ML20128N531
| ML20128N531 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/17/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20128N518 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9302230280 | |
| Download: ML20128N531 (16) | |
Text
.__ __. _ _. _ _ _ _ _
[>S RIOg#~%,
ENCLOSURE 3"
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- UNITED STATES 3
a
.. i NUCLEAR REGULATORY COMMISSION
- g WASHINoTON. D.C. 20066 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATl@
RELATED TO THE INSERVICE TESTING PROGRAM RELIEF RE0 VESTS LICENSE NOS. NPF-39 AND NPF-85 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION. UNITS 1 AND 2 DOCKET N05. 50-352 AND 50-353
1.0 INTRODUCTION
The Code of Federal Regulations,10 CFR 50.55a(f), requires that inservice testing (IST) of certain ASME Code Class 1, 2, and 3 pumps and valv~ be performed in accordance with Section XI of the ASME Boiler and Pres.are Vessel Code and applicable addenda, except where relief has been requested by the licensee and granted by the Commission pursuant to 50.55a(f)(6)(i), or where the alternative has been authorized pursuant to 50.55a(a)(3)(i) or (a)(3)(ii).
In r equesting relief, the licensee must demonstrate that:
(1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance with certain requirements of the applicable Code edition and addenda is impractical for its facility. Generic Letter (GL) 89-04, " Guidance on Developing Acts.ptable Inservice Testing Programs," provides alternatives to Code requirements which have been determined by the staff to be acceptable, provided the alternatives are implemented in accordance with the guidance delineated in the applicable positions.
These regulations authorize the Commission to grant relief from or approve alternatives for ASME Code requirements upon making the necessary findings.
The NRC staff's findings with respect to granting or not granting the relief requested or authorizing the proposed alternative as part of the licensee's IST Program are contained in this Safety Evaluation (SE).
The staff transmitted ar. SE to the licensee in a letter dated March 5,1991.
The SE contained a TecFnical Evaluation Report (TER) which addressed the licensee's first 10-year inservice testing program. Appendix A of the TER identified 15 anomalies which the licensee was requested to address. The licensee submitted a new relief request in response to item 13 in a letter dated April 15, 1992. A response to the remaining anomalies was submitted by-the licensee in a letter dated May 1, 1992.
Table 1 in this SE provides a summary of the actions taken by the licensee to address the anomalies and the licensee's outstanding actions resulting from this evaluation. Relief requests 52-VRR-1, GPRR-2, and GVRR-1 are evaluated in this SE.
9302230200 930217 PDR ADOCK 05000352 P
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.. 2.0 RELIEF RE00ESTS RELATED TO TER AN0MAllES 2.0.1 Use of Non-Intrusive Testina The relief request evaluations summarized in TER anomaly items 9,10, and 11 requested that the licensee investigate alternative methods to verify that the check valves in these relief requests actuate to their safety position.
The licensee did not provide any information in their responses regarding the feasibility of utilizing non-intrusive test methods in lieu of disassembly and inspection of these check valves.
Generic Letter 89-04, Position 2, does state that disassembly and inspection can be used as a positive means of full stroke open or closure verification of check valves. However, verification of disk position by non-intrusive means can, in some cases, meet the full intent of the Code and preclude the need for disassembly and inspection of check valves.
The licensee should continue to study the potential for utilizing non-intrusive testing to verify full stroke open exercising or closure of the check valves in the applicable relief requests.
2.0.2 Testina of Residual Heat Removal (RHR) Mini-Flow Check Valves The licensee's proposed method to verify flow through the mini-flow check valves by using a calculated flow rate is not in accordance with the Code i
requirements because the flow rate through the mini-flow line is not directly measured.
Therafore, the licensee should either submit a relief request describing their method of testing or verify flow through the RHR mini-flow line by direct means.
If a relief request is submitted, it should include the following information:
a description of how the RHR pump testing is conducted and how testing of the mini-flow check valves are incorporated into this testing; where the RHR pump flow rate is measured, for example, the flow from RHR pump ICP202 appears to be measured from flow element FE-1N014C; the calculations used to determine the flow rate through the RHR mini-flow line; and the preservice inspection pump curve used to determine the RHR flow rate through the RHR mini-flow line and justification supporting the acceptability of the preservice pump curve in this application.
2.1 Relief Reouest 52-VRR-1 i
The licensee is requesting relief from the requirements of Section XI, Paragraph IWV-3520, for the ccre spray injection check valves HV-52-108 and HV-52-208.
The licensee is proposing to manually exercise the valves in the forward direction and verify reverse flow closure using Appendix J and Section XI leak rate testing at refueling outages.
2.1.1 Licensee's Basis for Reouestina Relief The 1?censee states: "The above valves are equipped with air actuators that i
are designed to provide spring assistance for valve closure only.
Therefore, flow exercising in the forward direction can only be accomplished by injection j
into the vessel.
Injection into the vessel using the core spray pump is not possible because the core spray pump is not capable of overcoming reactor L
L, 1
l pressure during normal-operation. The high pressure coolant injection (HPCI) system injects through this valve. However, this would require the. injection of relatively cold water from the condensate storage tank into the reactor i
vessel via the HPCI pump. The introduction of relatively colder water-into the reactor coolant system would result in an excessive number of thermal cycles to the system piping and components.
Additionally, the introduction of colder water would increase reactivity due to the colder moderator temperature. Therefore, as an alternate means of forward exercising, the valve will be manually full opened in accordance with IWV-3522(b).
Manually forward exercising this valve at cold shutdown requires equalizing pressure across the valve.
Pressure equalization across this valve would be accomplished by injection of condensate into _the vessel through a-stagnated leg of the core spray system. Use of this injection path would introduce crud i
into the reactor vessel and could impact the unit restart due to technical specification 3/4.4.4 chemistry requirements. A means of crud removal is not i
available because no vent or drain paths exist on this leg of piping.
Crud removal from this leg of piping can only be performed during refuel by flushing the core spray header into the reactor using station procedures. The 3
reactor water cleanup system would have to be placed into operation to reduce crud levels so that the chemistry levels would be within acceptable ranges.
Restart would be delayed by this cleanup process.
Additionally, manually forward exercising requires partial disassembly of the l
actuator, which if attempted during cold shutdown, could result in a delayed plaat start-up. Therefore, forward exercising will be accomplished at refueling and exercising in the reverse direction will be accomplished during i
Appendix J and Section XI leak rate testing."
2.1.2 Alternate Testino The licensee proposes: " Manually exercising in the forward direction will be l
performed at refueling. The force used to forward stroke these valves will t
not exceed the criteria specified in IWV-3522(b).
Reverse flow closure will be verified at refueling by Appendix J and-Section XI leak rate testing."
4 2.1.3 Evaluation The core spray system is one of the emergency core cooling systems' designed to j
provide coolant to the primary system in the event of a loss-of-coolant-accident (LOCA).
The core spray system is a low pressure system designed to cool the reactor core by direct impingement of high-density spray following depressurization of the primary system. The core spray system does not operate under normal conditions, but is automatically actuated in the event of a LOCA. The core spray system consists of two_ redundant trains which are
~
directly connected to the reactor vessel at two separate nozzles.
Loop B contains the normally closed ain operated injection check valves-HV-52-108 and.
HV-52-208 'for units 1 and 2 respectively.. The HPCI system ties into the core 4
spray system just upstream of each of these two injection check valves.
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- -.The Code requires that these valves be exercised to the full open position to verify that the valve is capable of passing its intended flow.
In order to test this valve quarterly with flow, the HPCI system must be initiated to j
inject water from the condensate storage tank into the reactor vessel. This is impractical since water from the condensate storage tank is relatively cooler than the reactor coolant system water.
It would result in excessive thermal cycling of the system components and a transient condition due to an j
increase in reactivity.
Performing the manual full-stroke exercising during cold shutdowns would introduce crud into the reactor vessel from the stagnant leg of the core spray system. This would delay startup because additional time in cold shutdown would be required for the reactor water cleanup system to restore water chemistry levels to within technical specification limits..
j Crud removal from the stagnant core spray piping leg can only be accomplished.-
1 during refueling outages by flushing the core spray header into the reactor vessel.
The licensee has proposed to forward stroke these valves manually every 1-refueling outage. The proposed alternate testing provides reasonable assurance of operational readiness because the valves will be manually forward exercised every refueling outage in accordance with Section XI, IWV-3522(b),
j which verifies the functioning of the valve, j
Relief is granted pursuant to 10 CFR 50.55a(f)(6)(1) based on the impracticality of performing full-stroke open exercising of the check valves in accordance with Code requirements, and in consideration of the_ burden on 3
the licensee if the Code requirements were imposed on the' facility.
l The licensee has also proposed to verify reverse flow closure at every j
refueling outage utilizing Appendix J and Section XI leak rate testing. This portion of the relief request was approved by the staff in the SE dated March 5, 1992, and is not evaluated in this SE.
i 2.2 Relief Reouest GpRR-2 l
The licensee has requested relief from the pump instrument accuracy i
requirements of_Section XI, Paragraphs IWP-4110 and IWP-4120,-for the-l instrumentation listed in the supplemental information portion of this relief request.
The licensee is proposing to continue to use the installed instrumentation for inservice testing of the-associated pumps.
l 2.2.1-Licensee's Basis -for Reouestino Relief The licensee states:."Various permanently installed pressure and-flow instruments are calibrated to an accuracy that exceeds 12% of full-scale or have a full-scale range that exceeds the three times the reference value criteria that is specified by the Code.
Although these instruments do not meet =the Code requirements, they are able to provide the same or better indication accuracy at tne reference value that is allowed by the-Code.
a
, For instruments to be in compliance with ASME Section XI, Subsection IWP, two
'equirements must be satisfied. The first requirement (specified in IWP-4110 r
Table IWP-4110-1) states that flow and pressure instrumentation must be
(
accurate to within i2% of the full-scale value; the second. requirement-(specified in.IWP-4120) states that "the full-scale range of each instrument shall be three times the reference value or less." Based on these requirements, a maximum indication accuracy of 16% can be calculated by l
comparing the actual tolerance of the instrument to the reference value being measured. An example of calculating the indicated accuracy is shown below.
Examole Using a flow reference valuo of 10,000 gpm and a flow gauge with an actual full-scale range of 12,000 gpm that is calibrated to 12% of full-scale:
Code Reouirement Reference value - 10,000 gpm IWP-4120, 3 x reference value - 30,000 gpm Instrument tolerance - 1600 gpm (12% x 30,000 gpm)
Indicated accuracy 1600 gpm/10,000 gpm x 100% - 16%
The indicated accuracy for the instruments on the pumps listed are less than or equal to f6% at the reference value. These accuracies are the same or better than allowed by the Code."
2.2.2 Alternate Testino The licensee proposes: "The existing permanently installed pump instrumentation is acceptable provided the indicated accurt.cy is less than or equal to 6% of the reference value.
No alternate-testing will be performed."
l 2.2.3 Sucolemental-Information Provided by thelicensee The table below specifies the instruments where this relief request applies.
The indicated accuracy, which is less than.6% in all cases, is determined by dividing' the' actual initrument tolerance by the reference value multiplied by 100%.
Key to systems and-instruments-011 Emergency Service. Water -
012 Residual Heat Removal-Service Water 049 Reactor Core Isolation Cooling 051 Residual Heat Removal
-055 High Pressure Coolant Injection FI Flow Indicator (gpm)
PI Pressure indicator (psig)
I 6
System Instrument Reference Instrtment Instrument instrument Indicated
- mber' Vstue Range Accuracy iolorance Accuracy 011 FLOW E1517 3,400 0
12,000 1.51%
181.2 5.33%
011 FLOW E1547 3,400 0
12,000 1.51%
181.2 5.33%
011 Flow E2517 3,400 0
12,000 1.51%
181.2 5.33%
011 FLOW E2547 3,400 0
12,000 1.51%
181.2 5.33%
i 012 F1 51 1R601A 9,000 0
12,000 3.20%
384 4.27%
012 F1 51 1R6018 9,000 0 - 12,000 3.20%
384 4.27%
1 012 F1 51 1R6024 9,000 0
12,000 3.20%
384 4.27%
012 FI 51 1R6028 9,000 0
12,000 3.20%
384 4.27%
049 FI 49 1R600 1 570 0 700 3.08%
21.56 3.78%
049 FI 49 2R600 1 650 0 700 3.08%
21.56 3.32%
051 FI 51 1R603A 10,000 0
12,000 3.20%
384 3.84%
f 051 FI 51 1R6038 10,000 0
12,000 3.20%
384 3.84%
051 FI 51 1R603C 10,000 0
12,000 3.20%
384 3.84%
k 051 FI 51 1ir6030 10,000 0
12,000 3.20%
384 3.84%
l 051 F1 51 2R603A 10,000 0 - 12,000 3.20%
384 3.84%
051 FI 51 2R6038 10,000 0
12,000 3.20%
384 3.84%
051 F1 51 2R603c 10,000 0
12,000 3.20%
384 3.84%
j j
051 F1 51 2R6030 10,000 0
12,000 3.20%
384 3.84%
055 FI 55 1R600 1 5,600 0
6,000 3.08%'
184.8 3.30%
i 055 FI 55 2R600 5,300 0
6,000' 3.08%
184.8 3.49%
055 Pi 55 1R601 860 0
1,500 3.05%
-45.75 5.32%
055 PI 55 2R601 860 0
1,500 3.05%
- 45. 75 5.32%
4 i
2.2.4 Evaluatl0D
!I The licensee has requested relief from the Code accuracy and full-scale range requirements for several pressure and flow indicators used for' inservice e
testing of pumps.
The flow instruments in the emergency service water system exceed.the full-l scale range requirements of Section XI, Paragraph IWP-4120. These indicators i
are calibrated to an accuracy of il.51% of full scale.
This-results in the actual variance having a value less than the maximum variance allowed by the 4
l Code.
The installed instrumentation provides an acceptable level of quality and safety because the variance in the actual test results is more conservative than that allowed by the Code.
Therefore, the alternative is j
authorized, pursuant to 10 CFR 50.55a(a)(3)(i),-as requested.
1
+ -
The pressure and flow instruments in the residual heat removal service water, reactor core isolation cooling, residual heat removal, and high pressure coolant injection systems exceed the maximum Code allowable total accuracy requirements given in Section XI, Paragraph IWP-4110. These indicators have a full-scale range less than the maximum allowed by the Code. This results in the actual variance having a value less than the maximum variance allowed by the Code.
The installed instrumentation provides an acceptable level of safety because the variance in the actual test results is more conservative than that allowed by the Code. Therefore, the alternative is authorized, pursuant to 10 CFR 50.55a(a)(3)(i), as requested.
2.3 Relief Reouest GVRR-1 l
The licensee has requested relief from the analysis of leakage rates and _
corrective action requirements of Section XI, Paragraphs IWV-3426 and IWV-3427 for containment isolation valves. The licensee has proposed to conduct leak rate testing in accordance with Appendix J type testing and establish a maximum permissible leakage criterion for each individual local leak rate test.
2.3.1 Licensee's Basis for Reouestino Relief The licensee states:
" Containment isolation valves are required to be leakage rate tested in accordance with 10 CFR 50, Appendix J.
The leakage rate requirement
.; based on a total allowable leakage rate for all valves instead of an individual valve leakage rate.
IWV-2100(a) defines Category A as
' valves for which seat leakage is limited to a specified maximum amount in the closed position of fulfillment of their function.' Although for containment isolation valves leakage rates are not limited on an individual basis by Appendix J, they have been determined to be Category A valves.
Since containment isolation valves are Category A, the leakage rate testing requirements of IWV-3420 must be satisfied. The leakage rate testing performed per Appendix J satisfies the requirements of IWV-3421 through 3425, however, it does not satisfy the individual valve leakage rate analysis and corrective actions of IWV-3426 and IWV-3427.
Appendix J testing is accomplished by performing individual local leak rate tests on each containment penetration. The results of these tests represent the total leakage from the boundary valves associated with the penetration.
In order to prevent duplicate leakage testing of these valves, a maximum permissible leakage will be established for each individual local leak rate test.
If this value is exceeded, then corrective action will be taken to restore the leakage rate to within acceptable limits. The proposed actions e
will be taken in lieu of IWV-3426 and IWV-3427(a). Double frequency testing, as required by IWV-3427(b), shall not be performed. The usefulness of the data does not justify the burden of complying with this requirement.
Corrective action previously addressed will be sufficient in maintaining acceptable leakage rates."
)
. 2.3.2 Alternate Testina Containment isolation valves will be leak rate tested in accordance with the 10 CFR 50 Appendix J Type C testing program.
In addition, a maximum permissible leakage criterion will be established for each individual local leak rate test.
If the local leak rate test leakage criterion is exceeded, corrective action will be taken to restore the leakage rate to within the acceptable value.
2.3.3 Sucolemental Information Provided by the Licensee This relief request was granted in the SE dated March 5, 1991, with a provision that for penetrations with multiple valves being tested as a group, the maximum allowed leakage rate would be based on the smallest valve in the group. The licensee has established maximum leakage criterion based on the smallest valve in the group where possible.
However, there are 23 valve groups per unit at limerick where this criterion cannot be met.
Several penetrations are associated with valves of different sizes (i.e.,
24-inch valve,1.5-inch valve, and 1-inch valve) that are tested in parallel.
Because of the large difference in valve size, the licensee is unable to assign a maximum valve group leak rate that is low enough to detect significant leakage from the 1-inch valve, and high enough to allow acceptable leakage from the 24-inch valve. Assigning a maximum leakage value based on the smallest valve would result in unnecessary maintenance being performed due to acceptable leakage through the larger valve. Therefore, the licensee established maximum allowable leakage rates based on the summation of the individual valve leak rates.
The individual leak rates are determined using ASME Section XI Code requirements. Addition 11y, an " alert" limit has been established based on previous valve group test results. This " alert" limit is used for comparing current test data with previous test results.
In addition, the " alert" value is used to trend the leak tight perforiaance of the valve group.
Of the 23 valve groups identified,14 have sufficient test taps available to perform visual leakage inspections which can be used for detecting leakage i
through the smaller valves in the group. This visual inspection is performed when leak rates exceed the " alert" limit even though the total leak rate may be less than the maximum allowed for the group.
For the remaining 9 groups where test taps are not available, a conservative combined leak rate is used to assess the leak tight integrity of the valves in the group.
If leak rates i
exceed the specified " alert" limit, corrective actions are implemented.
The method used to establish the maximum allowahle leak rate for each valve, and subsequently the valve group, is based on the ASME Section XI, Paragraph IWV-3426 criteria.
Although individual valve leak rates are not being j
measured, this method meets the intent of the Code since the leakage value is quantified and corrective action is taken if the total leakage for the group exceeds the maximum allowed for the group.
(
i I
1 2.3.4 Evaluation The Code states that Category A valves shall be leak tested and the results compared with previous measurements.
In addition, permissible leakage rates shall be established for Category A valves.
Valves exceeding the established maximum allowable leakage limits shall be repaired or replaced. These limits are established to verify the functioning of a valve in the closed position in which seat leakage is a factor in the fulfillment of its safety function.
Relief was granted in the March 5,1991. SE to test containment isolation valves in accordance with 10 CFR Part 50, Appendix J, provided that for valves tested in groups, the assigned maximum group leakage rates were based on the smallest valve in the group. The licensee stated in their May 1, 1992, submittal that there were 23 valve groups in each unit where the nominal diameters of valves in the group are significantly different from each other, for example, a 24-inch valve, a 1.5-inch valve, and a 1.0-inch valve.
Basing the leakage limit on the smallest valve in these groups is impractical because a maximum leakage limit cannot be assigned that is both small enough to detect leakage from the smaller valve and large enough to allow acceptable leakage from the larger valve.
It would be a burden to require the licensee to test these valves according to the provision in the Marcii 5,1991, SE because the -
testing could result in unnecessary maintenance being performed after testing.
The licensee has proposed to establish leakage limits for these specific groups of valves by summing all the allowable leakages for each valve. The individual allowable valve leakages are calculated by utilizing the permissible leakage rate provided in Section XI, Paragraph IWV-3426.
In addition, an alert limit will be established based on previous test results for that group. The alert limit is used to either initiate additional testing or corrective action. The proposed testing provides a reasonable assurance of operational readiness because the results of the testing are compared with alert and maximum leakage limits and corrective action is taken if the leakage exceeds the specified leakage limits. The alert and maximum leakage limits for these penetrations are sufficient to prevent significant degradation of the valves.
Relief is granted, pursuant to 10 CFR 50.55a(f)(6)(i), based on the impracticality of performing testing in accordance with the Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility.
l Principal Contributor:
J. Colaccino Date: February 17, 1993
Attachment:
Table 1 l
l l
l
Table 1 Philadelphia Electric Power Corporation Liinerick Generating Station, Units I and 2 NRC Safety Evaluation Docket Numbers 50-352 and 50-353
?
Item theter senerfytlam of Anesty in HNC SE..
Limerick Actlene as Described in '
Semelming taelleff.
ested IRorah 5,7
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seemet'erf l~
~^'19P16 tospuise'te Anmesties seted any 1,~1pm Actlas a)
Item 1 In the workirg meeting minutes dated merch 31, After further evolustion, the ticanese hee The licensee hee revised (reeldset heet 1988, the Licensee comeltted to remove the determined that these vetwee perform a Revision 2 to h ir ist removat (tm) references in their program to the forwerd flow eefety fwetion to apen and should be program to address the system check testing performed on the RM system check vetwee forward flow tested. Check volve closure concerne of the enasety.
vetwee) 51-1(2}F031A-D. A review of Revision 0 of the efter foruord flow testing te verified No further eRC setlen is licensee 8e IST program Indicates thle chenee hee gsorterly in the vetve surveittence test.
ragst red.
not been mode.
Item 2 In the workfrs meetine minutes dated merch 31, The esorterly stroke test was revloed to The method the iIcensee (RNR system 1988, the licensee censitted to investigate e include e aquentitative flow rate to verify hee proposed to determine mini-flow positive method of futt-stroke esercleing RNR that the vetwee open es required. The flow in the ama sint-flow check vetwee) mini-flow check vetwee 51 1(2)F04aA-0.
design flow rate of the ant mini-flow line line le not in accordence 4
le 10E of the rated system flow with the Code ragsf ramente (approalmstely 1000 ese). The flow rate of because the actunt flow
{
the sua mini-fIou tine viit be verifled by thru the mint-fIou tine le i
calcutetlne the Rut pump differentist not measured. Therefore,
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pressure and approalmating the flow rete the ifcensee should either i
using the pump curve developed from the use direct means to vertfy preservice inspection flow test for the flow through the Rua mini-
[
specIfIe pump.
flow check wetvee or
{
ed mit a relief rosyseet i
within 90 days. Emesples i
of verifying flow by j
direct means include l
Instettetion of en j
uttresenic flow ester or e i
flow orifice in the Run i
mini-flow Ilne or verify futt-stroke exercise of the check vetsee by non-intrusive diagnostice.
4 I
(See SE, Sectien 2.0.2) l
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i t
f l
Itemlheter
- Deecription of Anomety in Inc SE Limerick Actions as esecribed in somminteg (metlef c Deted Stord 5,1991 Seepense to Anomalies Deted IImy 1,1992.
. Actions sequest er; 37 Item 3 In the working meetirg minutes dated Merch 31, The CS mini-flow line check valves are futt-The method the licensee is (core spray 1988, the licensee committed to investleste a stroke exercised p erterly. Their desten usins to determine flow in (CS) system positive mothed of futt stroke exercising Cs flow is esproximately 10% of rategi system the Cs mini-flow line le pump mini-flow system pump mini-flow check vetwee 52-1(2)F036A-D.
flow (320 sgm). Ultremonic flow
- In accordance with the check vetwee) instrumentation le used on imit 1 te measure Code re w irements.
the fIow in the mini-fIou Iinn. Unit 2 Therefore, the ticonsee utilizee a flow orifice to meeeure has addressed the concerne differentist pressure end determine the flow of the enamely. so rate in the mini-flow tine. A modification further NRC action is to instatt flow orifices to the imit 1 Cs rewired.
mini-fIou tines is in progress.
Item 4 The Licensee requested retlef from the Code The ticaneee enetooed a table e lch Retlef granted (e)(3)(i)
(GPER-2) instrument accuracy requiremente for ett pumps in specifies the pressure and flow the IST program with the esception of the instrumentation that are not in compliance Note: The licensee should enfeguard piping ft:1, diesel fust oft trenefer, with the Code re yframents. This table shows w date retlef re post and stantby tipid controt ptmps. The licensee that the actunt verlence in the meesured Gram-2 to include the did not identify each ef fected pump Instrument, parameter calculated for each instrument is ag ptementet information the reference vetue, and the futt-scale range, less than the Ccds allowable verlence.
provided in their response therefore, it was not possible to determine the to item 4.
r evellable accurecies and the effect that use of these instruments would have on the licensee's ability to monitor gump hydraulic condition eruf detect degradation. Relief was denied for instrtaments that did not arovide the smee or better accuracy at the reference value as re wired by the Code.
t Item 5 The licensee reposted retlef from the Code teek There are 23 contalement isolation vetve nelief oranted (e)(3)(1).
(Gvat-1) rate testine re yframents for att containment sro ws per smit d ere the provisionet isolation vetves. Were truffwidual teekage limits re y frament of beelne the teekese of a cro w note: The licensee should can be assigned and vetve teoksee determined, the of velves on the smetteet nominst diameter g dete relief re pest s
I ticensee should comply with the reyfrements of volve cemet be meet. In situations d ere Gveu-1 to include the f
l IW-3426 and IW-3427(e). nellef was granted for there are vetves of different sizes (i.e.,
s g ptmeentet inforention velves that can only be tested in proge with the 24-inch, 1.5-lach, and 1.0-inch velves) that provided in their respmse provision that the assigned sextaus grow teoksee are tested in parettet, e teekage timit to item 5.
i rates were based on the emettest valve in the comot be assigned that is low enough to detect significant teekese from the 1-inch l
- groep, j
valve and high enough to attow acceptable 7
leekoge from the 24-inch velve. Therefore, j
the monista attowable teekese rates will be based on the sumention of the individual t
vetve teek rates.
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J Lleerisdt Ac Anmelaisg
- f. tem Easter
- Doestiption of A.nmeety in K E
.e,s.e to.tions as Somerihed in '
euef <.
,.eted ner
- 5. mi a.enes.eted no, i. im
.cties. -
asspasst er /
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Item 6 The Licensee preposed verifying the closure Rollef request Gwat-4 mes revloed to ackf the The licersee's revloed (GWRR-4) capability of easAt set of series check vetwee following statement to the alternate test relief recpasst addressee L
tieted in thle rollef regaset as e unit. Rollef section: "soth velves ullt be declared the concerne of the une granted with the provlefon that both vetwes in inoperable if testing indicates the vetwee anommty. No further asc the pelt were doctored inoperable, disassembled, do not close on reverse flow."
action le respaired.
[
end repelred er reptoced if escesolve teekage uso detected daring testing.
Item 7 The Licensee proposed futt-stroke esercising each The retlef respasst has been revloed to state The licensee's revloed f
(evne-5) set of four eerles-parettet vacuus relief check that the check vetwee ullt be tested retlef respasst addressee i
velves tieted in thle retlef respacet es a mit.
<psorterly in the forward direction as e unit the concerne of the l
The proposed groep testirg gives no indication of (four wetwee por group). Att volves in the encenly. No further Nec the individtset volve condition. Relief use gros, mitt be declared inoperable if the action le roepaired.
granted with the provielen that ideen the gros, grote falte to pose the respaired forward i
feite to permit the respaired foruord flow, att flow.
volves in the grose are doctored inoperable until they are repelred, replaced, or Indivlshaetty verified capable of perforsteg their esf6ty factlen.
The licensee stated that vetve closure is verified Relief respasst GWRR-5 and associated vetwo by a temperature eenmer in the upstreen line that tables asere revloed to add reverse esercise provides en etern in the control rose if reverse testing respairemente for the folleming floes occure. For thle series-perettet vetwees 49-1(2)017, 49-1(2)018, combinetton, thle test verifles that et feest one 49-1(2)F068, 49-1(2)fes1, 55-1(2>025, of the peretlet vetve cambinatione le cleoed, but 55-1(2)026,'55.t2) foe 0, 55-1(2)-F096. Each It does not provide inforention about the parettet set of Jeock vetwee (2 sets, 2 i
condition of the remaining velve combinetton.
vetwee per set) ulLL be tested spaarterly in i
Adespaete isolation vetwee and test tape eelet to the reverse directlen.' Seth volves in the i
teak test each parettet vetve ceabinetton to set ullt be declared inoperable if testing verify that each Individset volve le capable of indicates that the vetwee do not close on I
preventing reverse flow. Therefore, the ticonsee roweree floes.
j la espected to campty with the Code ragstrement of verifyirg the closure capability of each velve.
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' Item Wie6er l peectlptless of Anamely in amt $f J L f Limerick Actismo se Gencrthed in.
?Astlemen i
Amaninleg (astlef
~ itseed IImed 5,1991L mempense to Anmeetles Seesd flor 1,1992.
Saipanet' or 2)'
item 8 The Licensee proposed testire the diesel generator This relief respacet and associated vetve The licensee's revloed (20-Utt-1) air start estameld volves es e unit durire monthly tables were revloed to add spaarterly otroke retlef respasst addresses diesel testing and to alternately footste the air time reupstrements and to change the esercise the concerne of the headore daring dieset testing overy 18 months.
test intervet from 18 months to aperterty.
anamoty. No further M C Piping and instr e nnt draulns 15I-N-20 showe In addition, a limittre diesel start time of action le respFred.
manuel vetwee that could poselbty be used to 10 seconds will be used to evolunte if the Isolete en air etert train daring dieset testire failure of the emergency dieset generator to to verify operability of the other train. Relief start within tr.le time can be attributed to use granted with the provision that the licensee the sesociated starting air vetwee. The stert" as the dieset assigne e maalsman tietting dieset stort time which licensee definee a is teos then er espant to the is llelt and verif tee ecceterating to 200 rpm in response to a the operability of the vetwee in each air start start alonet.
t train et toast cyaerterly by Isolating one sir start train en en etternatins beels darine dieset testine.
Item 9 The licensee pragw verifylte the futt-stroke This relief re<paset use revised to add the The licensee's revloed (55-vet-1) epen capability of the NPCI pump suction from the foltoutre statement to the etternate test retlef respaeot addressee
...pertlet stro6e ullt be the concerne of the
.I suppreselen poet check volve using disassent>ty and section: "
E inspection. Provisionet relief use granted performed ef ter volve sesembly."
enemely..No further NRC provided the Licensee performed a partiet flow action is recpaired.
test of the disassent>ted volve before it le returned to service. The staff recommanded that l
the Licensee actively pursue the use of non-Intruelve diagnostic technt< pass to demonstrate that these velves suins futty open daring portiet flow testing.
Item to The licensee proposed verifying the futt-stroke Thfe relief respacet une revloed to add the '
The lleenmee's revloed (55-vam-2) open capability of the NPCI pimp discherse check followine statement to the etternate test retlef request addresses
...pertlet stroke ultL be the concerns of the volves usins disassembly and inspection. Interim section: "
retlef use granted to eive the 1iconsee tles to perfonmed af ter wetwe essenddy."
enematy. no further sec inveettente and laptement cheness necessery to action le respaired.
perform post-inspectlen part stroke esercistne.
The staff recommended the licensee actively pursue the use of non-intrusive dimenostic technispass to demonstrate that these volves swing futty open daring partiet flow testing.
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Item'Enehar Descriptlen of Anumely les K K Llearled[ Actismus as Sancrified let -
Bemeining teesd Insrch 5,19F5 -
auspasse to asumelles amend sair 1g Iggt.
Astl ois (nellet t
W ar-esapeimnt)
Itas 11 h ticensee preymeed verifying the cleeure This edief reupsmet use revlead in sneer to The ticensee's revised (Guam-6) capalpitity of the este of series etsay fitt check fettaw the recememnestiene for semple retlef roupseet addromese wetves tieted in the relief rimpeset usins diseseementy and inspectlems specified in isec the concorre of the diencedy and lampmetten charing systen eint-Generic Letter Sp-06, Attachment 4, pooltlen anmesty. Be further W C eutesse er refustlets autesse. Relief mee srented 2, "Atternative to putt slew Testing of actfen le roupsfred.
with the prenriefen that the licensee part-stroke Coock Wetwas.* In additlen, this retlef esercioso the wolves to the epen peeltlen with roupseet mes revloed to add the following fleu efter they have been resseembled. The steff stetement to the etternate teste settlen:
recemanded that the Licensee actively inweettsete
"...pertlet stroke will be perferemd after methods, other then disemeenhty and Inspectlen, of volve re-nosambly."
werifyleis the eteauro cesablIIty of these weivos.
Itse 12 h licensee rosysmeted retlef from the Code stroke Thle relief resysset and the escociated telve h ticerose's revised (41.vam-2) timing reupstrumente for ADS wetwee PSV tables more revlead to add stroke flee retlef reepsmet included jf2)F91M, N, K, N, and S.
Sellef mee srented roupstremente In the apen directlen fer the use of a otroke flee with the provielen that the licensee emelys e retlef wolves PSV-41-1(2)F913E, 5, K. N, teet but a smalanse f
eenismes stroke ties tielt to these volves that le eraf f.
N etrate time test will be tielting stroke time mes hosed en preview test date and vertfy that they censkseted charine restert efter rehseline not escfoned as directed stroke within thet tielt amaring testing. N sucesse Isr tleins the Intervet between by the march 5,1991, SE.
amasured stroke timme need not be trended or enersiting the pitee volve and aceuttes The previelenet rettat hoe compere to previous voluso, but If the emeless emniterleis slotectlen en the telt pipe.
esipired; hemover, becomme tielt is emceeJed, the wetwe should be efectered these vetwee are tested en insperable and correcttwo actlen taken in a refuellns outese accereimnce with IW-341T(b).
fresssency, the previel wmi retlof le estended until the busInning of the nest refuelleg autase for each entit. Prior to thle autase, the Ifcensee unst aselys e emeless tietting stroke ties and Incorporate it into this retlef reupsmet.
Ites 13 nellef uma denied for esercising the core aprey setlef respamet 52-von-1 uma revloed to setlef seanted (f)(6)(1).
(52-wee-1)
Injectlen cht ' volve, sv-52-1(2)cs to the open provide addittenet Jwtificetten for not
~
peeltlen sharleg refuellns outesse amins a testing syserterly or marins cold shutdemne.
chainfelt. me Justificetten mes provided by the In additlen, this relief reupsmet mes revloed ticeners thet demmnstrates esercleing thle check to provide further clarificetten that vetve to the apen peeltlen epsorterly or sisring samnuelty stroking the wetwe will be cold shutdemme neutd be leprocticet er iseutd perfereed in accordance with ASIE Section-result in herdahlp without a campensating incrosse II, Peresreph IW-3522(b) roupstremente.
In oefety or epselity. -
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a-t a.
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Itse Reiher Deestiptiert of Assemely la E E.
~ LlanelsdL Actlene se Deserthed 9m Seeminieg l
anspost er '
eenyense so monettee seemd say 1, wet aessee '
motief
- seemd seweh 3, wn j
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Item 14 The licensee reynoted retlef from the Code stroke The Interte relief that ene greened for thle Generic Letter (EL) SP-M, f
(90-vmR-1) tielne roupstegnente for the aternary see treeteent relief respmot hos noe espired. Thle retlef Peeltleir.6, el -
t accese end pgen sigpty feetetten votwee, SV respeet is beleg deleted frem the E37 accepteide etternettvee i 4
M54, -MSS, -862, and -M75.
N ticensee's Program in Addeneen 1 to eevielen 3 of the for otroke time j
preposet of emersletng sad felt-sefe teettre these progree. Stroke ties teetleg for the volves
_.- - _.;o of rep 5d-vetwas aperterty withewt streme time emeeurement aseecleted with thle retlef tagsmet le heleg acting wolves. The provides no moene of detectirg volve degradotten.
perfereed la acceedence with the applicable aptierno discanned In thle Interie retlef use crented to attee the licensee ASME Sectlen XI rWremerns and the E4. peeltlen are a to continue the caerrent teettre edelle guiderce provided in sec Geratic Letter heletten frea the Code Investigatire acceptable etternatives to otroke 89-M es appropriete.
roupdramente and eheidd he
[
time testing.
d - M ed In the IST progree. Use of a retlef l
regses* :s e typteet
)
teethod of Wirg l
devlettens thet rely en GL v
l 89-M for acceptable etternatives. ey removing thle retlef regsmet, the licensee sheadd either d
W the devletten In the IST program er he in,
f l-compilers with AssE t
Sectlen II, Peregraph TW-
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i Item 15 In a proposed Technical Spec 5ficetten charge dated For purpeees of IST, preocure decay testine The IIcensee hem addressed i,
(centret red senesdner 17,198F, the Philadelphie Electric le used in lieu of specified teettese teettne the concorris of the l
drlwe scram Cooperar Indicated that the screr accieeutater check se ett 185 ocree scenadeter check volves enmest y.
so further sec are-deter wolves are tested for cteeure by perferette e can he tested siendtensenely. The actim le respdred.
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ehach weives) pressure decer teet for e perled of 30 escende.
ecceptance criterle for themse vetwee le aos semover, the endimittet did not ireficate the oceandeter pressure decer not to enceed 195 I
etteuebte preneure decay over this time Intervet.
pel in 30 seconde.
l In additten, these votwee eheutd t+ categorized A/C in the Licensee's 187 program.
The applicebte IST program vetwo totdeo have e
i-been revloed to Ireticate thet these volves i
l are Category A/C wolves. Atee, cetd i
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shutsenet justificetten 47-VCS-1 hee been j
rewf ood to tradicate that these vetwee are Category A/C wolves.
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