ML20138B193

Submits Request for Relief from ASME Oma 1988 Part 10, Inservice Testing of Valves in Light-Water Reactor Power Plant, Requirements for WCNOC IST Program

ML20138B193
Person / Time
Site:	Wolf Creek
Issue date:	04/23/1997
From:	Muench R WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ET-97-0038, ET-97-38, NUDOCS 9704290095
Download: ML20138B193 (3)

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LF CREEK W@)NUCLEAROPERATING C April 23, 1997 Richard A. Muench Vice President Engineering ET 97-0038 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Subject:

Docket No. 50-482: Inservice Testing Relief Request No. 2VR-9 Gentlemen:

This letter submits Wolf Creek Nuclear Operating Corporation's (WCNOC) request for relief from ASME OMa 1988 Part 10, " Inservice Testing of Valves in Light-Water Reactor Power Plants," requirements for the Wolf Creek Generating Station Inservice Testing (IST) Program. This relief request is submitted in accordance with 10 CFR 50. 55a (f) (5) (iii) . Approval is requested by August 1, 1997, to support the ninth refueling outage, which is scheduled to begin on September 20, 1997. The attachment provides the relief request and supporting information.

If you should have any questions regarding this submittal, please conta ne

at (316) 364-8831, extension 4034, or Mr. Richard D. Flannigan at extension 4500.

Very truly yours, 4

4 Rich d A. Muench i RAM /jad Attachment

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cc: E. W. Mers chof f (NRC) , w/a W. D. Johnson (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a 9704290095 970423 ll.llll.li I.ll!!IlllI,ll:lll lIl lll11 c 3 .

PDR ADOCK 05000482 P pgg -- - - - - - - . . ~ .. _

PO. Box 411/ Burbngton, KS 66839 ' Phone: (316) 364-8831 An Equal Opportunety Employer M F:HC VET

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l l Attachment to ET 97-0038 l

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l RELIEF REQUEST NO. 2VR-9

! VALVE:

l BGV0135 CATEGORY:

C FUNCTION:

Provides over-pressure protection for containment penetration 24.

ASME OMa 1988 PART 10 REQUIREMENTS:

Section 1.4, " Categories of Valves," requires, " valves within the scope of this part shall be placed in one or more of the following categories.

When more than one distinguishing category characteristic is applicable all requirements of each duplication or repetition of common testing requirements is not necessary."

Subsection (c), Category C, of Section 1.4 requires that, " valves which are self-actuating in response to some system characteristic, such as pressure (relief valves) or flow direction (check valves) for fulfillment of the required function (s), as specified in para, 1.1." In addition, Table 1, " Inservice Test Requirements" and Section 4.3.1,

" Safety Valve and Relief Valve Tests," require safety and relief valves to meet the inservice test requirements of Part 1, " Requirements for

! Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices."

BASIS FOR RELIEF:

BGV0135 provides over-pressure protection for containment penetration

24. This valve relieves pressure due to thermal expansion of the fluid inside the penetration when it is isolated. The relieving path is from the penetration back to the piping inside containment. The valve meets the requirements of ASME Section III design criteria and satisfies the containment penetration thermal over-pressure protection requirements of Generic Letter 96-06. The specifications for this valve indicate that it begins opening at 10 psid. The relief valve on the piping inside containment that this check valve relieves to is set at 148 psig. The penetration that this valve protects from thermal overpressure is capable of withstanding 1718 psig. Although this valve is a pressure relieving device, it is not a safety or relief valve. This valve is a spring loaded check valve. In this application, a spring loaded check valve is more appropriate from a design standpoint than a safety or relief valve.

! Since the function of this valve is to self-actuate in response to system pressure, it must be classified as a relief valve per the categorization requirement provided in Section 1.4(c). Because this valve must be categorized as a relief valve, it must be tested in accordance with Section 4.3.1 according to Table 1.

As a check valve, this valve does not have a certified set pressure. It is therefore impractical to expect the valve to perform to the level of repeatability between tests necessary to meet the requirements of i

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l Attachment to ET 97-0038 l Page 1 of 2 i

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d Section 4.3.1. This valve is not capacity certified and no means is provided for the adjustment of valve set pressure. The function of the spring in the check valve is to prevent valve flutter during normal operation which would cause valve degradation.

ALTERNATIVE TESTING:

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. A check valve open test will be performed in conjunction with the containment isolation valve testing performed to meet the requirements of ASME OMa 1988 Part 10 section 4.2.2.2, which references 10 CFR 50, j Appendix J. Wolf Creek performs leak testing using 10 CFR 50, Appendix J, Option B. The valve test frequency will be in accordance with the 10

, CFR 50, Appendix J, Option B requirements. Following the containment

isolation valve seat leakage test, the system valve alignment shall be changed to confirm that BGV0135 opens when containment isolation seat leakage test pressure is applied.

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