RBG-35-380, Rev 5B to River Bend Station Pump & Valve Inservice Testing Program Plan. Relief Requests Encl

Rev 5B to River Bend Station Pump & Valve Inservice Testing Program Plan. Relief Requests Encl

ML20077J725
Person / Time
Site:	River Bend
Issue date:	07/26/1991
From:	Odell W GULF STATES UTILITIES CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PROC-910726, RBG-35-380, NUDOCS 9108050012
Download: ML20077J725 (42)

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GULF STA TES w ma um UTILITIES mmm a n COMPANY srm m uwm wes Ye8 A46 4 [CDf b_14 [,1 h b.'N M{ M$l July 26 1991 RBG 35,,380 File Nos. G9. 5, G12. 5. 2. 6, G12.5.2.7 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

River Bend Station - Unit 1 Docket No. 50-458 Gulf States Utiliti.es (GSU) is providing Revision 5B of the River Bend Station (RBS) Pump and Valve Inservice Testing Program Plan for your review. This revision responds to the staff's safety evaluation report (SER) dated January 2, 1991, provides additional information and clarification for the Requests for Relief (RR) provided in Revision 5 and supplemented with Revision 5A, and provides five new RRs for the staff's consideration.

This revision addresses those RRs that were granted based l_

on certain conditions or were approved on an interim

basis. The attached Table 1 provides readily available

! information on the revisions and changes GSU proposes to make to the IST program for River Bend Station.

, Regarding the three RRs which were denied in the staff's l SER, GSU is in the process of removing these three RRs and restructuring the RBS IST program to comply with the aforementioned SER and Generic Letter 89-04.

Attached are the following revised RRs and five new RRs, which address separate certain alternate test provisions:

PRR No. 1 PRR No. 13 (new) VRR No. 36 PRR No. 2 VRR No. 9 VRR No. 44 PRR No. 5 VRR No. 15 VRR No. 49 PRR No. 8 VRR No. 18 VRR No. 58 PRR No. 9 VRR No. 20 VRR No. 61 (new)

PRR No. 10 VRR No. 24 VRR No. 62 (new)

PRR No. 11 VRR No. 31 VRR No. 63 (new)

PRR No. 12-(new)

A complete revision of the RBS IST Program Plan for Pumps and Valves will be submitted by January 30, 1992.

9108050012 910726 PDR P

ADOCK 05000458 PUR

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Should you have any questions, please contact Mr. L. L.

Dietrich of my staff at (504) 381-4866.

Sincerely, l , f'~ ) *: ,.

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W. 11. Odell Manager-Oversight River Bend Nuclear Group ME/LLD/M F Attachment cc: U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Driva, duite 1000 Arlington, TX 76011 Senior Resident Inspector Post Office Box 1051 St. Francisville, LT 70775 Mr. Doug Pickett, 1 Sting Project Manager Nuclear Regulatory Commirsion One White Flint North 11555 Rockville Pike Rockville, MD 20852

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E RIVER BEND STATION UNIT 1 [ ,

RESPONSE TO SER REVIEW &

SUMMARY

OF RELIEF REQUESTS ACTION BY NRC ACTION BY CSU RELIEF & &

REQUEST TER SECTION XI RECOMMENDATION RESPONSE NUMBER SECTION REQUIRENENT & BUBJECT Table IWP-3100 Relief granted provided Relief Request revised,to state if PRR-1 2.1.4.1 mear,urement made for pumps are stopped during the test, Noto #1 the pressure will be obtained and pumps stopped during quarter. recorded and that periodic inspection and lubrication checks are performed prior to starting and during operation.

2.1.5.1 IWP-3230 & Relief denied. Revised to delete the OM Part 6 PRR-2 Table IWP-3100-2 requirements for increased acceptance criteria and no alert ranges. Implementation will be completed and procedures revised by November 1, 1991.

Interim Relief granted GSU to set up meeting with NRC and PRR-3 2.2.3.1 IWP-3400(a) ECf.G to discuss frequency of Test Frequency for for 6 months.

testing. RBS SLC configuration Standby Liquid Control different from other plants.'

Pumps Existing system design places the plant in a Lc0 for both trains when testing is performed. Additional 6 months is requested to investigate and correct if necessary.

Interim Relief granted Revised Pump Relief Request #4 to PRR-4 2.1.3.1 IWP-4120 address IWP-4120 and issued new Instrument Full-Scale for 1 year.

Relief Request PRR-12 to address the Range differential pressure issue on RCIC, l SSWP, DC/EGF systems.

1 Relief granted provided Revised Pump Relief Request to PRR-5 2.1.2.1 IWP-4510 perform in accordance with ASME/ ANSI Measure Vibration Licensee complies with Amplitude OM-6 vibration test OMa-1988 Part 6 vibration requirements. requirements.

h IWP-3200-1, Note 1 Relief granted provided Revised to include the instruments PRR-8 2.3.1.1 accuracy requirements of used for determining inlet pressure Measure Inlet Pressure Table IWP-4110-1 are meet the accuracy requirements of met. IWP-4110-1.

Interim Relief granted Revised Relief Request to perform PRR-9 2.4.2.1 Table IWP-4510 vibration on the upper motor bearir g Vibration Amplitude for 1 year or next refueling outage. and location at the pump shaft journal bearing. _

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RIVER CEND CTATION U!IT 1 [

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RESPONSE TO SER REVIEW & SUNMARY OF RELIEF REQUEST 8 .

RELIEF ACTION BY NRC ACTION BY G8U REQUEST TER SECTION XI & &

NUNBER BECTION REQUIRENENT & SUBJECT RECONNENDATION RESPONSE PRR-10 2.1.1.1 IWP-3300 Relief granted provided Revised to state to perform a Measure Bearing Temp. it complies with OH-6 complete and comprehensive vibration vibration requirement.s. monitoring program per ASME/ ANSI OMa-1988 Part 6.

PRR-11 2.2.1.1 IWP-4600 Relief granted provided Revised to incorporate instrument Measure Flowrate it meets accuracy accuracy requirements.

requirements of IWP-4110-1.

VRR-2 3.3.1.1 IWV-3521 Relief granted provided GSU System Engineering and Design Test Frequency valves are leak tested Engineering are involved in a in pairs per IWV-3420. detailed analysis of our check valve 1B22*VF013A&B program to incorporate more non-1822*VF017A&B intrusive testing and different techniques necessary for verifying check valve operability. Request for 6 month extension for revising the program and Relief Request.

3.7.1.2 IWV-3521 1CCP*V119 tested per Test Frequency IWV-3420.

3.10.1.2 IWV-3521 IIAsav78 tested per IWV-Test 7requency 3420.

3.18.1.1 IWV-3521 1 CMS *V40 & V41 tested Test Frequency per IWV-3420.

3.20.1.1 IWV-3521 IDFR*Vl&V4 tested per Test Frequency IWV-3420.

3.20.1.2 IWV-3521 IDFR*V14,V15,V16,V17 Test Frequency tested per IWV-3420.

VRR-9 3.6.1.1 IWV-3521 Relief denied for Revised Relief Request to remove Test Frequency 1SVV*V9 & 31 based on ISVV*V9 & 31 from the Relief Request accessibility and and initiated new Relief Request insufficient VRR-61 for them.

justification.

RIVER CEND CTATION UNIT 1 _

RESPONSE TO SER REVIEW &

SUMMARY

OF RELIEF REQUESTS ACTION BY NRC ACTION BY GBU RELIEF & &

REQUEST TER SECTION XI P.ECOMMENDATION RESPONSE NUMBER SECTION REQUIREMENT & SUBJECT IW-3411 & IW-3521 shall Relief Request does not System Engineering and, Design VRR-15 App. B #26 Engineering will evaluate the test be exercised quarterly. provide the necessary Test Frequency technical justification. condition and Inservice Test. This process should be complete by November, 1991. Request 6 month extension to provide additional 1 I

information.

IW-3411 & IW-3521 Relief Request does not System Engineering will revise this VRR-18 App. B #25 Relief Request for the SLC system Test Frequency provide the necessary technical justification. valves only. Additional _ technical information is provided.

Relief granted to verify Revised existing Relief Request to VRR-20 3.12.2.1 IW-3521 explain exercising for closure Test Frequency open each cold shutdown and closure each during refuel. Generated new Relief refueling outage. Request VRR-62 for Cold Shutdowns.

IW-3521 Relief granted provided System Engineering and Design VRR-24 3.1.4.1 Test Method & Frequency compliance with GL 89-04 Engineering will evaluate our check for IE12*VF084A-C, Position #2. valve test program to incorporate IE12*VF085A-C, ICCP*V337 new industry techniques and recommended philosophy of NRC

& V338 Generic Letter 89-04, Positior #2.

Request 6 month extensic, for l additional justification L' quired.

IW-3521 Interim Relief granted 3.1.4.2 Test Method & Frequency for 6 months.

for 1HVKaV48 & V97 Additional information needed to complete evaluation.

IW-3521 Relief granted provided 3.1.4.3 the valve is partial Test Methcd & Frequency for 1E51*VF030 stroked prior to return to service.

IW-3521 Interim Relief granted 3.1.4.4 Test Method & Frequency for 6 months.

for ILSvaV114 & 120 Additional information needed to complete evaluation.

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CIVER CEND CTATION UNIT 1

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RESPONSE TO BER REVIEW &

SUMMARY

OF RELIEF REQUESTS .

RELIEF ACTION BY NRC ACTION BY GBU REQUEST TER SECTION XI & &

NUMBER SECTION REQUIREMENT & BUBJECT RECOMMENDATION RESPONSE 3.1.4.5 IW-3521 Relief granted provided ,

Test Method & Frequency compliance with GL 89-of Check Valves without 04, Position #2.

Intermediate Test Connections VRR-29 App. B #22 IW-3521 Does not provide CSU System Engineering and Test Frequency adequate technical Operations are presently involved in information as to the revising surveillance test negative impact. procedures associated with In-Service Testing. Components affected by this relief request may not be adversely affected provided certain lineups and operating conditions are in effect prior to testing. In order to establish the new techniques necessary for verifying the subject check valve operability under a controlled test scenario, CSU requests a 6 month extension for revising the applicable surveillance procedures and relief request as required.

VRR-31 3.1.2.1 IW-3420 through 3427 Relief granted provided Revised the Relief Request to i

Leak Rate Testing compliance with GL 89-04 incorporate IW-3426 & 3427(a) l Position #10. requirements.

I VRR-36 App. B #21 IW-3521 Does not provide Deleted the Relief Request. No Test Frequency adequate technical negative impact to testing the check

, information as to the valves on a quarterly frequency.

I negative impact.

VRR-44 App. B #24 IW-3411 & 3511 Administrative use of Revised Relief Request to only Test Frequency the Relief Request. include the relief valve.

VRR-49 App. B #23 Licensee informed NRC Deleted Felief Request.

the intention to delete Relief Request.

i RIVER EEND CTATION UZIT 1 _

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RESPONSE TO SER REVIEW &

SUMMARY

OF RELIEF REQUESTS .

RELIEF ACTION BY NRC ACTION BY GSU REQUEST TER SECTION XI L &

NUMBER SECTION REQUIREMENT & SUBJECT RECOMMENDATION RESPONSE _

VRR-58 ' App. B #18 IWV-3411 & 3521 Licensee has not Revised Relief Request,to l Test Frequency demonstrated incorporate Tech. Spec. limit of impracticality of exceeding drywell temperature limits performance testing. and deletion of ISWP*MOV57A&B from I

this Pelief Requent and generated new Relief Request VRR-63 for Cold shutdown.

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RIVER L'END CTATION UNIT 1 ,

RESPONSE TO SER REVIEW & ADDITIONAL NEW RELIEF REQUESTS .

RELIEF ACTION BY GSU REQUEST SECTION XI ALTERNATE &

NUMBER REQUIREMENT & SUBJECT TEST NETHOD RESPONSE PRR-12 IWP-4240 Inlet pressure seasurement will Generated a new Rel4ef Request to Differential Pressure be obtained from a calculation aid in certain pump tests where of tank level. inlet pressure must be observed by taking a measurement of tank level.

PRR-13 IWP-4600 Use of multimeter to read flow Generated a new Relief Request to Flow Measurement in volts (DC). aid in pump testing and to obtain-accurate and consistent data.

VRR-61 IWV-3521 Exercise during Refueling Generated as a result of VRR #9 Test Frequency Outages by associated test comment response.

connections and perform leak test to verify valve closure.

VRR-62 IWV-3521 An exercise test every Ccid Generated as a result of VRR #20 Test Frequency shutdown. comment response to test 1E12*VF050A&B.

VRR-63 IWV-3411 & 3521 An exercise test every Generated as a result of VRR #58 Test Frequency Refueling Outage. to separate two different test issues and valve categories.

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I ATTACHHENT

H HP REOUEST *0R RELIEF NO. 1 SYSTEM: Line Fjll Pumps (RHR, LPCS, HPCS, and RCIC)

COMPONENT: ~ 1E12*PC003, 1E21*PC002, 1E22*PC003, and 1E51*PC003 CLASS: 2 EUNCTION: Line fill pumps maintain the discharge piping of safety-related systems full to expedite flow during initiation, and to minimize the likelihood of system damage due to water hammer.

TEST REOUIREMENT: Table IWP-3100-1 Note (1) inlet pressure Pi is to be measured before pump start-up and during the test.

BASIS FOR RELIEF: Certain pumps are in operation to support the plant operation or are configured in a safety or Tech.

Spec. required service. In these situations, shutting down the pump to take an idle suction pressure to determine NPSH could impact plant operations and safety. Most of these safety related pumpn have instrument nonitoring to prevent g start-up on low flow or alarms when suction pressure exceeds the low limit. The securing of waterleg pumps (RHR, LPCS, HPCS and RCIC) to measure the suction pressure stopped would serve no useful purpose, since an adequate net positive suction head (NPSH) is verified by system pressure alarms. If the pumps are in operation prior to the test, the idle suction pressure vill not be taken.

Also, securing these pumps vill require filling and venting the safety-related system increasing the duration that the system is in a nga-standby readiness mode.

ALTERNAE TESTING: If the pumps are in operation and do not require stopping for test performance and indicate normal operation attributes, the idle suction pressure will not be taken. If the pumps are not in operation or are started and stopped during the test, the idle suction pressure will be obtained and recorded. Periodic inspections and lubrication checks are performed prior to starting and during operation to ensura reliability of the pumps.

PUMP REQREST FOR RILIEL,j{0. 2 P

SYSTEM All systems listed in the pump program EQMPONENT: All pumps listed in the IST program $g CLASS: 2 & 3 IUllCIIQ11: Safety Related ILET BE@IREMENT IWP-3230(b), if deviations fall within the Required Action Range of Table IWP-3100-2, the pttap shall be declared inoperative and not returned to service until the cause of deviation has been determined and the condition corrected.

BASIS FOR

'tELI EF : River Bend's IST Surveillance Test Progra: is performed by operations personnel. If a test value was taken and found to be in the Required Action Range, it would be checked unacceptable by personnel performing the test. The data package would then be given to the Shif t Supervisor / Control Room operationn Foreman for their review of the test. He would then make a timely determination as to whSther or not the data meets the requirements of Section XI and take all app"opriate Tech. Spec.

actions as required. Enginee"s would assist the SS/COF as necessary in making the determination as SB to whether or not ASME XI requirements were met.

Al&_EltNATE TESTING: Determination of Required Action to be performed by Shift Supervisor / Control Room Foreman upon their review and signature. Declaration of Required Action to coincide with Tech. Spec. Action Requirements.

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1 P_ UMP REQUEST FQA_RILIEF No. 4 SYSTEM: All systems listed in the IST Pump Program COMPONENT; All pumps listed in the IST Prograrr. $g CLASS: 2&3 FUNCTION: Various safety related activities SB TEST REQUIREMENTS: Per IWP-4120, the full-scale range of each instrument shall be three times the reference value SB or less.

BASIS FOR RELIEF: For pumps in the IST program, the plant installed instruments are often inoperative or out of calibration and are therefore not used for IST testing purposes. In these tests, the procedure requires the use of calibrated temporary H&TE. The M&TE comes in certain standard full-scale ranges (e.g. 0-15, 0-30, 0-60, 0-100, 0-150, etc.).

Examples A problem occurs when trying to obtain the start-up and running inlet pressure. The start-up inlet reference value is 18 psig and the running inlet reference value is 60 psig. This would requirc the use of 2 gauges to meet IWP-4120 requirements. In a second case, the reference value is 30 psig. Three times the reference value ;3 would be 90 psig and use of the 0-60 psig gauge would be too limiting.

t River Bend proposes the following allowances to l

IWP-4120: To use Ong gauge for pressure readings in lieu of attaching, using, and removing two separate gauges. In addition, to permit a lot deviation in the full-scale range reqairements to allow the use of a gauge which places the measured reading in the 3 quarter portion of the scale (where it should be obtained).

l ALTERNATE TESTING: 1) Instrumentation (tenporary or installed) to allow a 10% deviation in the full-scale range requirements of IWP-4120,

2) The use of one gauge to obtain measured 5B pressure parameters when the static and running pressures differ requiring the use of 2 pressure gauges to fulfill IWP-4120.

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PJZHP REQUEST FOR RELIEF NO. 3, EYSTEM: Service Water, Standby Liquid Control, High

, Pressure Core Spray, Residual Heat Removal, Low Pressure Core Spray, Reactor Core Isolation Cooling, Diesel Gen & Aux Emergency; HVAC Chilled Water, Fuel Pool Cooling 5B COMPONENT: 1SWP*P3A,B,C&D; 1C41*PC001A&B; 1E22

• PC001 & PC.vo3 ;

1E12*PC002A,B&C; 1E12*PC003; 1E21*PC001&PC002; 1E51*PC001&PC003; ISWP*P2A,B,C&D; 1EGF*P1A,B,&C; 1HVK*P1B,D,A&C; ISFC*P1A&B CLASS: 2 &3 FUNCTION:

( TEST REOUIREMENT: IWP-4510 Vibration Amplitude - At least one displacement vibration amplitude (peak to peak composite) shall be read during each inservice 5O test.

BASIS FOR RELIEE: New industry and utilities practices indicate the F use of vibration Velocity (in/sec) in lieu of vibration amplitude is more useful in detecting pump performance and bearing degradation.

Vibration meenurements shall be taken in a plane l approximately perpendicular to the rotating shaft on each bearing, where accessible.

This program will be in accordance with the l requirements of ASME/ ANSI OMa-1988, Part 6 and l establishes a complete and comprehensive vibration monitoring program to detect pump bearing l SB degradation as well as component reliability as whole operating component.

ALTERNATE TESTING: Measure vibration velocity (in/sec). The following i test parameters for vibration will be:

i Centrifugal Pumps: vibration measurement to be taken in a plane perpendicular to the rotating shaf t in two orthogonal directions where accessible on each pump bearing housing. Measurement of axial direction to be taken on accessible pump thrust bearings.

PUMP REQUEST FOR RELIEF MO. 5 (CONT.I Vertical Line Shaft Pumps vibration measurement

' to be taken on the upper. motor bearing in thres orthogonal directions one of which is axial direction.

Reciprocating Pumps: the location shall be on the bearing housing of the crankshaft, approximately perpendicular to both the crankshaf t and plunger travel.

A portable vibration device will be used to accomplish this vibration. The following parameters will be followed:

1. Measurement points will be clearly identified to permit duplication of vibration data.

2. Vibration instrument calibration shall be i 54-for the instrument and velocity pickup (s) as one unit to be calibrated together and maintained as such. 58

3. Vibration velocity instruments have a broad range of frequencies and settings making it impossible to establish a (3 times full scale range). Calibration of the unit will control instrument accuracies.

IIBRATIQM_AC.CE22&llGR_CALTERIA Acceptable Alert i Range Range thaoceptable l

Centrifugal &

Vertical Line Pumps 12.5Vr 1) >2.5Vr to $6Vr >6Vr S.3251n/sec >.325 to 1 71n/sec >.71n/sec

( Reciprocating Pumps 52.5Vr 2) >2.SVr to $6Vr >6Vr Notes 1) Where two vibration limits are shown the lower value is applicable.

2) Pumps less than 600 rpm use vibration amplitude /

displacement for these readings.

3) Vr - Referenced Velocity l

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EFEP REQUEST FOR RELIEF NO. 8 2117.TM C9)lPONENT CLMJ FtTNCTlQM D/G- Fuel Oil 1EGF*P1A,D,C 3 Fuci oil transfer from the otorage ,

tank to the day tank  ;

Standby 1SWP*P2A,B,C,D 3 Supply emergency Service Water cooling water to various safety related plant heat loads TEST REOUIREMENT: Per IWP-3100 and Table IWP-3100-1, Note (1), inlet pressure shall be measured before pump startup and during test.

BASIS FOR RELIEF: The suction section of the pumps are submerged in

, the pumping fluid. There is no method to measure the inlet pressure before and after pump startup.

In all cases, the fluid level above the pumps will remain unchanged during the test.

ALTERNATE TESTING: Calculate the pump inlet pressure from the hydrostatic head of fluid above the pump inlet at the time of test. Instrumentation for determining the fluid level meets the accuracy of IWP-4110-1 (12%). In the case of Standby Service Water, the fluid level is obtained visually from tank level 58 indicators (marks) and tape measure to determine level.

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4 g PUMP REQUEST FOR RELIEF WO. 9 SYSTEM: Zmergency Diesel Generator-Fuel oil COMPONENT: - 1EGF*P1A,B,C CLASSt 3 FUNCTION: To transfer fuel oil from the storage tank to the day tank.

TEST REQUIREMENT: IWP-4510 and Pump Relief Request No. 5_shall read and monitor at least one vibration point during each inservice test.

BASIS FOR -

58 RELIEE These pumps are submerged in diesel fuel and are inaccessible to measure vibration directly on the Pump.

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ALTERNATE TESTING: Vibration will be taken on the upper motor bearing ,

housing and at a location at a point next to the t pump shaft journal bearing. This area is located where the-pump housing is bolted to the fuel tank -

lid.

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EL'NP MEOURST FQR RELIEF NO. 10 EYSTEljt Service Water; Standby Liquid Control; liigh Pressure Pressu;e Core Spray; Residual licat Removal; Low Core Spray; Reactor Coro Isolation Cooling; Diesel Gen & Aux Emergency; HVAC Chilled Water; Spent Fuel Cooling COMPOl{EliIt 1SWP*P3A,B,C&D; 1C41*PC001A&B; 1E22*PC001&PC003; 1E12*PC002A,B,C&PC003; 1E21*PC001&PC002; 1E51*PC001&PC003; ISWP*P2A,B,C&D; 1EGF*P1A,B&C; 1HVK*P1A,B,C&D; ISFC*P1A&B CIASE 2 &3 FUNCTION: Various SB TEST REOUIREMENT: IWP-3300 Scope of Test Measure bearing temperature yearly.

BASIS FQB RELIEF: River Bend Station has implemented a complete and comprehensive vibration monitoring program for detecting bearing degradation. The code requirement to observe bearing temperature yearly does not give sufficient information to indicate degradation of the bearing unless failure is imminent at the point of this observation. The vibration. Monitoring Program will provide the information necessary to trend and predict bearing degradation.

ALTERNATE TESTING: To perform complete and comprehensive Vibration Monitoring Program using Vibration Velocity (in/sec) as Acceptance Criteria in accordance with the requirements of ASME/ ANSI OMa - 1988, Part 6.

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PUMP REQUEST FOR RELIEF MO. 11 l 4

SYSTEM: Standby Liquid Control f

COMPONENT: Pumps 1C41*PC001A and 1C41*PC001B CLASS: 2 FUNCTION: To pump sodium pentaborate solution into the [

reactor vessel.  ;

TEST REQUIREMENTS: Per IWP-4600, flow rate shall be measured using a rate or quantity meter installed in the pump test circuit.

BASIS FOR RELIEF 1- Since there is no orifice flange for flow measurement instrumentation _ installed-in the test ,

-circuit of the piping for the Standby Liquid i Control-pumps, nor are there sufficient locations i for obtaining an accurate pressure drop measurement, nor adequate piping configuration to >

utilize portable " clamp-on" flow measuring devices,

. flow rate shall be obtained by measuring the amount $g of liquid being pumped within a measured time ,

period. 1 i

ALTERNATE TESTING: Flow will be measured by the direct-measurement-of l $3 time .versus volume method using :a calibrated  ;

stopwatch and the existing sightglass on'the test -

tank. Measurement will then be-verified by a ruler and tape marking the initial tank level and then measur;.ng a 5-inch drop in level. The time "

required for the tank to drop this 5 inches will be measured. Flow can then be derived by calculating the volume of water transferred.in the given time..

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PR M 1EQUEST FOR RELIEY_No. 12 RyjJJ:H Reactor Core Isolation Cooling; Standby Service

. Water; Diesel Gen & Aux Emergency.

COMPONENT 1E51*PC001; ISWP*P2A, B, C, & D; lEGF*P1A, B, &C CLASS: 2 & 3-FUNCTION: Safety related pumps performing specific duties relating to the operation of the plant.

TIST REQUIREMENT: IWP-4240 Differential Pressure, the differential pressure across the pump shall be determined by...

taking the difference between inlet and the discharge. IWP-4120 Range, the full-scale range of each i'istrument shall be three times the reference value or less.

HASIS FOR RELIEF: The pumps listed on this Rollei' Request have unique operating parameters which makes it impossible to measure the - inlet pressure as specified by the l code. For the Standby Service Water and Emergency Diesel ruel 011 Transfer pumps, the, inlet pressure parameter is derived by the means a specific SB calculation. For_the RCIC pump, the low and speed parameters are adjusted to obtain fixed reference points for consistent and repeatable data. Then the inlet pressure in taken; in this specific case, the inlet pressure for idle and running is significantly different.

ALTERNATE TESTING: For the Standby Service Water and Emergency Diesel Fuel- Oil Transfer pumps, the Inlet Pressure measurement will be taken from a calculation of certain tank level instruments and for the RCIC pump the running suction shall be taken after the pump speed and flow are at their reference values.

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y PUMP _ REQUEST FOR RELIEF NO. 13

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SYSTEM: HVAC-Chilled Water Standby Service Water COMPONENT: 1HVK*P1A,B,C,D 1SWP*P3A,B,C,D CLASS 3 FUNCTION To provide cooling water to the Control Building (HVK) Chillers <

IISI REQUIREMENT: Per IWP-4600, flow rate shall be measured using a rate or quantity meter installed in the pump circuit. The meter may - be in any class that provides an overall readout repeatability within 58 accuracy limits of Table IWP-4110-1. Where the meter does not indicate the flow rate directly, the ,

record shall include the method used to reduce the data.

BASIS FOR RELIEF: These IST pumps have plant installed instrument gauges that do not read in increments beneficial i for measuring the flow rate parameter on these pumps. These instruments receive a signal only, and it is not possible to install a temporary gauge.

ALTERNATE TESTING: The use of a multimeter (12% accuracy) to read flow meter volts (DC) in lieu of a flow meter or temporary installed gauge.

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VALVE REOUEST FOR RELIEF NO. 9 COMPONENT FUNCTION CLASS GATDQGM 1821*VF036A,F,G,J ro prevent the excessive 2 c 1B21*VF036L,M,H,P,R loss of air from the 1B21*VF0398,C,D, Automatic Depressurization E,H,K,5 System air accumulators in the event of a loss of air supply to the accumulators SB TEST REOUIREMENT: Per IWV-3521, check valves shall be exercised at least once every three months.

BASIS FOR .

RELIEF: Testing the valves requires access to the drywell where they are located. There is no access to the )

drywell during normal plant operation and cold i shutdown of sufficient duration to open the )

drywell. Finally, ALARA concerns are an important reason for not performing the testing during cold SB Shutdown (i.e. up to 2 man-rem exposure is likely even after waiting 60 days for decay). The valves I are closed and tested for leak tightness overy refueling outage.

ALTERNATE TESTING: Leak test every refueling outage. This also verifies th a valves close.

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.. 1 YALVE REOUZ8T FOR RELIEF NO. 15 (Cold Shutdown Justification)

COMPONENT FUNCTION CLASS CBIEE;EX 1CCP*V72 Closed Cooling Water supply 3 C 1CCP*V73 header isolation check valves to RHR pump bearing coolers and Fuel Pool Cooling heat exchangers ,

SB IEET REOUIREMENT! Per IWV-3411 and IWV-3521, Category C check valves shall be exercised at least once every three months.

BASIS FOR RELIEF: The exercise testing of the valves during normal operation would cause the RHR pump on the affected loop to be declared inoperable due to the loss of cooling water to the RHR pump seal cooler. The exercise testing of the valves during cold shutdown is acceptable because with Reactor Coolant temperature below 212*, seal cooling to the RHR pumps is not required.

Closed Cooling Water (CCP) is the normal and preferred source of bearing cooling water for the RHR pump seal cooler. Exercising the check valves would isolate this supply rendering the pumps inoperable which would require an LCO. The safety SB position is closed, at which time standby service water will supply cooling isolated from CCP by the check valves.

When a CCP low pressure occurs, CCP is isolated and cooling water is supplied by SWP to the SFC HX and RHR bearing coolers. V73 works to prevent SWP flow from entering the CCP system should MOV16A fail to auto close on low pressure. 58 This same discussion applies to *V72. (MOVs 169 and 163 auto close to prevent flow to the non-safety related CRD pumps).

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VALVI REQUESLJOR RELJEF NO. 15 (CON'Tl (Cold shutdown Justification)

Testing these valves during operation would require isolation of cooling flow to the RHR pump bearings, fuel pool HX, and CRD pump bearings, resulting in loss of the CRD pumps and loss of RHR pump operability. If you try to use SWP to prove valves close, it Would S2ntaminate CCP with SWP quality water. Therefore, these valves cannot be tested quarterly without causing plant damage, shutdown and decreasing plant safety.

ALTERNATE TESTING: An exercise test of each valve during cold shutdown if not performed within the previous 92 days as allowed by IWV-3412 (a) and IWV-3522.

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VALVE REQUEST FOR RELIEF NO. 18 (Cold shutdown Justification) SB COMPONHT FUNCTION 91A31 _qEr30 city 1C41*MOVF001A,B Standby Liquid Control (SLC) 2 B pump suction from the SLC storage tank SB TEST REQUIREMENT: Per IW-3411 and IW-3523, Category A and B valves shall be exercised at least once every three 5B months.

BASIS FOR RELIEF: The exercise testing of the valves during normal plant operation wi'.1 require the pumps and system 5B to be declared beperable during the testing which would result in a Limiting condition for operation.

In order to verify tht exercise of the MOVF001A & B valves, the Standby Liquid control pumps are required to be isoleced at the manual suction 58 isolation valve due to no additional isolation valve in the cross tie of the system.

Opening F001A/B (=30 second valves) would allow some Sodium Pentaborate to mix with the clean water in the pump suction. Then the contaminated water would have to be flushed, then chemistry analysis of the water taken, during this entire time the system would be inoperable and LCo-condition since L the condensate makeup used for flushing would 58 dilute the concentration of solution and would not meet Tech. Spec. should an injection be required.

The necessary flushing of the common line between the two (2) loops (14.no #004-4-2) makes both divisions inoperable. The test method for l- MOVF001A/B would require declaring both pumps inoperable during the f. lushing. All of this is

l. performed under an a hour LCo.

ALTERNATE TESTING: An exercise test of each valve during cold shutdown if not performed within the previous 92 days as allowed by IW-3412 (a) and IW-3522.

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VALVE REOUEST FOR HELIEF NO. 20 COMPONENT FUNCTION CLAER GTDXRY lE12*VF050k,B High pressure isolation 2 C check for RHR shutdown cooling return line to reactor feedwater line TEST REOUIREMENT: Per IWV-3521, check valves shall be exercised at least once every three months.

BASIS FOR RELIEF: The RHR system head is inadequate to open the valves against feedwater operating pressure. The i

valves are opened when the RHR system is placed into the shutdown cooling (SDC) mode during plant shutdowns. To verify the valves close during plant shutdowns would require the shutdown cooling loop of the RHR system to be made inoperable.

Technical Specification 3.4.9.2 requires two (2) loops of SDC to be aval.lable or at least one alternate available for each inoperable loop.

Because of decay heat, it requires at least 30 days for an alternate method such as RWCU or fuel pool cooling to be able to handle the existing heat loads for SDC. During refueling outages, this requirement is reduced to one loop of SDC when the Technical Specification does permit one loop to be made inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for testing.

However, because of the difficulty and time required in performing this test using hoses connected for drain down of the column of water beneath the valve in order to verify disk closure, operations personnel will not permit this testing as a conservative measure.

This test cannot be accomplished with the loop in SDC. In addition, a significant volume of contaminated water is released to radwaste.

Finally, since the drain hub is located in a high radiation area for the VF050A valve and the drain valve connections are also located in high radiation areas and contamination zones during outages as a result of SDC, significant radiation exposure can be received.

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VALVE REQUEST FOR RELIEF NO. 20 (COM'T)

ALTERNATE .

TESTING: The valves will be confirmed to close during every refueling outage. The valves are confirmed open each time the associated RHR loop is placed into g the normal shutdown cooling mode during reactor cold shutdown in accordance eith Relief Request

1. 62.

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i VALVE REOUEST FOR RELIEF NO. 24 i COMPONENT FUNCTION p1Agg ggi;9CEX

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See Various 2&3 C attached list TEST REOUIREMERT: Per IWV-3521, check valves shall be exercised at least once every three months.

Per IWV-3521, check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant i operation. Valves that cannot be exercised during l

plant operation shall be specifically identified by the Owner and be full-stroke exercised during cold shutdowns.

BASIS FOR RELIEF: For valves that cannot be exercised during plant operation as specifically identified in the Relief Request, the required full stroke exercise testing of the valves during normal operation would require the systems to be made inoperable. The design of the associated system in each case is such that normal test methods are inadequate to confirm the test results. The valves are either back-to-back with no test connection between them or the pipe segment cannot be isolated. Therefore, these valves cannot be individually tested and verified operable by normal testing methods. An internal visual inspection and manual exercise of the disk will verify operability. This disassembly requires a refueling outage in order to provide adequate time for planning and implementation without impacting plant startup.

Note: ASME OM Code-1990, Section ISTC 4.5.4(c) SB allows disassembly overy refueling outage as an alternative to quarterly testing using normal test methods.

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VALVE REQUEST FOR RELIEF liO. 24 (CON'T)

ALTERNATE TESTIlig -

An internal visual inspection and manual exercise of the check valve disk in accordance with the following schedules First refueling - all check valves listed.

Second and subsequent refueling = - a sampling of the list of check valves consisting of one(*) valve from each of the five designated l58 groups of valves which are grouped by similar design (manufacturer, size, model number and materials of construction) and having similar service conditions.

A dif ferent valve of each group is required to be disassembled, inspected and manually full-stroked at each refueling, until the entire group has been tested. If it is found that the disassembled valva's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.

(*Except for group 2 in which 2 valves will be 58 selected.)

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VALVE REOUEST FOR RELIEF NO. 24 (CON'T1 VALVE LIST VALVE TYPE ILIII QRRRE 1CCP*V337 1 2" 1 1CCP*V338 1 2" 1 1DFR*V78 2 4" 2 1DFR*V79 2 4" 2 1DFR*V87 2 4" 2 1DFR*V88 2 4" 2 1DFR*V97 2 4" 2 1DFR*V98 2 4" 2 1DFR*V107 2 4" 2 1DFR*V108 2 4" 2 1DFR*V117 2 4" 2 1DFR*V118 2 4" 2 1DFR*V127 2 4" 2 1DFR*V128 2 4" 2 1E12*VF084A,B,C (Note 1) 1 1.5" 3 1E12*VF085A,B,C (Note 1) 1 1.5" 3 1E51*VF030 3 6" 6 1HVK*V48 1 2" 1 1HVK*V97 1 2" 1 1LSV*V12 1 1" 4 ILSV*V35 1 1" 4 1LSV*V36 4 1" 9 1LSV*V42 1 1" 4 l

1LSV*V46 1 1" 4 1LSV*V72 4 1" 9 SB 1LSV*V76 4 1" 9 ILSV*V90 4 1" 9 i 1LSV*V114 1 1" 4 l 1LSV*V120 1 1" 4 ISVV*V122 1 1.5" 5 ISVV*V123 1 1.5" 5 i

1SVV*V129 1 1.5" 5 ISVV*V130 1 1.5" 5 ISSR*V705 1 1.5" 7 1SSR*V706 1 .75" 8 58 TYPE 1 - VCS060-A *13* Check valve 600 lb SW SA105 GR II CS body stellited trim bolted cap piston type integral seat 2 - VCWO15-E *33* Check valve spring loaded 150 lb BW SA105 CS body stellited trim bolted cap piston type renewable seat

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l VALVE REOUEST FOR RELIEF NO. 24 (CON'T) 3 - VCWO15-D *33* Check valve 150 lb BW A105 GR II CS body stellited trim -bolted cap swing type renewable seat .

4 - VCS150E *31* Check valve spring loaded 1500 lb SW SA105 GR II CS body stellited trim welded 58 cap piston-type integral seat Note 1: For these check valves between the line-fill pumps and the process lines only sna of the pa!rs of valves (i.e.

VF084A and VF085A) is required to be disassembled, inspected, and exercised. However, if the valve tested fails, then both of the valves-in-the pair need to be disassembled, tested, and reworked if necessary.  !

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VALVE REOUEST FOR RELIEF NO. 31 COMPONENT FUNCTION QLABA _C2 Egggy See Containment Isolation 1, 2 A or AC attached or 3 list IfdT REQUIREMENT: Per IW-3 4 21, Category A valves shall be leak tested per IW-3422 thru IW-3427.

BASIS FOR RELIEF: Containment isolation valve leak rate testing vill be conducted pursuant to Appendix J. The limitations of Appendix J shall be met. Adherence to these conditions limits overall leakage to less than that allowed by ASME IW-3 4 21-3 4 2 6.

Therefore, the River Bend Leak Rate Program will provide for a more limiting and a more conservative overall leak program.

The River Bend Leak Rate Program vill also proceduralize an administrative maximum allowable leak rate for all valves required to be type 'C' tested pursuant to 10CFR50 Appendix J. The program will also set administrative guidelines based on test results concerning performance of analysis of valve leak test results once a sufficient number of tests have been performed. This analysis will be used to determine predicted failures and rate of degradation if any. Rosults will be used to enhance predictive maintenance and allow River Band flexibility in order to comply with ALARA concerns and maximum utilization of resources. Guidelines will also be set as to maximum allowable predicted leak rate based on past performances. Corro*.ive ,

action shall be taken whenever a tested vs.1ve excoeds the maximum allowable leak rate 1o ,nt forth by the River Bend Leak Rate Prrgrm (Reference ANSI /ASME OM Code-1990, Section d0 58 4.3).

ALTERNATE TESTING: Conduct containment isolation valve leak rate testing program in accordance with 10CFR50 Appendix J and River Bend leak rate guidelines, complying b6 with the requirements of Section XI IW-3 4 2 6 and 3427(a). I l

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YALVE REOUEST FOR RELIEF NO. 31 (CON'Tl VALVE LIST

~1B21*VF010A,B 1E12*MOVF008 1821*AOVF032A,B 1E12*MOVF009 1821*MOVF016 1E12*MOVF011A,B 1CCP*V118 1E12*MOVF021 1CCP*V160 1E12*MOVF023 1CCP*MOV138 1E12*MOVF024A,B 1CCP*MOV158 1E12*MOVF027A,B 1CCP*MOV159 1E12*MOVF037A,B ICMS*SOV31A,B,C,D 1E12*MOVF042A,B,C 1 CMS *SOV35A,B,C,D 1E12*MOVF053A,B 1CNS*V86 1E12*MOVF064A,B,C 1CNS*MOV125 1E12*MOVF073A,B 1CPP*MOV104 1E12*MOVF105 1CPP*MOV105 1E12*AOVF006 1CPP*SOV140 1E21*MOVF001 1C11*VF122 1E21*MOVF005 1C11*MOVF083 1E21*MOVF011 1 DER *V4 1E21*MOVF012 1 DER *AOV126 1E21*AOVF005 1 DER *AOV127 1E22*MOVF004 1DFR*V180 1E22*MOVF012 1DFR*V181 1E22*MOVF015 1DFR*V182 1E22*MOVF023 1DFR*AOV101 1E22*AOVF065 1DFR*AOV102 1E51*AOVF066 1DFR*MOV146 1E51*MOVF013 1E12*VF044A,B 1E51*MOVF019 1E12*VF099A,B 1E51*MOVF031 1E12*AOVF041C 1E51*MOVF063 1E12*MOVF004A,B 1E51*MOVF064 l

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y& Lyn anonasr rom anLiar wo. si (COM'T1 YhLVE_ LIST IE51*MOVF068' 1SAS*MOV102 1E51*MOVF076-' 1SFC*V101 ,

1E51*MOVF077 1SFC*V350 1E51*MOVF078 1SFC*V351 l 1FPW*V263 ISFC*MOV119  !

1FPW*MOV121 ISFC*MOV120 l 1G33*MOVF001 ISFC*MOV121 1G33*MOVF004 1SFC*MOV122 i 1G33*MOVF028 - 1SFC*MOV139 1G33*MOVF034 ISSR*SOV130 1G33*MOVF039 1SSR*SOV131 1G33*MOVF040 1SSR*SOV139 1G33*MOVF053 ISVV*V9 1G33*MOVF054 1SVV*V31 1 1HVN*V541 ISVV*MOV1A,B 1HVN*V1316 ISWP*V174  !

1HVN*MOV102' 1SWP*V175 1HVN*MOV127 1SWP*MOV5A,8 1HVN*MOV128 1SWP*MOV81A,B IIAS*V80 1SWP*MOV503A,B ,

3IAS*MOV106 1SWP*MOV507A,B 1LMS*V12 1SWP*SOV522A,B,C,D ILMS*V14 1WCS*RV144 1LMS*V16 1WCS*RV154 1LMS*V7 1WCS*MOV172 1RHS*V240 1WCS*MOV178 ISAS*V486 i

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• e VALVE REQUEST FOR RELIEF NO. 36 SB l DELETED

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VALVE REQUEST FOR RELIEF NO. 44 COMPONE}{T FUNCTION CLASE. CATDOORY

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l 5B 1E12*RVF036 RHR relief valve for steam 2 C condensate supply to RCIC TJST REOUIREMENT: Per IWV-3511, relief valves shall be tested at the end of each time period as defined in Table IWV- SB 3510-1.

BASIS FOR RELIEF: The River Bend Station Operating License NPF-47, paragraph 2C(5)a prohibits the use of the Steam condensing Mode of RHR. The relief valve is 58 permanently isolated from any high pressure source.

ALTERNATE IESTING: No testing will be performed on this valve until the prohibition on using the Steam condensing Mode SB of RHR is lifted in our Operating License.

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VALVE _ REQUEST FOR.RELIX W Q u q 58 DELETED l

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• VALVE REQUEST _f.OR RELIEF NO. 58 COMPONENT FUNCTION gLAltg gBIgiggy ISWP*V326 ' Standby Service Water supply 3 C header loop A isolation check with Normal Service Water 1SWP*V327 Standby Service Water supply 3 C header loop B isolation check with Normal Service Water SB TEST REQUIREMENT: Per IWV-3411 and IWV-3521, Category A and B valves and check valves shall be exercised at least once overy three months.

BASIS FOR RELIEF: check valves V326 and V327 are verified open by normal plant operations. In order to test these valves closed it is necessary to secure the Normal Service Water loop resulting in the shutdown of essential equipment for the safe operation of the plant such as instrument air. As a minimum, this requires supplying a temporary backup instrument air compressor. In most shutdowns it would also be necessary to supply a temporary means of cooling the condensate pump which would be in service for RPV level control. For example, the normal service water headers to the drywell cooling units would be isolated. This would permit the drywell 58 temperature to exceed the Technical Specification limit, requiring a plant shutdown.

In a short shutdown these activities would be too extensive and difficult to set up. In a refueling l58 outage, these items are prearranged and can be carried out without risk to the plant or public.

j SB ALTERNATE TESTING: An exercise test for each valvo during every refueling outage.

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I VALVE REQUIST FOR RELIEF NO. 61 COMPONENT . FUNCTION QLApa CATD00RY 1SVV*V31 Main Steam Safety Relief 2 A/C 1SVV*V9 Valve accumulators instru-ment air supply check valves TEST REOUIREMENT: Per IWV-3521, check valves shall be exercised at least once overy three months.

BASIS FOR RELIEF: To test these check valves we would have to isolate the instrument lines to the following instruments:

ICMS*LT23A&B Suppression Pool Level Transmitters, 1E22*LTN055 C & G High Pressure Core Spray Level 5B Transmitters, and 1E51*LTNO36 A & E Reactor Core Isolation Cooling Level Transmitters. Isolation of these instruments during normal operation or cold shutdown would cause trips to the associated systems. In addition, any ECCS system is critical during plant operation and even during outages it is essential to minimize down time of these instruments.

ALTERNATE TESTING: Exercise during refuel outages by associated test connections and perform a Leak Test to verify valve closure for operability.

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VALVE REOUEET_FOR__ RELIEF NO. 62 (Cold Shutdown Justification)

COMPQ]iMliT FUNCTION CLASS ChTDOCRY 1E12 *VF004, D High pressure isolation 2 C chock for RHR shutdown cooling return line to

, reactor feedwater line L

IrdiI REOUIREMENT: Por IWV-3521, check valves shall be exercised at least once every three months.

i BASIS FOR 1 RELIEF: The RHR system head is inadequate to open the j valves against feedwater operating pressure. The valves are opened when the RHR system is placed into the shutdown cooling (SDC) mode during ~1 ant shutdowns. To verify the valves close duri .g A 2 shutdewns would require ~3e shutdown cool w np of the RHR system to be made inoperable. 5B Technical Specification 3.4.9.2 requires m i i loops of SDC to be available or at least ma alternate available for each inoperable .p.

Because of decay heat, it requires at least 30 days for an alternate method such as RWCU or fuel pool cooling to be able to handle the existing heat loads for SDC. During refueling cutages, this

.. requirement is reduced to one loop of SDC when the Technical Specification does permit one loop to be made inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for testing.

i However, because of the difficulty and time required in performing this test using hoses

• - connected for drain down of the column of water beneath the valve in order to verify disk closure, Operations personnel will agi permit this testing as a conservative measure.

This test cannot be accomplished with the loop in SDC. In addition, a significant volume of contaminated water is released to radwaste.

Finally, since the drain hub is located in a high radiation area for the VF050A valve and the drain valve connections cra also located in high radiation areas and contamination zones during outages as a result of SDC, significant radiation exposure can be received.

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,L VALVE REQUEST FOR RELIEF NO. 62 ICON'T)

(Cold shutdown Justification)

ALTERNATE TESTING:- That the valves (open position) are_ verified during

old shutdowns each time the associated RHa loop is SB placed into the normal shutdown cooling mode during the reactor shutdown. The valves will be confirmed

-to close during every refueling outage per Raelief Request #20.

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• VALVE REQUEST FOR RELIEF NO. 63 (Cold shutdown Justification)

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COMPONENT EVEQTION plMg gA12pggy 1SWP*MOV57A,B Standby Service Water supply 3 B header isolation with Normal Service Water TEST REQUIREMENT: Per IWV-3411 and IWu-3521, Category B valves shall be exercised at least once every three months.

5B BASIS FOR RELIEE: Stroke and exercise testing of chese valves during cold shutdown would require a RHR loop to be inoperable which would result in a Technical Specification Limiting Condition for Operation and would disrupt Normal Service Water to operating equipment.

ALTERNATE TESTING: An exercise test for each valve during every cold shutdown when Service Water loads can be minimal.

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