Safety Evaluation Accepting Relief Request 98-01 for Catawba Nuclear Station Units 1 & 2 from Requirements of ASME Boiler & PV Code for Second 10-year Interval Program for Inservice Testing of Pumps & ValvesML20216E177 |
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04/13/1998 |
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NRC (Affiliation Not Assigned) |
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ML20216E102 |
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NUDOCS 9804160121 |
Download: ML20216E177 (5) |
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Category:SAFETY EVALUATION REPORT--LICENSING & RELATED ISSUES
MONTHYEARML20211A9791999-08-20020 August 1999 Safety Evaluation Granting Licensee Request for Approval of Proposed Relief from Volumetric Exam Requirements of ASME B&PV Code,Section Xi,For Plant,Unit 2 ML20209E4361999-07-0909 July 1999 SER Agreeing with Licensee General Interpretation of TS LCO 3.0.6,but Finds No Technical Basis or Guidance That Snubbers Could Be Treated as Exception to General Interpretation ML20196K6631999-07-0707 July 1999 Safety Evaluation Supporting Licensee 990520 Position Re Inoperable Snubbers ML20206P5201999-05-14014 May 1999 Safety Evaluation Accepting GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20205S5551999-04-21021 April 1999 Safety Evaluation Accepting Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20205N3651999-04-12012 April 1999 Safety Evaluation Accepting IPE of External Events Submittal ML20196J8351998-12-0808 December 1998 Safety Evaluation Granting Relief Request Re Relief Valves in Diesel Generator Fuel Oil Sys ML20196C0251998-11-27027 November 1998 SER Accepting Clarification on Calibration Tolerances on Trip Setpoints for Catawba Nuclear Station ML20196A6881998-11-25025 November 1998 Safety Evaluation Granting Relief Request 98-02 Re Limited Exam for Three Welds ML20247M0861998-05-21021 May 1998 SER Accepting 1997 Rev to Catawba UFSAR Submitted on 970925. Rev Added Analysis for Postulated Accident Involving Dropping of Sf Pool Weir Gate Onto Sf Assemblies ML20216E1771998-04-13013 April 1998 Safety Evaluation Accepting Relief Request 98-01 for Catawba Nuclear Station Units 1 & 2 from Requirements of ASME Boiler & PV Code for Second 10-year Interval Program for Inservice Testing of Pumps & Valves ML20217M4211998-04-0303 April 1998 Safety Evaluation Approving Request for Relief 97-04, non-code Repair Valves.Relief Granted Retroactively to Unit 1 & Expired Dec 1997.Relief for Unit 2 Will Expire at End of Cycle 9 Outage or Next Scheduled Outage Exceeding 30 Days ML20199A5521998-01-22022 January 1998 Safety Evaluation Re Licensee Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves, for Cns,Units 1 & 2 ML20199A6421998-01-22022 January 1998 Safety Evaluation Accepting Proposed EALs Changes for Plant, Units 1 & 2.Concludes That Changes Consistent W/Guidance in NUMARC/NESP-007,w/variations as Identified & Accepted in Review & Meets Requirements of 10CFR50.47(b)(4) ML20198P9641998-01-15015 January 1998 SE Granting Relief Request 97-03 for Second 10-yr Interval Inservice Insp Program ML20198R9951997-10-30030 October 1997 Safety Evaluation Authorizing Request for Approval of Alternative to Exam Requirement of Reactor Vessel Shell Weld,Per 10CFR50.55a(g)(6)(ii)(A)(5) ML20198J7651997-10-15015 October 1997 Safety Evaluation Accepting 10-yr Interval Insp Program Plan Alternatives for Listed Plants Units ML20211F8801997-09-22022 September 1997 Safety Evaluation Supporting Second ten-year Interval Inservice Inspection Program Plan & Associated Requests for Relief for Catawba Nuclear Station Unit 1 ML20149K8281997-07-29029 July 1997 SER Granting Request for Exemption from Requirements of 10CFR70.24 for Units 1 & 2 ML20141E1121997-06-16016 June 1997 Safety Evaluation Approving Licensee Position That UFSAR Table 6-77 Be Revised to Identify SA-1 & SA-4 Instead of SA-3 & SA-6 as Containment Isolation Valves ML20148H2501997-06-0505 June 1997 Safety Evaluation Accepting Proposed Restructuring of Util Through Acquisition Of,& Merger W/Panenergy Corp ML20141G6701997-05-20020 May 1997 Safety Evaluation Accepting Proposed Alternative Use of TS Requirement for Code Class Snubbers ML20135B3051997-02-27027 February 1997 Safety Evaluation Granting Second 10 Yr ISI Program Plan & Associated Requests for Relief ML20134P2421997-02-20020 February 1997 Safety Evaluation Accepting TR BAW-10199P for Ref in Plants Licensing Documentation & Use in Licensing Applications ML20134L4081996-11-19019 November 1996 SER Accepting Performance of Plant Standby Nuclear Svc Water Pond ML20134G5551996-11-0707 November 1996 Safety Evaluation Accepting Proposed Application of BWU-Z CHF Correlation for Plants Mark-BW 17x17 Type Fuel ML20129E4851996-10-0101 October 1996 Safety Evaluation Recommending That Relief Request 96-02 Be Granted,Per 10CFR50.55a(g)(6)(i),per Request ML20056D9611993-07-30030 July 1993 SER Accepting Licensee 930325-0429 Submittals of Technical Info to Support Continued Operation of Facility for Remainder of Fuel Cycle 7 ML20055H9151990-07-27027 July 1990 Safety Evaluation Accepting Actions Taken to Resolve NRC Bulletin 88-002, Rapidly Propagating Fatigue Cracks in Steam Generators Tubes ML20248C0731989-08-0303 August 1989 Sser Accepting 880601,0909 & 890602 Changes to ATWS Mitigation Sys Actuation Circuitry for Plants ML20246L4221989-05-12012 May 1989 Safety Evaluation Supporting Revs 15 & 6 to Pump & Valve Inservice Testing Program & Relief Requests ML20150C2651988-06-28028 June 1988 Safety Evaluation Supporting Licensee Assessment to Fracture Toughness Requirements for Protection Against PTS Events,Per 10CFR50.61 ML20150C2611988-06-28028 June 1988 Safety Evaluation Supporting Licensee Assessment to Fracture Toughness Requirements for Protection Against PTS Events,Per 10CFR50.61 ML20154H2171988-05-18018 May 1988 Safety Evaluation Accepting Util 880414 Submittal Re Reload Startup Physics Test Program ML20148H1001988-01-22022 January 1988 Safety Evaluation Supporting Util 871113 Proposed Tech Spec Changes Reflecting Unit 2 Cycle 2 Refueling & Addition of Boron Dilution Mitigation Sys for Unit 2 ML20236M9631987-11-0606 November 1987 Safety Evaluation Accepting Util Proposed ATWS Mitigating Sys Actuation Circuitry for Facilities,Per 10CFR50.62(c)(1) & Pending Final Resolution of Tech Spec Issue ML20236D4451987-09-30030 September 1987 SER Re Licensee 870814 & 21 Responses Re Single Failure Potential in Nuclear Svc Water Sys.Nuclear Svc Water Sys Meets Requirements of GDC 5 & 44 Re Sharing & Provisions for Suitable Redundancy in Cooling Water Sys ML20236F5881987-07-29029 July 1987 Safety Evaluation Supporting Util 831104,841102,1231 & 851203 Responses to Items 3.1.1,3.1.2,3.2.1,3.2.2 & 4.5.1 of Generic Ltr 83-28 ML20215D2701987-06-11011 June 1987 SER Accepting Rev 13 to Unit 1 & Rev 4 to Unit 2 Pump & Valve Inservice Testing,Per Generic Ltr 83-28,Item 2.1 (Part 2) ML20214T4061987-06-0202 June 1987 Safety Evaluation Supporting Util 860424 Submittal Re Turbine Sys Maint Program for Early Detection of Cracking in Low Pressure Turbine Wheels ML20214M3361987-05-22022 May 1987 Safety Evaluation Supporting Util Rept Entitled, Rod Swap Methodology Rept for Startup Physics Testing ML20209B1511987-01-28028 January 1987 SER Supporting Util Responses to Generic Ltr 83-28,Item 4.5.2 Re Reactor Trip Sys on-line Testing ML20207Q5851987-01-15015 January 1987 SER Re Generic Ltr 83-28,Item 2.1 (Part 2) Concerning Vendor Interface Programs for Reactor Trip Sys Components.Util Response Acceptable.Item Closed ML20207N3011987-01-0808 January 1987 Safety Evaluation on Util 830309 & 851025 Requests for Relief from 10CFR50.55a Requirements Re Pump & Valve Inservice Testing Program.Relief Granted W/Listed Exceptions ML20207P6341986-08-31031 August 1986 Safety Evaluation Accepting Util 851120 & 860324 Proposals to Eliminate Arbitrary Intermediate Pipe Breaks in Select List of High Energy Piping Sys ML20199L3941986-07-0202 July 1986 SER Providing Final Conclusions & Recommendations from Evaluation of Tdi Owners Group Program to Validate & Update Quality of Tdi Diesel Generators ML20211E4251986-06-10010 June 1986 Draft SER Re Util 850624 Response to Generic Ltr 83-28,Items 4.1,4.2.1 & 4.2.2 Re Preventive Maint Program for Reactor Trip Breakers/Maint & Trending.Position on Item 4.1 Acceptable.Position on Items 4.2.1 & 4.2.2 Unacceptable ML20207T4241985-12-30030 December 1985 SER Re SPDS Based on Documentation & 850513-15 Audit.Spds Does Not Fully Meet Requirements of Suppl 1 to NUREG-0737. Five Listed Variables Should Be Added to Spds.Interim Implementation Acceptable ML20138M9011985-12-17017 December 1985 Draft SER on Util 850329 Response to 841003 Request for Addl Info Re Hydrogen Control Measures for Plant.Addl Info & Analyses Required Re Effect of Upper Compartment Burns on Air Return Fan ML20128F9921985-06-21021 June 1985 SER Based on Util 831104 Response to Generic Ltr 83-28,Item 1.1 Re post-trip Review Program Description & Procedures. Program & Procedures Acceptable 1999-08-20
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML20217H0201999-09-30030 September 1999 Monthly Operating Repts for Sept 1999 for Catawba Nuclear Station,Units 1 & 2 ML20216E5401999-09-0707 September 1999 Special Rept:On 990826,discovered That Meteorological Sys Upper Wind Speed Cup Set Broken,Causing Upper Wind Channel to Be Inoperable.Cup Set Replaced & Channel Restored to Operable Status on 990826 ML20212B4711999-08-31031 August 1999 Monthly Operating Repts for Aug 1999 for Catawba Nuclear Station,Units 1 & 2 ML20217H0321999-08-31031 August 1999 Revised Monthly Operating Rept for Aug 1999 for Catawba Nuclear Station,Units 1 & 2 ML20211B1281999-08-31031 August 1999 Dynamic Rod Worth Measurement Using Casmo/Simulate ML20211A9791999-08-20020 August 1999 Safety Evaluation Granting Licensee Request for Approval of Proposed Relief from Volumetric Exam Requirements of ASME B&PV Code,Section Xi,For Plant,Unit 2 ML20211F3441999-08-17017 August 1999 Updated non-proprietary Page 2-4 of TR DPC-NE-2009 ML20211C1291999-08-17017 August 1999 ISI Rept Unit 1 Catawba 1999 RFO 11 ML20210R1051999-08-0606 August 1999 Special Rept:On 990628,cathodic Protection Sys Was Declared Inoperable After Sys Did Not Pass Acceptance Criteria of Bimonthly Surveillance.Work Request 98085802 Was Initiated & Connections on Well Anode Were Cleaned or Replaced ML20210S2891999-07-31031 July 1999 Monthly Operating Repts for July 1999 for Catawba Nuclear Station,Units 1 & 2 ML20212B4871999-07-31031 July 1999 Revised Monthly Operating Rept for July 1999 for Catawba Nuclear Station,Units 1 & 2 ML20209E4361999-07-0909 July 1999 SER Agreeing with Licensee General Interpretation of TS LCO 3.0.6,but Finds No Technical Basis or Guidance That Snubbers Could Be Treated as Exception to General Interpretation ML20196K6631999-07-0707 July 1999 Safety Evaluation Supporting Licensee 990520 Position Re Inoperable Snubbers ML20210S2951999-06-30030 June 1999 Revised Monthly Operating Rept for June 1999 for Catawba Nuclear Station,Units 1 & 2 ML20209H4501999-06-30030 June 1999 Monthly Operating Repts for June 1999 for Catawba Nuclear Station,Units 1 & 2 ML20209H4561999-05-31031 May 1999 Revised Monthly Operating Rept for May 1999 for Catawba Nuclear Station,Units 1 & 2 ML20206T4771999-05-31031 May 1999 Rev 3 to UFSAR Chapter 15 Sys Transient Analysis Methodology ML20196L1881999-05-31031 May 1999 Non-proprietary Rev 1 to DPC-NE-3004, Mass & Energy Release & Containment Response Methodology ML20196A0001999-05-31031 May 1999 Monthly Operating Repts for May 1999 for Catawba Nuclear Station,Units 1 & 2 ML20206P5201999-05-14014 May 1999 Safety Evaluation Accepting GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20206N8391999-05-0404 May 1999 Rev 16 to CNEI-0400-24, Catawba Unit 1 Cycle 12 Colr ML20206R1811999-04-30030 April 1999 Monthly Operating Repts for Apr 1999 for Catawba Nuclear Station,Units 1 & 2 ML20196A0041999-04-30030 April 1999 Revised Monthly Operating Repts for Apr 1999 for Catawba Nuclear Station,Units 1 & 2 ML20206N8261999-04-22022 April 1999 Rev 15 to CNEI-0400-24, Catawba Unit 1 Cycle 12 Colr. Page 145 of 270 of Incoming Submittal Not Included ML20205S5551999-04-21021 April 1999 Safety Evaluation Accepting Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20205N3651999-04-12012 April 1999 Safety Evaluation Accepting IPE of External Events Submittal ML18016A9011999-04-12012 April 1999 Part 21 Rept Re Defect in Component of DSRV-16-4,Enterprise DG Sys.Caused by Potential Problem with Connecting Rod Assemblies Built Since 1986,that Have Been Converted to Use Prestressed Fasteners.Affected Rods Should Be Inspected ML20206R1931999-03-31031 March 1999 Revised Monthly Operating Repts for Apr 1999 for Catawba Nuclear Station,Units 1 & 2 ML20205P9521999-03-31031 March 1999 Monthly Operating Repts for Mar 1999 for Catawba Nuclear Station,Units 1 & 2 ML20205P9561999-02-28028 February 1999 Revised Monthly Operating Repts for Feb 1999 for Catawba Nuclear Station,Units 1 & 2 ML20204C9111999-02-28028 February 1999 Monthly Operating Repts for Feb 1999 for Catawba Nuclear Station,Units 1 & 2 ML20203A2581999-02-0505 February 1999 Safety Evaluation of TR DPC-NE-3002-A,Rev 2, UFSAR Chapter 15 Sys Transient Analysis Methodology. Rept Acceptable. Staff Requests Duke Energy Corp to Publish Accepted Version of TR within 3 Months of Receipt of SE ML20204C9161999-01-31031 January 1999 Revised Monthly Operating Repts for Jan 1999 for Catawba Nuclear Station,Units 1 & 2 ML20199K8711999-01-13013 January 1999 Inservice Insp Rept for Unit 2 Catawba 1998 Refueling Outage 9 ML20199E3071998-12-31031 December 1998 Monthly Operating Repts for Dec 1998 for Catawba Nuclear Station,Units 1 & 2 ML20216F9931998-12-31031 December 1998 Piedmont Municipal Power Agency 1998 Annual Rept ML20205E9441998-12-31031 December 1998 1998 10CFR50.59 Rept for Catawba Nuclear Station,Units 1 & 2, Containing Brief Description of Changes,Tests & Experiments,Including Summary of Ses.With ML20206P2081998-12-31031 December 1998 Special Rept:On 981218,inoperability of Meteorological Monitoring Instrumentation Channels,Was Observed.Caused by Data Logger Overloading Circuit.Replaced & Repaired Temp Signal Processor ML20203A4101998-12-22022 December 1998 Rev 16 to CNEI-0400-25, Catawba Unit 2 Cycle 10 Colr ML20203A4041998-12-22022 December 1998 Rev 14 to CNEI-0400-24, Catawba Unit 1 Cycle 11 Colr ML20198B1341998-12-14014 December 1998 Revised Special Rept:On 980505,discovered That Certain Fire Barriers Appeared to Be Degraded.Caused by Removal of Firestop Damming Boards.Hourly Fire Watches Established in Affected Areas ML20196J8351998-12-0808 December 1998 Safety Evaluation Granting Relief Request Re Relief Valves in Diesel Generator Fuel Oil Sys ML20199E3221998-11-30030 November 1998 Revised MOR for Nov 1998 for Catawba Nuclear Station,Units 1 & 2 Re Personnel Exposure ML20198E3151998-11-30030 November 1998 Monthly Operating Repts for Nov 1998 for Catawba Nuclear Station,Units 1 & 2 ML20196C0251998-11-27027 November 1998 SER Accepting Clarification on Calibration Tolerances on Trip Setpoints for Catawba Nuclear Station ML20196A6881998-11-25025 November 1998 Safety Evaluation Granting Relief Request 98-02 Re Limited Exam for Three Welds ML20196D4041998-11-19019 November 1998 Rev 1 to Special Rept:On 980618,determined That Method Used to Calibrate Wind Speed Instrumentation Loops of Meteorological Monitoring Instrumentation Sys Does Not Meet TS Definition for Channel Calibration.Procedure Revised ML20195E5521998-10-31031 October 1998 Monthly Operating Repts for Oct 1998 for Catawba Nuclear Station,Units 1 & 2 ML20198E3261998-10-31031 October 1998 Revised Monthly Operating Repts for Oct 1998 for Catawba Nuclear Station,Units 1 & 2 ML20154M7661998-10-12012 October 1998 LER 98-S01-00:on 980913,terminated Vendor Employee Entered Protected Area.Caused by Computer Interface Malfunction. Security Retained Vendor Employee Badge to Prevent Further Access & Computer Malfunction Was Repaired.With 1999-09-07
[Table view] |
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@ ttioq g +4 UNITED STATES g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30866 0001
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l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l OF THE SECOND 10-YEAR INTERVAL INSERVICE TESTING PROGRAM j
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REQUESTS FOR RELIEF NO. 98-01 DUKE ENERGY CORPORATION l CATAWBA NUCLEAR STATION. UNITS 1 AND 2 I
DOCKET NOS. 50-413 AND 50-414
1.0 INTRODUCTION
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Title 10 of the Code of Federal Reaulations (10 CFR) Section 50.55a, requires that inservice
' l testing (IST) of certain American Society of Mechanical Engineers (ASME) Code Class 1,2, j and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and j Pressure Vessel Code (ASME Code) and applicable addenda, except where relief has been J
requested and granted or proposed alternatives have been authorized by the Commission pursuant to 10 CFR 50.55a (f)(6)(i), (a)(3)(i), or (a)(3)(ii). In order to obtain authorization or :
relief, the licensee must dernonstrate that: (1) conformance is impractical for its facility; (2) the proposed altemative provides an acceptable level of quality and safety; or (3) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Guidance related to the development and implementation of IST programs is given in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," issued April 3,1989, and its Supplement 1, issued April 4,1995. Also, see NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Phnts," which was promulgated by GL 89-04, Supplement 1.
Section 50.55a authorizes the Commission to grant relief from ASME Code requirements or to approve proposed alternatives upon making the necessary findings. Pursuant to 50.55a(f)(6)(i),
the Commission may grant relief and impose attemative requirements as it determines are authorized by law and will not endanger life or property or the common defense and security i and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
i By letter dated January 22,1998, Duke Energy Corporation (the licensee) submitted Relief l Request No. 98-01 for the Catawba Nuclear Station, Units 1 and 2, second 10-year interval program for inservice testing of pumps and valves. The licensee's IST program covers the second 10-year IST intervals that began December 29,1995, for both units. The IST program i Enclosure 9804160121 980413 i PDR ADOCK 05000413 t
P PDR
is based on the requirements of the 198g Edition,Section XI, of the ASME Code, which by reference incorporates Part 6, " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10 " Inservice Testing of Valves in Light-Water Reactor Power Plants," of the ASME Operations and Maintenance Standard OM-1988.
2.0 DISCUSSION AND EVALUATION 2.1 Diesel Generator Fuel Oil System Valves 1FD34, 2FD34,1FD74, and 2FD74 The licensee requested relief from the requirements of OM-1, paragraph 1.3.4.1, which specifies testing requirements for Class 2 and 3 pressure relief devices. Specifically, the licensee requested relief from bench testing the diesel generator engine retum header relief valves 1FD34,2FD34,1FD74, and 2FD74.
The licensee states:
The subject valves perform a dual function of regulating fuel pressure to the diesel generator engine and providing overpressure protection of the fuel oil retum line from the main circulation header. Each valve is physically located above its corresponding diesel generator fuel oil day tank. The valves are set to regulate fuel oil pressure at a maximum value of 40 psig. With the diesel generator running, the valve relief pressure setpoint maintains a backpressure of )
40 psig on the main circulation header. The valve will lift to relieve pressure in excess of 40 psig, thereby fulfilling both its regulation and overpiassure protection functions. They are 1-inch valves manufactured by Fultlo Specialties Company.
OM-1 requires that relief valves in applications such as this be periodically removed from service and bench tested using the respective fluid medium for the valve (in this case, fuel oil).
The licensee is seeking relief from OM-1, paragraph 1.3.4.1, Pressure Relief Valves. This paragraph specifies testing requirements for Class 2 and 3 pressure relief devices. The licensee is requesting relief from the requirement to bench test the subject valves, stating:
Catawba does not presently have a test bench to allow testing of the subject valves. Procurement of a separate test bench for these four valves would be impractical and would not provide sny additional assurance of the valves' ability to perform their design function. This ability can be successfully demonstrated by attemate testing as discussed below.
' The licensee proposes:
Diesel generator fuel oil pressure will be verified monthly during the diesel
' generator performance test. The monthly test, conducted according to procedures PT/1&2/A/4350/02A&B, D/G Operability Test, for Units 1 and 2 and
i i
diesel generators A 'and B, respectively, verifies both the pressure regulating and overpressure protection functions of the subject valves. These procedures perform the monthly diesel generator run during which fuel oil recirculation ;
header pressure is monitored. Procedure MP/0/A/7700/21, Diesel Engine Fuel Oil Back Pressure Relief Valve Corrective Maintenance, is performed after outage diesel generator maintenance to adjust the subject valves to the required i 40 psig backpressure. l l
Verification of the subject valve functions (pressure regulating and overpressure i protection) as part of the diesel generator performance test will provide complete assurance of the valves' ability to perform as designed. The valves will be tested - . .- -
under the actual conditions for which they are expected to operate; hence, their system functions can be directly verified. No adverse impact upon public health and safety will be generated from a radiological or other standpoint.
Contrary to what is indicated in the licensee's relief request, bench testing is not a Code requirement. OM-1, paragraph 1.3.1.3, states that "it is not a requirement of this part that valves or accessories be removed from their installed position or disassembled." Therefore, the staff concludes that relief from bench testing is not required. if the proposal to test the valves in place as part of the monthly diesel generator performance test is not consistent with OM-1 requirements, the licensee should refer to the NRC's guidance in NUREG-1482, Section 3.4, " Skid-Mounted Components and Components Subassemblies," and submit a relief request with sufficient detaiis relative to attemative testing, i.e., testing the valves in place. ;
i 2.2 Diesel Generator Engine Starting Air Check Valves 1/2VG5&7,1/2VG6&8,1/2VG49&51, !
and 1/2VG50&52 i L
The licensee requested relief from the requirements of OM-10, paragraph 4.3.2.2, which specifies that each valve shall be exercised or examined in a manner that verifies obturator { '
travel to the required position. The licensee a!so requested relief from the requirement to individually test diesel generator starting air dryer discharge check valves 1/2VG5&7, 1/2VG6&8,1/2VG49&51, and 1/2VG50&52. l l The licensee states:
Each valve in the above-listed pair works together with its in-series counterpart i' to prevent depressurization of the respective normally-charged diesel generator i engine starting air tank. Each valve opens as necessary during normal operation to recharge the tank when the respective diesel generator is not in operation.
Each valve must open during diesel generator operation to recharge the tank, if necessary. These valves are 1-inch Kerotest soft-seat check valves. They are located between their respective air dryer and the starting air tank.
These valves are required to be full-stroked exercised every three months to the position required to fulfill their function.
. .o I
4 ASME Code requirements dictate that each valve in the above-described pairs of valves be separately tested and be determined capable of fulfilling its design function. ASME/ ANSI OM-1987 Edition, Part 10, including OMa-1988, paragraph 4.3.2.2, specifies that each valve shall be exercised or examined in a manner which verifies obturator travel to the required position. Due to the series system valve arrangement, Catawba has no means to separately verify each valve's ability to close. Catawba therefore requests relief from the ASME Code requirement specifying that each valve be individually tested.
The licensee proposes:(as stated)
(
. i Valve pairs (1/2VG5&7,1/2VG6&8,1/2VG49&51, and 1/2VG50&52) will be tested at least quarterly. This test will be conducted according to procedures PT/1&2/A/4200/077, VG Valve Inservice Test, for Units 1 and 2, respectively.
The purpose of this test is to check the backleakage through each valve pair with
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the diesel generator secured. A starting air tank pressure decrease of greater j than 5 psig in a 10-minute period would indicate excessive leakage through the l valve pair and would require corrective action upon detection of such a condition. !
Both valves in the affected pair will be inspected for degradation and repaired as l appropriate should such a condition be detected.
Testing of the above described valve pairs as indicated above will verify the ability of the pair to perform its design function. Both valves in each pair are not i required to be capable of functioning separately in order for the diesel generator to function property, No adverse impact upon the health and safety of the public, either from radiological consequences or otherwise, will be created as a result of the proposed attemative testing.
i The check valves 1/2VG5&7,1/2VG6&8,1/2VG49&51, and 1/2VG50&52 (two in series) have a -
l safety function to prevent a depressurization of the normally charged diesel generator engine starting air tank and to open as necessary to recharge the tank when the diesel generator is not i
- in operation. The Code requires valves performing safety functions to be stroked to the position (s) required for the valves to perform those functions; however, the licensee stated that
' the current system design does not allow testing to ensure both valves in series will close.
The guidance in NUREG-1482, Section 4.1.1, addresses testing series check valve pairs as a unit. If only one of the redundant series valves is credited in the safety analysis (that is, the other could be removed without creating an unreviewed safety question or creating a conflict l with regulatory or license requirements), then verification that the group of valves is capable of l' performing the required function should be acceptable for inservice testing. On this basis, all group check valves must be included in the IST program and be subject to equivalent quality f- assurance criteria. Testing is required during each quarter or at an extended interval in accordance with the Code. If the licensee finds indication that the closure capability of the group of valves is questionable, all valves in the group must be declared inoperable and corrective actions taken for all valves, as necessary, before being returned to service.
Inservice testing of series valves as a pair cannot be used as an attemate means of verifying leak-tightness (Category A/C valves). Inservice testing to verify the closure of serics check
(
l v
l valves as a pair does not enable the licensee to verify the operational readiness of each component as intended in the Code because this testing method would not detect if one valve l
of the pair failed open.
The iicensee's proposed attemative testing conforms with the guidance provided in NUREG-1482, Section 4.1.1. Under these conditions, the requirements of the Code are i
, impractical as the system design does not allow individual testing to ensure the series check l valves will close imposition of the Code would require redesign of the system or replacement of the components to allow individual valve testing. The staff finds that the proposed attemative testing provides reasonable assurance of operational readiness conssitent with NUREG-1482,
? Section 4.1.1. - - -
l The staff determine that the licensee's proposal provides reasonable assurance of operational
! readiness, and that the requirements of the Code are impractical. Pursuant to 10 CFR j 50.55a(f)(6)(i), the requested altemative with regard to testing the diesel generator starting air dryer discharge check valves, is granted. The relief granted is authorized by law and will not endanger life or property or the commori defense and security, and is otherwise in the public interest giving due consideration to the burden that could result if the requirements are imposed on the facility.
Principal Contributor: K. Dempsey Date: April 13, 1998 l
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