to be the determining factor for the testing interval.
Alternate Testing: Leakage rate testing of the containment vacuum relief valves will be in accordance with the requirements of 10CFR50 Appendix J, Option B (Performance-Based Requirements).
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Attachmint 2 PY-CEl/NRR-2290L Pagn l8 0f 30 Valve Relief Request #
VR x Systems Control Rod Drive Hydraulic System (C11)
'Valaes: 1C11-132 '(typical of 177) Hydraulic Control Unit Rupture Discs-Category: D-Class:. 2 Function: .These nonreclosing pressure relief devices provide over pressure protection for the nitrogen side of the Hydraulic
' Control Units.
Test-Requirement: ASME OM Code, 1995, Appendix I, 1 1.3.6, Class 2 and 3 nonreclosing pressure relief devices shall.be replaced every 5 years, unless historical data indicates a requirement for more frequent replacement.
- Basis for Relief
- The rupture units supplied w. h the Control Rod Drive (CRD), Hydraulic Control Unit (HCU) Accumulator have an active safety function to provide overpressure protection to the HCU accumulator. The rupture units also have a passive safety function to maintain the nitrogen charge in the HCU accumulator, which in turn
. maintains the control rod scram (rapid insertion) capabilities. The rupture unit is designed to burst at 2000 to 2200 psig at 400*F, or 2550 to 2900 psig at 72*F, and has a normal ' operating pressure of 1750
.psig.
If the rupture unit were to burst during normal plant operation, a CRD HCU. low pressure alarm would annunciate in the control. room. With a low pressure condition the associated control rod would remain operable, but the control rod scram time would be
. declared " slow". The. Perry Technical Specifications allow no more than 13 operable control rods to be declared " slow", and no operable control rod that is
" slow" shall be adjacent to another operable control rod that is " slow" or a withdrawn control rod that is stuck. Thus, the increase in control rod insertion time would love a negligible.effect on the capability to safely shutdown the reactor.
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The affected rupture unit would then be replaced and the control rod' returned to service.
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Attachmsnt 2 PY-CEUNRR-2290L t
Page 19 0f 30 Valve Relief Request #
VR-8 (Continued)
These rupture discs are not subjected to operating conditions that cause degradation, as they are in an inert environment (nitrogen blanketed) and remain at a re'aiively
. constant pressure. These devices also have a qualified life of 40-years as identified in the environmental qualification program. Due to the high degree of reliability (only one reported failure in l
1984 was recorded in the Nuclear Plant Reliability Data System) of these devices, replacement every 5-years would provide no significant increase in quality and safety but would present a hardship to the Owner, both in cost and radiation exposure.
Alternate Testing: ' Replacement of the Hydraulic Control Unit Rupture Discs will be at the Owners Discretion but not to exceed 40 years of in-service life.
Attachrnent 2 PY-CEl/NRR 2290L Page 20 0f 30 Valve Relief Request #
VR-9 Systems: Reactor Core Isolation Cooling System (RCIC)
Valves: lE51-F079, lE51-F081 Category: C Class: 2 Function: These RCIC check valves serve various " unctions to allow for proper operation of the RCIC system t . sine.
Test Requirements: OM(10) - 4.3.2, Exercising Tests For Check Valves Basis for Justification: The exercise and normal (closed) position verification of lE51-F079 and lE51-F081 will be performed during refueling outages due to restrictions on system operability and area radiation levels. The RCIC Vacuum Breaker Check Valves act as an integral unit (i.e., series pair) thus ensuring the turbine exhaust steam line pressure remains equalized, and r ' ring isolation of the containment atmosphere ! ' turbine's exhaust steam. Both the open r . .d position exercise require significant test duratioits for equipment; installation, testing and removal.
Additionally, these check valves meet the NRC staff's position for series pair. Valve. redundancy is provided due to the harsh / volatile operating environment and closure of only one valve assures satisfactory performance of their intended safety function. These val.es are category "C" (no sect leakage test) because any seat leakage is directed into the controlled containment environment.
Finally, the failure of both valves to pass the closure verification would require both valves te be repaired or replaced, as necessary, r
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Atta:hm:nt 2 PY-CEl/NRR-2290L Page 21 of 30 Valve Relief Request #
VR-9 (continued) .
l Each test method requires personnel to be located in high radiation fialds for prolonged periods while the plant is cperating at power and requires the RCIC system to be removed from service for the duratica of the test. Therefore, compliance with the quarterly exer'cise requirement would result in unusual difficulty and hardship without a compensating increase in the level of quality and safety due to the increased exposure of personnel to radiation and the prolonged period of inoperability of a system required for safe shutdown. j The classification of these valves as a series-pair has been previously approved per a NRC Safety j Evaluation Dated April 5, 199' l Lug No. W PY-NRR/CEI-0629L)
Alternate Testing: Perform valve exercise 'estiny of the series pair, lE51-F079/F081, during refueling outage.
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Attachmsnt 2
. PY-CEl/NRR-2290L Page 22 of 30 3
-Valve Relief Request #
VR
- System: As Applicable
. Valves: .All. category A and AC valves requiring periodic leakage-rate testing with-the exception of containment isolation valves and pressure-relief devices.
Category:. A'and AC Class 1, 2 and 3
. Function: Category A or AC valves have seat leakage limited to a specific maximum amount in the closed position for fulfilling a required function.in shutting down a-reactor to the cold shutdown condition, in maintaining the cold shutdown condition, or in' mitigating the consequences of an accident. These valves are grouped by the safety function requiring a seat leakage limit. These functions include 1) accumulator pressure boundary leakage, 2) instrumentation
-(i.e., backfill ~, sensing transmitters, cabinets) failure, 3).
reactor coolant pressure isolation, 4) high-to-low system interface, 5) . system leakage integrity, and 6) parallel pump bypass flow.
Test Requirement: OM (10)-4.2.2.3 (a): Frequency,. Tests shall be
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conducted once every 2 years.
Basis for Relief:'A Performance-Based Testing Program has been developed which would eliminate the prescriptive test frequency requirements and allow test intervals to be based'on system and component' performance.'Through its own Regulatory Improvement Program, the NRC has institutionalized an ongoing effort to eliminate requirements marginal to safety and to reduce the regulatory burden on utilities. A performance-based. .
testing program, utilizing an extended testing. !
interval based on the successful completion of 2 or
.more consecutive leakage. rate tests, would take advantage of the. findings of NUREG-1493, Appendix A.
The conclusions drawn by the NUREG suggest that "if a component does not fail within two operating cycles, further failures appear to'be governed by the random l failure rate of the component". The NUREG also states {"
that any test scheme considered, should require a failed component to pass at least two consecutive tests'before allowing an extended test interval.
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i Attachment 2 PY-CEl/NRR 2290L Page 23 of 30 Valve Relief Request #
1 VR-10 (Continued) l The Performance-Based Testing Program for ASME Section XI valves requiring leakage terts, was developed in much the same manner as the Option B Program for )
i Appendix J testing, which was permitted by amendment )
of the Code of Federal Regulations on 10-26-95. In {
the studies performed in support of the code hange, J it was concluded that performance-based testing is {
feasible without significant risk (NUREG 1493). Also, '
EPRI Research Project Report TR-104285, " Risk Impact '
Assessment of Revised Containment Leak Rate Testing -
Intervals" reaffirmed this position by stating that changes in leakage testing frequencies are feasible without significant risk impact.
The development of this performance-based testing program started with toe generation of a leakage test history for each valve that is to be included in the program. Then a review of the test histories for each valve was conducted to establish if a minimum of two (2) consecutive periodic tests had passed and whether any erratic behavior could be detected. All the valves were then placed into a type category (i.e.,
check, globe, gate, etc.) to establish which types may be more prone to failure. By performing this, a direct comparison could be made of like valves in like systems to determine if some of those valves weith good test histories should be monitored more frequently.
Valves that pass a minimum of 2 consecutive tests without any erratic behavior and are not considered i suspect valves will be put on an extended interval of l 4 years or 2 refueling cycles, whichever is longer.
Any valve not meeting the minimum threshold requirement will be left on a 2-year test interval until at least 2 consecutive tests are acceptable. In addition, if a failure occurs on any extended interval valve, the initial test frequency of 2 years must be re-established until two consecutive tests pass.
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PY-CEl/NRR-2290L 1 Page 24 of 30 l l
Valve Relief Request #
VR-10 (Continued)
Alternate Testing: Leakage rate testing of Category A and AC valves will be performed in accordance with the ASME Section XI Performance-Based Testing Program. Valves that have met the threshold of passing two consecutive tests will be permitted to ;o tested every 4 years or 2 refueling cycles, whichever is longer. Valves which fail their acceptance criterion will be tested each refuel until they pass a minimum of two consecutive tests.
The following is a listing of valve groups to be included in the ASME Section XI Performance-Based Program. Valves affected by this relief request are categorized by the safety function requiring a seat leakage limit. Valves shall meet the applicable guidelines of the Nuclear Energy Institute (NEI-94-01), Industry Guidelines for Implementing ,
Performance-Based Option of 10CFR Part 50, Appendix J for a performance I based testing program. Using the guidelines, valves that have passed a minimum of two consecutive leakage rate tests may be placed on an extended testing interval. All valves placed on an extended testing interval for seat leakage will still have all other associated Section XI testing (i.e., exercising and position verification), performed at the required frequency by the Inservice Testing Program. Valves that have not passed the minimum of two consecutive tests will continue to be tested during each refueling outage until their test histories become satisfactory to permit an extended testing interval.
Each valve or combination of valves is being assigned an operational frequency rating, that is indicative of the expected frequency at which !
the valve would perform an active function (i.e., opening and closing).
The operational frequency assigned would be relative to the expected rate of valve degradation (i.e., valves seldom exercised would not be expected to lose their valve seat integrity as rapidly as those valves
{
exercised more frequently). The operational frequency ratings will be i assigned as follows: seldom, infrequent, occasional and frequent. {
l SELDOM - Maintenance or convenience type valves in which operation is seldom desired or required.
INFREQUENT - Valves in which operation would be expected at a cold shutdown or greater frequency for testing or other evolutions. j OCCASIONAL - Valves in which operation would be expected at a '
quarterly frequency for testing or other evolutions.
FREQUENT - Valves in which operation is expected during normal plant operation, for reasons other than testing. Valves assigned as FREQUENT, would be considered for exclusion from the performance based testing program.
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Attachment 2 PY-CEl/NRR-2290L Page 25 of 30 Valve Relief Request #
VR-10 (Continued)
ACCUMULATOR PRESSURE BOUNDARY LEAKAGE Safety related components might rely upon an accumulator as a pressure source for actuation or backup actuation. The following valves are used in the isolation integrity of-the accumulator's pressure boundary.
Inboard Main Steam Isolation Valve (MSIV) Accumulator -
INFREQUENT:
Inboard Accumulator Supply Check valves (1B21-F02(A/B/C/D) makeup an integral portion of the Inboard MSIV accumulator pressure boundary. These accumulators are supplied by the non-safety instrument air system (1PS2) and the supply check valves must close and limit seat leakage to a specific maximum amount upon loss of the air supply. Maintaining the seat leakage below the specified limit ensures that the accumulator will maintain sufficient pressure for proper cycling of the Inboard MSIV. Seat leakage is currently'being measured by the feed rate required to maintain test pressure in the test volume.
Outboard Main Steam Isolation Valve (MSIV) Accumulator -
INFREQUENT:
Outboard Accumulator Supply Check valves (1B21-F029A/B/C/D) makeup-an integral portion of the Outboard MSIV accumulator pressure boundary. These accumulators are supplied by the non-safety
-instrument air system (lP52) and the supply check valves must close and limit seat leakage to a specific maximum amount upon loss of the air supply. Post accident, these accumulators are also supplied by the safety related air system (lP57) after it is manually manual initiated, at which point these valves are no longer required to maintain seat leakage to a specific maximum amount.' Maintaining the seat leakage below the specified limit ensures that the accumulator will maintain sufficient pressure for proper cycling of the Inboard MSIV until the safety related instrument air supply can be aligned. Seat leakage is currently being measured by the feed rate required to maintain test pressure in the test volume.
Safety Related Air "A" Accumulator - SELDOM: 1 l
Safety Related Air "A" Accumulator Supply Check Valves (lP57-F555A l
& F556A) makeup an integral portion of the Safety Related Air j (lP57) System pressure boundary. These check valves are considered maintenance only. The accumulator is supplied by the non-safety related portion of the 1P57 system and the supply check valves must close and limit seat leakage to a specific maximum amc7nt upon loss of the air supply. Maintaining the seat leskage below !
the specified limit ensures that the accumulator will mai.ntain )
sufficient pressure for proper cycling of Automatic j Depressurization System Safety Relief Valves. Seat leakage I I
measurement is currently satisfied by measuring leakage through a downstream telltale connection while maintaining test pressure on one side. 4
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Attachment 2 .
PY-CE!/NRR-2290L Page 26 0f 30 Valve Relief Request #
VR-10 (Continued)
ACCUMULATOR PRESSURE BOUNDARY LEAKAGE (continued)
Safety Related Air "B" Accumulator - INFREQUENT l
Safety Related Air "B" Accumulator Supply Check Valves (1P57-F555B j
& F556B) makeup an integral portion of the Safety Related Air (lP57) System pressure boundary. These check valves are considered maintenance only. The accumulator is supplied by the non-safety related portion of the 1P57 system and the supply check valves must close and limit seat leakage to a specific maximum
- amount upon loss of the air supply. Maintaining the seat leakage below the specified limit ensures that the accumulator will maintain sufficient pressure for proper cycling of Automatic Depressurization System Safety Relief Valves. Seat leakage measurement is currently satisfied by measuring leakage through a downstream telltale connection while maintaining test pressure on one side.
Additionally, Outboard MSIV Accumulator Normal Supply Check Valves (lP57-F572B & F574B) makeup an integral portion of the Safety Related Air System (lP57) pressure boundary after manual initiation. The Outboard MSIV accumulators are supplied by the instrument air system (lPS2) and the supply check valves must close and limit seat leakage to a specific maximum amount upon loss of the air supply. Maintaining the seat leakage below the specified limit ensures that the accumulators will maintain sufficient pressure for proper cycling of Automatic ,
Depressurization System Safety Relief Valves au well as closure i force for the Outboard MSIVs. Seat leakage measurement is !
currently satisfied by measuring leakage through a downstream i telltale connection while maintaining test pressure on one side.
Upper & Lower Containment Inner & Outer Door Airlock )
Accumulators - FREQUENT: l Airlock Door Accumulator Air Supply check valves [lP53-F587B & ;
F588B (Upper Inner Door), 1P53-F587A & 1PS3-F588A (Upper Outer Door), 1P53-F572B & F573B (Lower Inner Door), 1P53-F572A u F573A (Lower Outer Door makeup an integral part of the specific door seal accumulator pressure boundary. These accumulators are ! supplied by the non-safety instrument air system (lPS2) and the ; supply check valves must close and limit seat leakage to a ' specific maximum amount upon loss of the air supply. Maintaining
'the seat leakage below the specified limit ensures that the ,
accumulator.will maintain sufficient pressure for proper inflation of the small and large door seal. Seat leakage measurement is currently being determined by reasuring pressure decay in the test volume and' atsigning the total apparent leakage rate to the valve combination. i e
Attachmer 2 PY-CEI/'.RR-2290L Pagez1of30 Valve Relief Request # VR-10 (Continued) ACCUMULATOR PRESSURE BOUNDARY LEAKAGE (continued) Drywell Inner & Outer Door Airlock Accumulators - INFREQUENT: Airlock Door Accumulator Air Supply check valves (lP53-F601B & F602B (Drywell Inner Door), and 1P53-F601A & F602A-(Drywell Outer Door)). makeup an integral part of the specific door seal accumulator pressure boundary. These accumulators are supplied by the non-safety instrument air system (lPS2) and the supply check valves must close and limit seat leakage to a specific maximum amount upon loss of the air supply. Maintaining the seat leakage below the specified limit ensures that the accumulator will maintain sufficient pressure for proper inflation of the small and large door seal. Seat leakage measurement is currently being determined by measuring pressure decay in the test volume and assigning.the total apparent leakage rate to the valve combination. INSTRUMENTATION LEAKAGE ISOLATION RPV Water Level Instruments Continuous Backfill - INFREQUENT: Reactor Vessel Reference Level Backfill Supply Check Valves (1B21-
'R0llA-F,' R011A-G, R0llB-F,.R011B-G, R011C-F, R0 llc-G, R011D-F and R011D-G) provide a makeup Flowpath'from the Control Rod Drive (CRD) . System to each of the reactor pressure vessel level sensing line reference legs. This backfill is used to prevent errors in reactor vessel level indication during normal and transient operating conditions. The backfill allows makeup flow of approximately 0.02 gpm, which prevents the buildup of non-condensable gasses. The portion of the CRD system which supplies the ' makeup flow is non-s sfety related and the supply check valves must close and llmit sect leakage to a specific maximum amount upon loss of the CKL system. Maintaining the seat J eakage below the specified limit ensures proper reactor vessel level indication and minimizes a potential reactor coolant leakage path. Seat leakage measurement is currently: satisfied by measuring leakage i through a downstream telltale connection while maintaining test pressure on one side.
Containment Atmosphere and Water Level Instrumentation - OCCASIONAL: Containment Atmosphere and Water Level Instrument Isolation valves q (lD23-F010A/B, F020A/B,.F030A/B, F040A/B & F050, 1M17-F055 & F065 ) and 1G43-F050A/B & F060) isolate instrument lines which are i considered closed loops outside containment. These solenoid 1 isolation valves are normally open and remotely closed in the unlikely event of a failure of the closed loop portion (i.e., instrumentation).of'the system outside containment in order to 4 i limit seat leakage to a specific maximum amount. Maintaining the ! seat leakage below the specified limit ensures the proper
. i isolation of the primary containment pressure boundary if an instrument line failure were to occur. Seat leakage is currently being measured by the feed rate required to maintain test pressure in the test volume.
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I Atuchment 2 : PY-CEI/NRR 2290 i Page 28 0f 30 l Valve Relief Request # VR-10 (Continued) i REACTOR COOLANT PRESSURE ISOLATION .! Pressure Isolation Valves'(PIV) are defined as two normally closed ~ valves in series that isolate the reactor coolant system (RCS) from an-attached-low pressure system. These valves are. tested to prevent the unlikely condition of an intersystem LOCA resulting from excessive valve seat leakage through the affected line. These valves remain close
-during normal plant operation to limit seat-leakage to a specific maximum amount. Maintaining the seat leakage below the specified limit ensures the proper isolation of the reactor coolant pressure boundary.
Seat leakage is curretely being measured by the feed rate required to maintain test pressure in the test volume. Residual Heat Removal (RHR) Iniection Lines - INFREQUENT: RHR Injection Line Inboard Isolation Check valves (1E12-F041A/B/C) and RHR Injection Line Outboard Isolation Motor Operated valves (1E12-F042A/B/C) isolate the RCS from the low pressure portions of the RHR system. Low Pressure Core Spray (LPCS) Injection Line - INFREQUENT: LPCS Injection Line Inboard Isolation Check valve (1E21-F005) and LPCS Injection Line Outboard Isolation Motor Operated valve (1E21-F006) isolate the RCS_from the low pressure portions of the LPCS
' system.
High Pressure Core Spray (HPCS) Iniection Line - INFREQUENT: HPCS' Injection Line Inboard Isolation Check valve (1E22-F004) and LPCS Injection Line Outboard Isolation Motor Operated valve (1E22-F005) isolate the RCS from the low pressure portions of the HPCS system. Standby Liquid Control (SLC) Injection Line - INFREQUENT: SLC Injection Line Inboard and Outboard Check valves (IC41-F006 & F007) isolate the RCS from the. low pressure portions of the SLC system.
, Residual Heat Removal (RHR) Shutdown Cooling Suction Line -
INFREQUENT: RHR Shutdown Cooling Inboard Isolation Valves (1E12-F009 & F550) and Outboard Isolation Motor Operated valve (IE12-F008) isolate the RCS from the low pressure portions of the RHR system. Reactor Coro 1, solation Cooling (RCIC) Injection Spray Line - INFREQUENT: ~ ' RCIC Head Spray Inboard and Outboard Isolation Check valves (1E51-to F066 & 1E51-F065) isolate the RCS from the low pressure portions (: of the-RCIC' system. I L u__ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - -
Attachment 2 PY-CEI/NRR-2290L Page 29 0f 30 Valve Relief Request # VR-10 (Continued) HIGH-TO-LOW SYSTEM INTERFACE PRESSURE ISOLATION High-To-Low System Interface Pressure Isolation Valves are defined as two normally closed valves in series that isolate a high pressure liquid system from an attached low pressure liquid system. Valve testing prevents.the unlikely condition of excessive seat leakage from causing a system overpressure condition. These valves remain closed during normal plant operation to limit seat leakage to a specific maximum amount. Maintaining the seat leakage below a specified limit ensures that proper intersystem isolation exists between systems. Seat leakage is currently being measured by the feed rate required to maintain test pressure in the test volume. Residual Heat Removal (RHR) Head Spray Line - INFREQUENT: RHR Head Spray Inboard Isolation Check valve (lE12-F019) and Outboard Isolation Motor Operated valve (lE12-F023) are the head spray line intersystem pressure isolation valves used to prevent over-pressurization of a low pressure safety related system. Residual Heat Removal (RHR) Shutdown Cooling Return Lines - INFREQUENT: RHR Shutdown. Cooling Isolation Check. valves (lE12-F050A/B) and Isolation Motor Operated valves (lE12-F053A/B) are the shutdown cooling return lines intersystem pressure isolation valves used to prevent over-pressurization of a low pressure safety related system. Feedwater Leakage Control System (FWLCS) Supply' Lines - INFREQUENT: FWLCS Supply Inboard Isolation Check valves (lN27-F739A/B & IN2'/- F742A/B) and Outboard Isolation Motor Operated valves (lN27-F737 & F740) are the supply' lines intersystem pressure isolation valves. used to prevent over-pressurization of a low pressure safety related system. 1 l i i L ' l. L.
AttchmInt 2 PY-CEI/NRR-2290L Page 30 0f 30 Valve Relief Roquest # VR-10 (Continued) PRIMARY COOLANT LEAKAGE PATHWAY TO ATMOSPHERICALLY VENTED TANKS SYSTEM LEAKAGE INTEGRITY Systems that require an active isolation to perform the desired safety function, may require the isolation feature to allow minimum system leakage. The valve or valve group is to be assigned the maximum allowable system leakage. Emergency Closed Cooling (ECC) System Leakage Integrity - INFREQUENT: Nuclear Closed Cooling (NCC) System To ECC Cross-Tie Isolation valves (P42-F295A/B & P42-F325A/B) are intersystem isolation valves used to isolate the non-safety NCC system from the safety ECC System upon activation of a LOCA signal. Maintaining the seat leakage below the assigned limit ensures that proper intersystem isolation exists between the systems. Seat leakage measurement is currently being determined by measuring a system makeup in the test volume and assigning the total apparent leakage rate to the valves. PARALLEL PUMP BYPASS FLOW Systems that require an active isolation of the parallel pump loop to perform the desired safety function may require the isolation feature to allow minimum system leakage. Standby Liquid Control (SLC) System Parallel Pump Bypass Flow - OCCASIONAL: SLC Pump Discharge Check valves (lC41-F033A/B) allow flow of borated coolant to the reactor vessel upon activation and prevent pump bypass flow upon closure. Maintaining seat leakage below the specified limit ensures minimum pump bypass flow. Seat leakage is currently being measured by the feed rate required to maintain test pressure in the test volume. l l I l l 1 t i u--_--_------- ;}}