ML20057E475

Submits Inquiry OM Part 1-1987 BWRs,2.1 Scope

ML20057E475
Person / Time
Site:	Perry
Issue date:	09/08/1993
From:	Seman S CLEVELAND ELECTRIC ILLUMINATING CO.
To:	AMERICAN SOCIETY OF MECHANICAL ENGINEERS
References
NUDOCS 9310120189
Download: ML20057E475 (2)

Text

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J f THE CLEVELAND ELECTR PO. box 97 m PERRY. Ohio 44081 s 5

TELEPHONE (216) 259-3737 FRoM CLEVELAND: 479-1260 5 ADDRESS-10 CENTER ROAD i

j Serving The Best location in the Nation PERRY NUCLEAR POWER PLANT September 8, 1993 N.

Secretary Committee on Operation and Maintenance of Nuclear Power Plants The American Society of Mechanical Engineers 345 East 47th Street i New York, NY 10017 i Subj ect: Submittal of Inquiry, OM Part 1-1967 Boiling Vater Reactors, 2.1 Scope Scope: When applying OM Part 1 1 2.1(a) the rules and requirements for inservice performance testing of Main Steam Pressure Relief Valves Vith Auxiliary Actuating Devices for boiling vater reactor nuclear power plants are the statud inservice performance tests all inclusive for verifying valve ope.ational readiness?

Background:

At a recent (feptember 2, 1993) meeting with NRR Mechanical Engineering Branch the NRC stated that their position was that Main Steam Prs.ssure Relief Valves with Auxiliary Actuating Devices must satisfy the exercise and stroke time test requirements for Category 'A' valves. The utility presented the argument that all the inservice performance tests required for Main Steam Pressure Relief Valves with Auxiliary Actuating Devices were detailed within OM Part 1. The NRC did not agree with the argument. NRR is enforcing the requirement to stroke time these valves to monitor for degrading conditions.

l The utility presented that the rule change (September 8, 1992) to 10CFR50.55a Codes and Standards endorses OM Part 4, OM Part 6 and OM Part 10. 10CFR50.55a(b)(2)(viii) States" (viii)Section XI References to OM Part 4, OM Part 6 and OM Part 10 (Table IVA-1600-1). When using Table IVA-1600-1, " Referenced Standards and Specifications" in the Section XI, Divisica 1, 1987 l Addenda, 1988 Addenda, or 1989 Edition, the specified )

" Revision Date or Indicator" for ASME/ ANSI OM Part 4,  !

ASME/ ANSI Part 6, and ASME/ ANSI Part 10 shall be the  !

OMa-1988 Addenda to the OH-1987 Edition." l l

A position was developed applying the OM Part 10 requirements l to justify not stroke timing these valves. The position identified Main Steam Pressure Relief Valves with Auxiliary l Actuating Devices as Category 'AC' per OM Part 10 1 1.4. Then hhoc 9310120189 930908 y/ L PDR ADOCK 05000440 -

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• a Page 2 the requirements for inservice tests delineated within OM Part 10 Table 1, Category C (Safety and Relief) includes; a Leakage Test Procedure, Exercise Test Procedure and Position Indication Verification. The table specifies the following to satisfy these concerns:

1. Leakage Test Procedure - None, with Note 2 being applicable. " Note (2): When more than one distinguishing category characteristic is applicable, all requirements of -

each of the individual categories are applicable, although  ;

duplication or repetition of common testing requirements '

is not necessary."

2. Exercise Test Procedure - See Para. 4.3.1 which states" Safety and relief valves shall meet the inservice test requirements of Part 1."

3. Position Indication Verification - See Para- 4.1.

The conclusion was that Category 'A' leak tightness was covered under Note (2) and stroke timing was not applicable because the  :

exercise test procedure does not specify Note (2). i l

The closing argument presented to NRR was that Main Steam i Pressure Relief Valves with Auxiliary Actuating Devices design provides no effective method to stroke time in accordance with j Code. Therefore the valve's response in milliseconds and '

applying minimum timing errors in tenths of a second would  !

provide meaningless data. The meeting generated this inquiry.

1 Inquiry: When applying OM Part 1 1 2.l(a) the rules and requirements for inservice performance testing of Main Steam Pressure Relief Valves with Auxiliary Actuating Devices for boiling water reactor nuclear power plants are the stated inservice performance tests all ,

inclusive for verifying valve operational readiness? l Reply: Yes Code Change: Clarify OM Part 1 1 2.l(a) as follows: "

This section defines all the rules and requirements for performance testing of pressure relief devices to verify the device's o;erational readiness for boiling vater reactor nuclear plants."

Sincerely, Scott Seman Lead ISI Engineer i Mail Zone - TP3 (216) 259-3737 Ext. 7662 SH/ev l

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