ML20212D685
| ML20212D685 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/22/1986 |
| From: | Frisch R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8701020158 | |
| Download: ML20212D685 (35) | |
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@rowsmaus ABEdlMAN'5 PRSENE55 Power oenerei Offices: 1946 West Parnali Road, Jackson, M149201. (517) 788-0550 December 22, 1986 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK FOINT PLANT -
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PUMP AND VALVE INSERVICE TESTING PROGRAM Nuclear Regulatory Commission letter dated October 15, 1986 requested Consum-ers Power Company to reconsider certain relief requests made in previous Inservice Testing Program submittals and to provide any additional information deemed necessary to reduce program inconsistencies and omissions that were discussed during a September 3, 1986 conference call.
Attachment 1 provides our responou to the program anomalies identified in Appendix D of the Technical Evaluation Report which was provided with the
.! October 15, 1986 NRC letter.
Because considerable time has lapsed since our original Inservice Testing Program submittal and because of our responsas to program anomalies in Attach-ment 1, we have reviewed all of the previously submitted relief requests. For your convenience, all of the relief requests applicable to our program have been included in Attachment 2. All of the proposed changes made as a result of this review are itemized in Attachment 2. This listing supersedes all previous relief request submittals. The sont significant change is the frequency of pump testing is being chenged from monthly to once every three months as allowed by Article IWP-3400 of the 1980 ASME Section XI edition.
This change will allow pumps and valves to be tested on the same frequency and save on radiation exposure for testing of the core spray pumps. The next most significant change is formalizing our current practice of not restricting startup due to pump and valve testing as stated in our October 4, 1984 letter.
8701020158 861222 PDR ADOCK 05000155
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Director, Nuclear Reactor Regulation 2 Big Rock Point Plent Add'1 Info - Pump & Valve ISI Testing Program December 22,;1986 -
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This change was _ verbally' agreed to during the September 3,1986 conference
- call.
i Ral p R Wisch Senior Licensing Analyst
'CC ~ Administrator, Region III, USNRC.
NRC Resident Inspector - Big Rock Point Plant
. Attachments 3
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h Consumers Power Company Big Rock Point >lant Docket 50-15f
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[ RESPONSES of ICT PROGEAM ANOMALIES IDENTIFIE7 IN E API'ENDIX D OF NRC REVIEW
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RESPONSES OF IST PROGRAM ANOMALIES IDENTIFIED IN APPENDIX D OF NRC REVIEW LI. .The Reactor System Depressurization Valves, SV-4984, -4985, -4986 and J-4987, are never full-stroke exercised (see the Relief Request Evaluation Lin Section 3.6.1.1).
Response
.These valves cannot be full-stroke exercised unless continuous primary system pressure is applied, releasing a large volume of primary steam into the~ containment.and exposing personnel and equipment to adverse conditions.
f/ During testing, pressure in the spool piece between the isolation valve and the depressurization valve is relieved before the depressurization valve. reaches the full stroked position. Thus, only partial stroking of
- the valve is possible during testing and no valve stroke timing can be performed. Alternative methods to allow for full-stroke testing of these valves are being investigated as part of the Integrated Plan Issue Number B-082.
2; Relief should be granted from the Section XI requirements of testing the Core Spray pumps monthly during power operation. However, the licensee's
.- ' relief request (see the Relief Request Evaluation in Section 2.2.1)
- provided insufficient technical basis for not testing these pumps during cold shutdowns, therefore, relief should not be granted as requested and these pumps should be tested during cold shutdowns.
. - Response:
The core' spray pumps and valves VPI-300, VPI-306 and VPI-307 shall be tested once per reactor shutdown for refueling and each cold shutdown but not more frequently:than once every three months.
- 3. : : The staff agrees with the licensee that the following valves cannot or
-should not be exercised during power operation. However, the licensee's relief requests for these valves provided insufficient technical basis for not_ exercising the valves during cold shutdowns, therefore, relief should not be granted from cold shutdown testing and the valves should be exercised
-during cold shutdowns.
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Valves __
Relief Request Evaluation
'VFW-9-Feedwater Stop Check Valve 3.4.1.1 VPI-300--Core Spray Header Check Valve 3.5.2.2 VPI-306 and 307--Core Spray Pump Discharge Check Valves 3.5.2.2 MI1286-1170A-BT01-NLO4
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'cp Response:
VFW-9. resolved'per letter from the NRC dated December 12, 1985.
'See response to #2 above for response for VIP-300, VPI-306 and VPI-307.
- 4. The licensee did not include the Diesel Fuel Oil Transfer System valves in their-IST program.- 'This system performs.a safety function and the appli-cable valves should be included in the IST program and tested in accordance with Code requirements. The applicable Diesel Cooling Water System valves
- should also be included in the IST program and be tested in accordance
-with Section XI requirements.
{( Response:
Emeraency Diesel Generator The~ diesel engine is a Caterpillar, Type 343, Series A, six cylinder turbo-charged 1800 RPM engine, rated at 319 HP. Premium fuel oil is supplied from a 5000 gallon underground tank.
Two shaft driven fuel oil pumps supply the fuel requirements of the engine. One pump supplies the approximately five gallon " day" tank (T-65) and takes its suction directly from the underground storage tank with an overflow'back to the tank. The second pump supplies the fuel oil demand directly,~with the' excess returning to the storage tank. The " day" tank level is checked at approximately two hour intervals by an auxiliary operator (when diesel is not operating) and kept full by a hand wobble pump if needed.
JThe diesel engine is forced water cooled by an integrally mounted pump which takes its suction from the plant discharge canal, routed through a tube type heat exchanger, and discharged tack to the canal.
An alarm is provided for high jacket water temperature at 200*F (TS-1525 and TS-1527). Provisions have been made for three emergency sources of cooling water (manual valving):
- 1. From the service water system
. 2; Domestic water system
- 3. Fire water system The diesel-generator is functionally tested every three days (Plant
. procedure T3-01),
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Conclusion:
l Since the diesel generator is functionally tested every three days, the .l fuel oil pumps are shaft' driven and the cooling water pump is integrally 1
-mounted, it follows that the fuel oil transfer and the cooling water !
systems, and any associated valving, (check 'or solenoid) are also function-
, ally tested'and do not require additional testing. While not an IST test.
a water pump flow test is performed by TR-84 each refueling, including servicing the lube and fuel oil systems and final inspection.
. Diesel Fire Water Pump The diesel engine (driver) is a Waukesha, Model 135 DKUF Series, six cylinder,103 HP,1750 RPM full diesel engine. Premium fuel oil is supplied from a 1000 gallon unCerground storage tank (T-53). A gear type fuel oil transfer pump that meshes with the integral injection pump
. camshaft gear supplies the fuel requirements of the engine and takes its suction from the storage tank. This pump is provided with a manually operated plunger (wobble) pump for purging the system of air after chang-ing a filter and filling the gravity (day) tank if required.
The diesel. engine is force cooled by a large capacity centrifugal pump.
- flange mounted on the front end of the cylinder block and belt driven from the crankshaft.
The diesel. engine (driver) for the diesel fire water pump will be replaced during the 1987 refueling outage. The new diesel fire pump driver will
.be a Caterpillar Model 3208 (175NA), 8 cylinder, 121 HP at 1750 rpm full diesel engine. A mechanical governor controls the fuel injector pump output to maintain the engine rpm selected by the operator. Premium diesel fuel oil is supplied from a 1000 gallon underground storage tank (T-53). A gear type ponitive displacement fuel oil transfer pump that meshes with the individual injection pumps, one for each cylinder, meter and pump fuel under high pressure to an injection valve for each cylinder.
The cooling system for the new driver (12.5 gallon per minute capacity) consists of.a belt driven centrifugal pump, with two thermostats which regulate engine coolant temperature.
The diesel fire pump is functionally tested once per week (Plant Procedure T7-20). This testing will not change with the addition of the new diesel engine.
An alarm is provided for " water temperature above normal" at 195'F. A manual cooling water valve allows bypassing the temperature controller to increase the cooling water flow. While not an IST test, maintenance
' procedure TR-85 for Diesel Fire Pump Inspection / Repair performs and recorda a check and flush of the cooling water system each refueling, and services.both the Lube 011 and Fuel Oil Systems and performs a final inspection..
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Conclusion:
Since the fuel oil pump is gear driven by the integral injection pump camshaft gear. the cooling water pump is driven by the shaft and the diesel fire pump is functionally tested every week, it follows that the fuel oil transfer and cooling water systems, and any associated valving (check or solenoid) are also functionally tested and.do not require additional testing. Further, while not an IST test, Maintenance Procedure TR-85 services the Lube and Fuel Oil Systems, flushes the Cooling Water System and performs a final inspection.
Both the Electric Fire Pump and the Diesel Fire Water Pump are included in routine cold shutdown testing. Both are tested each reactor refueling shutdown by Plant Procedure TSD-01 for operating characteristics. These include all the requirements of Section XI, ASME Table IWP-3100-1 with the exception of bearing temperatures and flow rate. Plant Maintenance Procedure TR-84 and TR-85 test the cooling water flow rates each refuel-ing.
- 5. Permissible leakage' rates should be specified for each Containment Isolation ~ Valve in accordance with IWV-3426 and the appropriate corrective actions outline in IWV-3427 should be taken when the permissible leakage rate of a value is approached (see IWV-3427 b) or exceeded.
, Response:
Permissible leakage rates shall be established for each containment isolation valve prior to the next LLRT.
- 6. The licensee did not identify valves that perform a pressure boundary isolation function in their IST program. The following valves appear to perform a pressure boundary isolation function and, therefore, should be categorized A or A/C as appropriate, be leak tested per the requirements listed in Section 3.1.8, and be included in the Big Rock Point Technical Specification.
Shutdown Cooling System Core Spray System MO-7056 MO-7071 MO-7057 VPI-303 MO-7058 MO-7061 MO-7059 VPI-304
Response
These valves were originally classified as Category B and C valves and not A and A/C valves as may seem appropriate because of their inability to be leak tested. Since the time that these valves were originally classified the code has changed and IWV-3421 allows for valves which function in the course of plant operation in a manner that demonstrates functiona31y adequate seat tightness need not be Icak tested. These valves shall be
. reclassified as A and A/C valves since they do perform a pressure boundary MI1286-1170A-BT01-NLO4 4 I
isolation function but, they will not be leak tested since these valves do 4-isolate systems of lower pressure from the primary system and there are sufficient indicators within the systems to show that the valves have adequate seat tightness.
The Big Rock Point Plant is not a Standard Technical Specification Plant and only the containment isolation valves are included in the Technical Specifications. The valves listed above are pressure boundary isolation valves but not containment isolation valves and will not be included in our Technical Specifications.
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- a ATTACHMENT 2 Consumers Power Company Big Rock Point Plant Docket 50-155
. INSERVICE TESTING PROGRAM RELIEF REQUESTS
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-- " < INSERVICE TESTING PROGRAM RELIEF REQUESTS t
lThe following is a listing ofLthe current relief requests applicable to Big Rock Point's ISI Program and any changes that have been made since our
- December 7,~1979 submittal.
Core-Spray Pumps This request is changed from the December 7, 1979 submittal to test these pumps each cold shutdown and refueling per Appendix D item #2 of NRC's review of_the IST Program. Also included in this request is.a
. change in the testing frequency from not more frequently than monthly to not more frequently than every three months as allowed by later editions of the code.-
Electric and Diesel Driven Fire Pumps This request is changed from the December 7, 1979 submittal to allow for a three month testing cycle as allowed by later edition of the. code.
Control Rod Drive (VCRD 301 and CRD Pump Suction Poppet Valves)
Relief Request' unchanged from December 7, 1979 submittal.
- . Emergency Condenser (MO-7052, M0753, M07062, M07063)
Relief' Request unchanged from December 7, 1979 submittal.
. Containment Isolation Valves (CV-4031, CV-4102, CV-4025, CV-4103, CV-4091 CV-4092, CV-4093, CV-4027, CV-4117, CV-4094 - CV-4097, CV4105)
Relief Request unchanged from December 7, 1979 submittal.
Liquid Poison System (CV-4020)
~ Relief Request unchanged from December 7, 1979 submittal.
Liquid Poison System (VP-300)
Relief Request unchanged from December 7, 1979 submittal.
ShutdowrgCooling System (MO-7056, M07057, M07058, M07059)
?The category of these valves is changed from B to A in accordance with Item f6 of Appendix D of NRC's review of our IST program. No additional leak testing.will be required on these valves since they operate in a
. manner which demonstrates adequate seat tightness.
Treated Waste Return (CV-4049 and VRW-313)
Relief Request unchanged from December 7, 1979 submittal.
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' Demineralized Water Supply'(VMD-300)
Relief Request unchanged from December 7,1979 submittal.
-Liquid Poison System (CV-4050)
-- Relief Request unchanged from December- 7.1979 submittal.
Liquid Poison Supply to Reactor Vessel (VP-301 & VP-302)
- Relief Request. unchanged from December 7,1979 submittal.
Main Steam System (MO-7050)
Relief Request unchanged from December 7, 1979 submittal.
Main Steam Line' Drain Isolation Valve (MO-7065)
Relief Request unchanged from December 7, 1979 submittal.
Feedwater (VFW-304 & VFW-9)
Relief Request changed-from December 7,.1979 submittal in accordance with letters from CPCo to the NRC dated April 10, 1985 and NRC to CPCo dated December 12, 1985.
Feedwater (VFW-305)
Relief Request in accordance with letters from CPCo to NRC dated
-April 10, 1985 and NRC to CPCo dated December 12, 1985.
Control Rod Drive (CVNC09's & CVNC10's)
Relief Request unchanged from December 7, 1979 submittal.
Enclosure Spray System (MO-7064 & MO-7068)
' Relief Request of December 7, 1979 changed to reflect operable status of MO-7068. Required relief from testing is unchanged.
. Core Spray System (VPI-300, VPI-306, VPI-307)
Relief Request changed to reflect changed testing frequency of the core spray pumps per Items #2 and #3 of Appendix D of the NRC's review of our IST Program.
Core Spray System (VPI-303 & VPI 304)
The category of these valves is changed from C to A/C per Appendix D Item #6 of NRC's review of our IST Program. No leak testing of these velves will be performed since they operate in a manner which demonstrates adequate seat tightness.
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Core Spray System (VPI-301 & VPI-302)
'the relief request subaitted on December 7, 1979 should be changed to reflect the actual type of test performed. A full flow test is not performed and is not required. A flow test is performed as required to demonstrate operability of the valve.
Reactor Depressurization System (SV-4984 - SV-4987)
Relief Request unchanged from December 7, 1979 submittal.
- Core Spray System (MO-7072)
Relief Request changed from 8/14/80 submittal to reflect revised frequency. This valve will be included in new t' ore Spray Pump Procedure
-and tested on the same frequency.
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RELIEF REQUEST
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- Item:', Relief request for core spray pumps.
Test Requirement: Monthly during' plant operation and within on week after plant startup if not tested during the shutdown.
Basis for Relief: These pumps are part of the Emergency Core Cooling System. Testing during power operations would require a valve lineup which would preclude their performing tLeir required function after a loss of coolant accident (LOCA). In the event of a LOCA, areas which must be entered to change this valve lineup would be untenable.
In addition, testing during power operation would require
. personnel entry into the very high radiation area directly beneath the reactor vessel.
Alternate Testing: Once per reactor cold shutdown and each refueling (but not more frequently than once every three months).
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- w 1'1 RELIEF REQUEST Item: Relief request for Electric and Diesel Driven Fire Pumps Test Requirement:- Monthly during plant operation and within one week after plant startup if not tested during the shutdown.
Basis for-Kalief: . These fire pumps must be tested on a monthly basis as required by ASME Section XI IWP testing. To perform the test would require fire water flow through the shell side of the core spray heat exchanger. This fire water is then discharged back to the lake.
This flow test, which is the only valid test, will reduce
- the flow available to the ECCS to below that calculated as necessary. Thus, to prevent degradation of the Emergency Core Cooling System, relief is requested to allow testing each reactor shutdown. The granting of this relief request will insure there will be adequate flow avcilable to the Emergency Core Cooling System.
This relief request will also apply to the fire pump discharge check valves, VFP-304 and VFP-309.
-Alternate Testing: Once per reactor cold shutdown and each refueling (but not more frequently than once every three months).
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RELIEF REQUEST System: Control' Rod Drive (Print M-106)
~ Valve:- VCRD-310 and CRD Pump Suction Poppet Valves Category: AC ASME Class:- 2 Function: :To prevent backflow from containment through the CRD Supply line, r Test, Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.
- Basis-for Relief: The closing function cannot be verified except during times of local leak rate testing which.is performed each reactor shutdown for refueling per 10CFR50, Appendix J.
' Alternate Testing: ; Local leak rate test each reactor shutdown for refueling.
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RELIEF REQUEST
" System: Emergency Condenser (Print M-107)
. Valves MO-7052, MO-7053, MO-7062, MO-7063 4
. Category:- B-ASME Class: 1 Function: Emergency Condenser Inlet and Discharge Isolation Valves Test Requirement: Exercise valves for operability every three months
'. Basis 3r Relief: The exercising of these valves at power would admit steam i t- to the emergency condenser. This action would cause unnecessary thermal stresses in the tube bundles. The
, proposed alternate testing will minimize thermal cycles.
Alternate Tasting: Once each cold shutdown or when one loop becomes inoperative.
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' System: Containment Isolation Valves-(Prints M-107, M-108)
Valve: CV-4031, CV-4102, CV-4025,'CV-4103, CV-4091, CV-4092, CV-409'3, CV-4027, CV-4117,'CV-4094 - CV-4097, CV-4105 t: Category:- A'
-ASME' Class:' 1 for CV-4092, CV-4093 2 for CV-4031.,CV-4102, CV-4025, CV-4103, CV-4027, CV-4117, CV-4091 CV-4094 - CV-4097, CV-4105 Function: To Isolate Containment'
. _ . Basis for Relief: Technical Specifications require leak: rate test every 12 months. A Technical Specification' change has been
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-submitted to change this interval to each reactor shutdown for refueling, but not to' exceed every two years.
'The following valves are in the position to perform their
~ intended function.
-CV-4091, CV-4092, CV-4093, CV-4027, CV-4117 Thus, these valves need not be exercised on a quarterly basis.
' Alternate' Testing: -Test in accordance with Technical Specifications and exercise valves CV-4031, CV-4102, CV-4025, CV-4103, CV-4094 - CV-4097, CV-4105 on a quarterly basis.
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. -w RELIEF REQUEST l T- l System: .. Liquid' Poison System (Print M-107)
- Valve: CV-4020 e,
-Category:' B ASME-Class:. 1 Function: Liqu'id Poison Tank Discharge Isolation Valve
' Test' Requirement: Exercise valve for operability every three months.
2 Basis for Relief:. Closing this valve prevents injection of liquid poison and prevents system from being available for operation as required by Technical Specifications. Testing can only occur during cold shutdown.
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. Alternate Testing: Exercise' valve each reactor cold shutdown but not more frequently than quarterly.
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e RELIEF REQUEST System: : Liquid Poison System (Print M-107)
Valve: Check Valve VP-300
- CateJory:- C-ASME :dass: 1.
Function: Once System is Actuated, Check Valve Prevents Nitrogen from Escaping to the Steam Drum While Establishing a Siphon.
Test Requirement: Exercise valve for operability every three months.
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. Basis-for Relief: The valve has no operator. In additica, pressure cannot be applied to test valve operation without breaching primary boundary.
' Alternate Testing: Exercise valve every cold shutdown but not more frequently than quarterly.
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- System: Shutdown Cooling System (Print M-107)
-Valve: NO-7056,-MO-7057, MO-7058, MO-7059
~ Category: A
.ASME Class: 1
_ Function: fShutdown Cooling System Inlet and Discharge Isolation Valves Test Requirement: Exercise valves for operability every three months Basis for Relief: ' Exercising these valves while the reactor is at operating pressure would overpressurize the shutdown cooling system (design pressure 300 psig). In addition, amendment 28 to the Technical Specifications requires opening of the valve breakers at system pressure greater than 300 psig.
' Alternate Testing: The valves are exercised as part of putting the system in service during each shutdown.
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l RELIEF REQUEST System: ' Treated Waste Return (Print M-108) i' Valves Isolation Valve CV-4049 and Check Valve VRW-313 Category:- A and-A/C l
. l ASME Class: 2 i
Function: To Isolate Containment
~ Test Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.
Basis for Relief: The. valves are passive valves that.are in the position that will perform their intended function. Thus, exercising will not provide any additional margin of safety.
Altiernate Testing: Local leak rate test at each reactor shutdown for refueling.
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RELIEF REQUEST System: Domineralized Water Supply-(Print M-110)
Valve: Inlet Check Valva (VMD-300)
Category: A/C
-ASME Class: 2
~ Function: To Isolate Containment Test. Requirement: Exercise quarterly and local leak rate test each reactor shutdown for refueling.
Basis for Relief: -There is no means to verify closure of the-check valve except during a local leak rate test. Thus, the local ic.ak rate test will be the only means of testing.
LAlternate Testing: Local leak rate test each reactor shutdown for refueling.
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C RELIEF REQUEST System: . Liquid Poison System (Print M-121) y .
Valve: -CV-4050 Category: .B ASME Class:--l' Function: Isolate Flow of Liquid Poison to Recirculation Pump Suction Test; Requirement:
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L Exercise valve for operability every three months.
Bisis for Relief: An interlock opens this valve automatically when either recirculating pump is in service. Thus, exercising this valve requires taking both recirculating pumps out of service.
Alternate Testing: Exercise.vsive and verify valve position indication once during any shutdown in which both recirculation pumps are secured, or.as a minimum, each reactor shutdown for refueling.
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- 2 RELIEF REQUEST 3'
System: . Liquid Poison Supply to Reactor Vessel (Print M-121)
Valva: -Check Valve in Liquid Poison. Supply-Line to Reactor Vessel.(VP-302) and Check Valve'in Liquid Poison Supply Line to Recirculating Pumps (VP301)
. Category:. C:
1ASME Class: 1
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Function: To Prevent Reactor Water Backflow through Liquid Poison Lire
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Test Requirement:: Eiercise valves.for operability every three months.
Basis'for Relief: t _The Check valves have no operators. Exercising these valves by initiating flow in the system would introduce
' liquid poison into the reactor during operation or shutdown.
Alternate Testing: Visually inspect valves each reactor shutdown for refueling by removing valve internals.
Discussion: The liquid poison check valves are a Chapman Type V tilting disc check valve which has a three piece body
, ' construction. The seat ring, disc and pivot pins are located in the center section which is secured between two flanges with twelve studs.
This type of check valve construction lends itself to ease of disassembly, inspection, and reassembly.
In order to accommodate this inspection, a 3" gate valve
- must be installed downstream of VP-302 so the check valve can be isolated from the reactor vessel.
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16 RELIEF REQUEST System: Main Steam System (Print M-121)
~ Valve: MO-7050
. Category: A' s
ASME Class: 1 u - .- -
Function: To Isolate Main Steam Line Prior to Leaving the Containment Test Requirement:- Exercise valve for operability every three months and leak test each reactor shutdown for refueling.
Basis for Relief: Exercising this valve interrupts all main steam flow thus exercising must occur during a cold shutdown condition. Leak testing is only possible during NSSS hydrostatic test.
Alternate Testing: Exercise valve during each reactor shutdown. Note valve leakage durin,g each NSSS hydrostatic test associated with a reactor shutdown for refueling.
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17 l RIaIEF REQUEST System: Main Steam Line Drain Isolation Valve (Print M-121)
' valve: MO-7065 Category: A ASME Class: 1 Function: To Isolate Main Steam Line Drain to Condenser
. Test Requirement: Exercise valve for operability every three months and leak test each reactor shutdown for refueling.
Basis for Relief: The valve is electrically disabled in the closed Position and does not have to change position to perform its intended function; thus, no exercising of the valve will be performed.
Alternate Testing: Note leakage rate through the valve during each NSSS hydrostatic test associated with a reactor shutdown for refueling.
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System: Feedwater Valve:. Feedwater Check Valve VFW-304; and-Feedwater'Stop Check Valve VFW-9; Plug Type (Category:- 'C-
- ASME Class: 1 l Function: ~ fPrimary_ Coolant Pressure Boundary a . Test Requirement:- ~ASME Section XI'1977,-summer 1978 addendum IWV-3520 - Valve exercising is not possible during power operation, therefore full _ stroke test during cold shut-
-downs is required. Testing at every shutdown if intervals ;
are 2.3 months or if testing has been completed within the last 3 months testing is not required. Valve disk movement g shall te determined by an appropriate indicator.
' Alternate Testing: Close valve VFW-9 via hand wheel during each refueling outage.
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Basis for Relief: The valves cannot be exercisad during power operation because feedwater flow cannot be interrupted during this time. The valve each close when feedwater flow is stopped. Valve disk movement to the closed position for VFW-304 cannot be determined as there are no direct or indirect indications available to make the determination. Valve disk movement to the closed position for VFW-9 can be determined by turning the valve stem into the seat. VFW-9 is a stop check valve equipped with a hand wheel and stem which can be turned into
.the valve disk. The stem and disk are not connected however, so raising the stem will not raise the disk.
The determination of both VFW-304 and VFW-9 being open is made by verifying proper feedwater flow exists when returning i the system to service after shutdown.
The frequency interval, for closing the valve VFW-9, of each refueling outage is requested due to the high radiation area that exists in the vicinity of the valve. It requires two operators, in an approximate 350 to 500 mr/hr and return 1.t to the full open position. The accumulated exposure for one exercise operation amounts to 0.7 to 1 man-rem. The Consumers Power Company's position is that the benefit derived from exercising the valve stem, that only would be minimal from a valve reliability standpoint and would not off-set the additional radiation exposure involved. Because this area is frequented often during a refueling outage, the exercising of the valve stem to verify valve closure during a refueling outage can be more easily justified.
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RELIEF-REQUEST System: Feedwater
- Valve: Feedvater Check Valve VFW-305; Swing Type r
Category: ' A, C
'ASME Class: 2 Function: Containment Isolation Valve Test Requirement: ASME Section XI 1977, summer 1978 addendum IWV-3410 - Valve exercising is not possible during power operation, therefore full stroke test during cold shutdowns is required. Testing at every shutdown if intervals are 2 3 months or if testing has been completed within the last 3 months testing is not required. Valve disk movement shall be determ,ined by.an appropriate indicator.
IVW-3420 - Valves shall be leak testad every two years.
IVW-3520 - Valve exercising per category C requirements are met by fulfilling requirements of category A IWV-3410 requirements.
= Alternate Testing: . Perform a 10CFR50 Appendix J 1eak rate test during each refueling.
Basis for Relief: The valve cannot be exercised during power operation because feedwater flow cannot be interrupted during this time. The check valve seats (closes) when feedwater flow is stopped. Valve disk movement to the closed position cannot be determined as there are no direct or indirect indications available to make the determination. Disk movement to the open position is only possible when feedwater flow is ind*1ated. Indication of feedwater flow provides the equired indication the valve is open.
Valve exercise testing therefore cannot be accomplished except to verify the valve is open by indication of proper feedwater flow.
As a containment isolation valve the valve will be leak rate tested each refueling outage in accordance with 10CFR50 Appendix J requirements.
IC1286-1186A-BT01-NLO4
. _ _ _ m p , a ;s a 20 RELIEF REQUEST System: ' Control Rod Drive (Print M-122)
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Valve: Scram Inlet (CVNC09) and Outlet (CVNC10) Isolation Valves (32 Sets of 2 Valves)
Category: B AEME Class: 2 Function: To Cause a Control Rod Drive to Insert Rapidly Test Requirement: Exercise valves for operability every three months.
~ Basis for Relief: Exercising these valves would cause the associated control rod to scram.
Alternate. Testing: Exercise valves prior to reactor critical approach following a ccid shutdown.
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IC1286-1186A-BT01-NLO4
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.. . RELIEF REQUEST
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System: .. Enclosure l Spray System (Print'123)
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}' Valve: MO-7064, MO-7068 l Category: B:
-ASME Class:. 2-7 ? Function:- Enclosure Spray ~ Isolation Valves
, Test. Requirement: Exercise valves for operability.every thre'e months
> .' Basis for' Relief: Exercising these valves during power operation would result.in spraying water on energized electrical equipment inside containment.
. MO-7064 and MO-7068'cannot be exercised during cold shutdowns because the fire system header must be taken out of service and drained to allow the-exercising of the
, . valves. This will. pose an unwarranted fire hazard if the
-fire system is not available in the containment. Testing during each reactor shutdown for refueling prevents a 7 more acceptabla risk as far as fire suppression capabilities in the containment.
Alternate Testing: ' Exercise valves each reactor shutdown for refueling.
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. Sys tes:,; Core Spray Systeog(Print M-123) m.
Valve: . Core Spray Pump' Discharge Check Valves (VPI-306, VPI-307) and-Core Spray Test Tank t Inlet Check Valve (VPI-300)
~. Category: C ASME' Class: 3 Fuuction: To prevent backflow in the Core Spray System n sl . f l Test Requirement: - Exgttise valves for.operabi.'.ity-every three months.
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--Basis for Relief: r .The valv'es~have'no' operators. They cannot be exercised
- -by initiating flow is the system during power operation
, bacause the core spraf pumps'cannot be operated for test tduring powhr eparations.
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.Alternste' Testing: Once each, reactor cold shutdown and each refueling. (See
. Core Spray Pump Relief Request discussion because these j : vilves can only_be tested when the pump is tested.)
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RELIEF REQUEST
.Systsm: Core Spray System (Print M-123)
Valve: Primary Check Valves (VPI-303 and VPI-304)
Category: A, C '
ASME Class: 1
' Function: Primary check valves in the core spray lines to prevent reactor pressure from' pressurizing lines if the isolation valves were opened.
Test Requirement: Exercise for operability every three months Basis for Relief: The primary check valves hnve no operators. The valves cannot be opened against operating reactor pressure by initiating flow through these lines, beer.ase core spray system pressure is much less than operating reactor pressure. During shutdown, the initiation of flow through these lines would introduca non-reactor grade water into the core. The only means to insure proper valve operation is to disassemble and inspect the valve
.during each reactor shutdown for refueling. There exists no method to insure disc movement torque requirements are met. The valve will be inspected and verified that the disc is' free to move.
Alternate Testing: Disassemble and inspect each reactor shutdown for refueling.
IC1286-1186A-BT01-NLO4
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' RELIEF REQUEST
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System: Core Spray System (Print M-123) .
' Valve:- Secondary Chetek Valves (VPI-301 & VPI-302)
LCategory: C
~ASME Class: 1 4
iFunction: .To Prevent Water Backflow'From the Reactor to the Fire Water System
. Test Requirement: Exercise valves for operability every three months.
Basis for Relief: :The secondary check valves have no operators. Testing of
-the. valves will take the core spray system out of service.
Thus a flow test will be performed-by allowing the fire water to. enter the service water system and then be discharged to the. canal. (Note that proper sampling and analysis of the fire water will be performed to insure no uncontrolled release.) This flow testing.will be scheduled each reactor cold shutdown (but not more frequently than three months).
Alternate Tes' ting: Flow test the check valves each reactor cold shutdown (but not more frequently than three months).
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RELIEF REQUEST
' System: Reactor.Depressurization System (Print A-203)
. Valve:.'SV-4984 - SV-4987-
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- Category: .A~
ASME Class: 1 Functions: _Depressurization Valve Test. Requirement: ~ Exercise valve for operability every three months.
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Basis for Relief: The' valve cannot be fully stroked unless continuous
- b. primary system pressure is applied. During, testing, pressure in the spool piece between the isolation valve and the depressurization valve is relieved before the
'depressurization valve reaches the fully stroked position. Thus, only partial stroking of the valve is possible during testing.
Alternate Testing: ' Exercise the depressurization valve each reactor cold a shutdown .but not more frequently than three months.
This exercising.will only entail a partial stroking of the valve.
IC1286-1186A-BT01-NLO4
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L RELIEF REQUEST
. System: Core Spray System .
Valve:--MO-7072)
Category: B ASME' Class: 2 Function: To Provide'a Third Path of Fire Water to the Containment Teit Requirement:- Exercise quarterly Basis for Relief: . Exercising this valve will introduce fire water into the inhibited water of the core spray pump piping. Exercising during each shutdown will minimize the amount of fire water that enters the core spray pump piping.
lAlternate Testing: Each reactor-cold shutdown but not more frequently than every three months.
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ICl286-1186A-BT01-NLO4