ML18066A626

Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995

ML18066A626
Person / Time
Site:	Palisades
Issue date:	08/26/1999
From:	Haskell N CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9909070157
Download: ML18066A626 (7)

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A CMS Energy Company Palisades Nuclear Plant Tel: 616 764 2276 27780 Blue Star Memorial Highway Fax: 616 764 3265 Covert, Ml 49043 Nathan L. Haskell Director, Licensing August 26, 1999 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk.

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DOCKET 50-255 - LICENSE DPR PALISADES PLANT INSERVICE TESTING PROGRAM -VALVE RELIEF REQUEST 33

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On March 5, 1996, Consumers Energy submitted its third 120-'fnOnth interval inservice testing (IST) program for the Palisades Plant. On August 30, 19.96, the NRC

• responded with their Safety Evaluation Report (SER) of the relief requests contained in that program.

An additional new valve relief request (VRR) is attached for approval in accordance with the requirements of 10 CFR 50.55a(a)(3)(i) as an alternative to the Code requirements th9t will .provide an acceptable level of quality and safety. This VRR would allow the use of Appendix II "Check Valve. Condition Monitoring Program" of the ASME OM Code-1995 Edition (with the 19~6 Addenda (OMa-1996)) as an alternative to the specified ASME/ANSI OM-1'987, Part 10 (with the 1988 Addenda (OMa-1988)) test requirements.

This VRR (No. 33) is numbered consecutively within the lnservice Testing Program for

• valve testing and follows the last VRR (No. 32) which was submitted on June 3, 1997.

• This relief request is similar to 'Otber relief requests that were approved for Wolf Creek on November 26, 1*997, andforPaloVerde*oA July 8, 1999.

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SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

Nathan L. Haskell Director, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Attachment

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 INSERVICE TESTING PROGRAM -VALVE RELIEF.REQUEST 33 4 Pages

RELIEF REQUEST BASIS NUMBER33 SYSTEM: Various Check Valves VALVES: Various Check Valves and Groupings defined by Application, Design, and Service. The applicable check valves and groupings are described in the IST program document EGAD-EP-09, "lnservice Testing Program Testing Basis Document."

CATEGORY: AC ore CLASS: All (1, 2, 3)

FUNCTION: The applicable check valves have various safety-related functions as described in the IST program document EGAD-EP~09*, "lnser:vice Testing Program Testing Basis Document."

TEST REQUIREMENT:

The test requirements from the fo'llowing ASME/ANSI OM-1987 (with OMa-1988 Addenda), Part 10 sections will pe affected by adopting the mandatory requirements in Appendix II, "Check Valve Condition Monitoring Program" contained in the ASME OM Code-1995 Edition (with OMa-1996 Addenda): ,

Section 4.3.2 Exercising Tests for Check Valves 4.3.2.1 Exerds'in1g' Test Frequency.

4.3.2.2 Exercising Requirements.

4.3.2.3 Valves in Regular Use.

4.3.2.4 Valve Obturator Movement.

4.3.2.5 Valves in Systems Out of Service.

4.3.2.6 Corrective Action.

5 ACCEPTANCE CRITERIA AND CORRECTIVE ACTION 6 RECORDS AND REPORTS 6.1 Valve Records.

6.2 Test Plans.

6.3 Record of Tests.

6.4 Record of Corrective action.

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RELIEF REQUEST BASIS NUMBER 33

• BASIS FOR RELIEF:

BACKGROUND The ASME Operations & Maintenance Code Committee, the Nuclear Industry Check (NIC) Valve Group, and the Nuclear Regulatory Commission (NRC) have completed the task of improving the requirements for inservice testing of check valves. This effort has resulted in the development of the performance-based, "Check Valve Condition Monitoring Program" in Appendix II of the 1996 Addenda (OMa-1996) to the ASME OM Code-1995 Edition. This performance-based program chang~d the G~rrent prescriptive code requirements for check valves to a controlled method that will i;>redictively monitor check valve conditions. Savings in both man-hours and personnel* radiation dose can be realized over the currently required time-directed approach using the improved testing techniques and methodologies in the performance-based prograr;n.

The industry trend in check valve problems has continued to decline. Performa_nc,e- .

based* (condition monitoring) versus time-directed techniques have proven to be more effective in detecting and monitoring degradation, thereby assuring future performance.

more reliably. Performance-based testing is an improved approach for degradation detection prior to failure.

• JUSTIFICATION In* order to take advantage of the performance-based code and to avoid a duplication of efforts, relief is being requested in accordance with 10 CFR 50.55a(a)(3)(i) as an alternative which provides an acceptable level of quality and safety.* This relief will.

implemgnt Appendix II to ASME OMa-1996, "Check Valve Condition Monitoring Program." The.proposed testing alternatives therefore provide an acceptable level of quality and safety, in accordance with current Code requirements and the final rule revisions to 10 CF.R 50.55a, . directed by COMEXM-99-001, issued on June 24, 1999.

Appendix II has a corrective maintenance type measure that requires re-evaluation of the test!?, examinations, and other maintenance activities intervals after each activity is performed. This is done to determine if any changes in the optimized condition monitor:ir,ig apaly~is are required. Sufficient data must exist to determine the intervals for condition monitoring activities. The initial interval for tests and associated examinations are established per Appendix II and the proposed alternative test modifications. Trending and analysis of existing data is used to reduce or to extend the interval time between activities.

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RELIEF REQUEST BASIS NUMBER 33 While Appendix II is in effect, the open and close capability may be obtained from activities such as:

• Nonintrusive tests that analyze both open and close design function capabilities

• Disassembly of a valve that determines the ability of the disc to stroke in both the open and close positions

• A corroboration of other testing methods (e.g. leak rate testing for close, and full flow testing or design accident flow testing for open).

Other t~st methods useq to assess valve condition and acceptable performance must be equally effective tb thos*e identified here, and must be documented in the check valve condition mon'itoring analysis.

ALTERNATIVE TESTING:

Check valves selected for the condition monitoring. progr~rn. in lieu of traditional ASME Code exercising, Will comply with ASME OMa-1996, Appendix II, "Check Valve Condition Moniforing Program."

The following modifications will be additionally imposed for using Appendix II:

1. Check Valve obturatot movement will be tested, examined or verified in

'both the open and closed direction to ensure* unambiguous detection of functionally*degraded check valves. 0Ma,,J988.Addenda to ASME:/ANSI OM~1987, Part 10 Section 4.3.2.4 will be* used to det~rmin~ valve

• obturator movement requirements.

2. Initial IST interval must be. !inii.ted to two fuel cycles or ~hree years ..

Subsequent extended interva_ls must be limited to one fuel cycle per extension up to 10 years. In no case will the test or examination interval for an individual valve exceed 120 months. *. *

3. If it is decided .to di~continue the "condition monitoring program" on a valve or grouping of valves, the testing and examinations will revert back to OMa-1988 Addenda to ASME/ANSI OM-1987, Part 10 Section 4.3.2, "Exercising Tests for Check Valves," Section 5, "Acceptance Criteria and Corrective Action," and Section 6, "Records and Reports." This is the current approved IST Program requirement at Palisades.

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RELIEF REQUEST BASIS NUMBER 33 BASELINE DATA:

Each check valve or grouping will have an initial baseline condition monitoring analysis performed, with the tests and examinations and their intervals established based on technically justified results.

STATUS:

Submitteq as a prqposed alternative in accordance with 10 CFR 50.55a(a)(3)(i) and cannot be implemented until approved by the NRC.

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