ML18005A231

Rescinds 871030 Relief Request & Forwards Cold Shutdown Justification as Rev 3 to Inservice Pump & Valve Testing Program to Support Vent Valve Testing.Valves Will Be Tested Per ASME Code Requirements.Valves in Modes 1-4 Impractical

ML18005A231
Person / Time
Site:	Harris
Issue date:	12/04/1987
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NLS-87-274, NUDOCS 8712110047
Download: ML18005A231 (14)

Text

Q 0cll PA~+ CE ~+ 5 I p~~L= Qp3p cg C~L Carolina Power 8 Light Company OEC 04 t987 SERIAL: NLS-87-270 United States Nuclear Regulatory Commission ATTEiNTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICEiVSE NO. NPF-63 IN-SERVICE PUMP AND VALVETESTING (IST) PROGRAM Gentlemen:

On October 30, 1987, Carolina Power R Light Company (CPRL) submitted a code relief request regarding testing of the Reactor Coolant System (RCS) vent valves during refueling rather than quarterly. Based on further review, CPRL has determined that these valves can be tested on a cold shutdown basis. Therefore, CPRL herein rescinds the October 30, 1987 relief request and submits as a supplement to Revision 3 of the IST program, the attached "cold shutdown justification" to support testing the vent valves at cold shutdown. It is CPdcL's intent to incorporate this change into the IST program, effective December 22, 1987. Thereafter, the valves willbe tested in accordance with ASME Code requirements at cold shutdown [Ref. IWV-3~10 and IWV-3012 (a)]. The attached cold shutdown justification is provided for your review.

The RCS High Point Vents are required by NUREG-0737, "Clarification of TMI Action Plan Requirements, Item II.B.I n As required by NUREG 0737, these valves provide a means to vent noncondensible gases from the RCS which may inhibit core cooling during natural circulation. The scenarios for which these valves would be used are beyond the design basis of the plant. Use of these valves is covered by emergency operating procedures as required by NUREG-0737. Also, as required by NUREG-0737, the vents must not lead to an unacceptable increase in the probability of a loss-of-coolant accident and must be designed to ensure a low probability of inadvertent or irreversible actuation. The SHNPP design (refer to attached Figure) consists of six solenoid-actuated, pilot-operated valves. The valves are normally closed and provide a double RCS barrier. The valves vent to the containment or the Pressurizer Relief Tank (PRT). The only routine use of the valves occurs during filland vent of the RCS.

Technical Specification 3.0.11 requires that one vent path from the reactor pressure vessel head and one vent path from the pressurizer be operable and closed during operation. Technical Specification 0.0.11.2.a requires testing of the vent valves every 18 months. The In-service Testing program required by Technical Specification 0.0.5 requires testing of these valves quarterly. Testing of the valves with the RGS pressurized could result in a limited but uncontrolled blowdown should the associated upstream or downstream valve fail, inadvertently open, or experience excessive leakage during

.testing. -The result would be a loss of RCS inventory to the pressurizer relief tank or containment atmosphere in excess of Technical Specification 3.0.6.2.d limits, possibly resultin i utdown.

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Testing at power (i.e., with the RCS pressurized) has demonstrated that a scenario exists by which the block valves can be forced open during testing of the upstream vent valve(s). This is due to a combination of valve test sequencing, timing, and the particular characteristics of the valve's fluid-assisted operation.

This scenario has been addressed by an orientation change of the block valves and changes in the test procedure. These changes will improve the reliability of these valves by: 1) reducing the time necessary to fully reseat the valve discs and 2) by not challenging the valves before the discs are fully reseated.

Given that these valves are not assumed to operate in design basis accidents and the potential consequences of testing them at full system pressure, testing of these valves at power is contrary to both the goal of maintaining double isolation of the RCS and the NUREG-0737 requirement to ensure a low probability of inadvertent or irreversible actuation of the valves. For the above reasons, testing these valves in Modes 1-0 is impractical.

N If you have any questions please contact Steven D. Chaplin at (919) 836-6623.

Yours very truly, S.. Zi me.man nage.

Nuclear Licensing Section SDC/bmc (5307SDC)

Attachment cc: Mr. B. C. Buckley Dr. 3. Nelson Grace Mr. G. F. Maxwell

COLD SHUTDOWN TEST 3USTIFICATION System: Reactor Coolant CS-2 Valves: IRC-900, 90l, 902, 903, 900, 905 Category: B Class:

Function: RCS Vent Valves Test Requirement: Exercise valve for operability, observe proper operation of fa!1-safe actuator and measure stroke time quarterly.

Cold Shutdown VaLves are RCS High Point Vent Valves, which were installed in Justification: response to NUREG 0737, Item II.B.L and are designed onlv to vent noncondensible gas produced by a "beyond design basis accident" from the RCS. These valves are only routinely used during cold shutdown to provide a path for normal RCS venting prior to heatup.

Technical Specification 3.0.LL requires that one vent path from the reactor pressure vessel head and one vent path from the pressurize. be ope.able and closed durin~ ope.ation. Technical Specifications requires testing oi the vent valves every LS months. Testing oi the valves during power ope.ations could result in a, limited but uncontrolled blowdown should the associated upstream or downstream valve fail, inadvertently open, or experience excessive leakage. The result would be a, loss of RCS inventory to the pressurize. relief tank or containment atmosphere in excess of Technical Specification 3.0.6.2.d limits, possibly resulting in unit shutdown.

Quarterly Part None. These valves are not equipped with part stroke Stroke Testing: exerciser s.

Alternate Test: Exercise valve for operability, observe proper operation of fail-safe actuators, and measure stroke time during a cold shutdown, if not performed within the previous 92 days.

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REGUL* Y INFORMATION DISTR IBUTIO YSTEM (RIDS)

V~'CCESSION NBR: 8712110047 DOC. DATE: 87/12/04 NOTARIZED: NO DOCKET 0 FACIL: 50-400 Shearon Harv is Nuclear Power Planti Unit ii Carolina 05000400 AUTH. NAME AUTHOR AFF ILlATION ZIMMERMANiS. R. Carolina Power 5 Light Co.

RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards cold shutdown test gustification submitted as supl to Rev 3 of in-service pump 8a valve testing program to support testing vent valves at cold shutdown.

DISTRIBUTION CODE: A047D COPIES RECEIVED: LTR ENCL j SIZE:

TITLE: OR Submittal: Inservice Inspection/Testing NOTES: Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 0 PD2-1 PD 5 5 BUCKLEY'S B 1 1 INTERNAL: AEOD/DOA 1 1 AEOD/DSP/TPAB 1 ARM/DAF/LFMB 0 .NRR/DEST/MEB NRR/DEST/MTB OGC/HDSi 1

1 1

1, 0

NRR/PMAS/ ILRB 01 1

1 1

1 RES/DE/EIB 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL ih

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SRK Carolina Power & Light Company DEC 04 $ 87 SERIAL: NLS-87-270 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-63 IN-SERVICE PUMP AND VALVE TESTING (IST) PROGRAM Gentlemen:

On October 30, 1987, Carolina Power 4 Light Company (CPRL) submitted a code relief request regarding testing of the Reactor Coolant System (RCS) vent valves during refueling rather than quarterly. Based on further review, CPRL has determined that these valves can be tested on a cold shutdown basis. Therefore, CPRL herein rescinds the October 30, 1987 relief request and submits as a supplement to Revision 3 of the IST program, the attached "cold shutdown justification" to support testing the vent valves at cold shutdown. It is CPRL's intent to incorporate this change into the IST program, effective December 22, 1987. Thereafter, the valves will be tested in accordance with ASME Code requirements at cold shutdown [Ref. IWV-3010 and IWV-3012 (a)]. The attached cold shutdown justification is provided for your review.

The RCS High Point Vents are required by NUREG-0737, "Clarification of TMI Action Plan Requirements, Item II.B.1." As required by NUREG 0737, these valves provide a means to vent noncondensible gases from the RCS which may inhibit core cooling during natural circulation. The scenarios for which these valves would be used are beyond the design basis of the plant. Use of these valves is covered by emergency operating procedures as required by NUREG-0737. Also, as required by NUREG-0737, the vents must not lead to an unacceptable increase in the probability of a loss-of-coolant accident and must be designed to ensure a low probability of inadvertent or irreversible actuation. The SHNPP design (refer to attached Figure) consists of six solenoid-actuated, pilot-operated valves. The valves are normally closed and provide a double RCS barrier. The valves vent to the containment or the Pressurizer Relief Tank (PRT). The only routine use of the valves occurs during filland vent of the RCS.

Technical Specification 3.0.11 requires that one vent path from the reactor pressure vessel head and one vent path from the pressurizer be operable and closed during operation. Technical Specification 0.0.11.2.a requires testing of the vent valves every 18 months. The In-service Testing program required by Technical Specification 0.0.5 requires testing of these valves quarterly. Testing of the valves with the RCS pressurized could result in a limited but uncontrolled blowdown should the associated upstream or downstream valve fail, inadvertently open, or experience excessive leakage during testing. The result would be a loss of RCS inventory to the pressurizer relief tank or containment atmosphere in excess of Technical Specification 3.0.6.2.d limits, possibly resulting in unit shutdown.

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Testing at power (i.e., with the RCS pressurized) has demonstrated that a scenario exists by which the block valves can be forced open during testing of the upstream vent valve(s). This is due to a combination of valve test sequencing, timing, and the particular characteristics of the valve's fluid-assisted operation.

This scenario has been addressed by an orientation change of the block valves and changes in the test procedure. These changes will improve the reliability of these valves by: 1) reducing the time necessary to fully reseat the valve discs and 2) by not challenging the valves before the discs are fully reseated.

Given that these valves are not assumed to operate in design basis accidents and the potential consequences of testing them at full system pressure, testing of these valves at power is contrary to both the goal of maintaining double isolation of the RCS and the NUREG-0737 requirement to ensure a low probability of inadvertent or irreversible actuation of the valves. For the above reasons, testing these valves in Modes I-0 is impractical.

If you have any questions please contact Steven D. Chaplin at (919) 836-6623.

Yours very truly, S.. Zi merman nager Nuclear Licensing Section SDC/bmc (5307SDC)

Attachment cc: Mr. B. C. Buckley Dr. 3. Nelson Grace Mr. G. F. Maxwell

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COLD SHUTDOWN TEST JUSTIFICATION System: Reactor Coolant CS-2 Valves: IRC-900, 90l, 902, 903, 900, 905 Category:

Class:

Function: RCS Vent Valves Test Requirement: Exercise valve for operability, observe proper operation of fail-safe actuator and measure stroke time quarterly.

Cold Shutdown, Valves are RCS High Point Vent Valves, which were installed in Justification: response to NUREG 0737, Item II.B.l and are designed ~onl to vent noncondensible gas produced by a "beyond design basis accident" from the RCS. These valves are only routinely used during cold shutdown to provide a path for normal RCS venting prior to heatup.

Technical Specification 3A.ll requires that one vent path from the reactor pressure vessel head and one vent path from the pressurizer be operable and closed during operation. Technical Specifications requires testing of the vent valves every l8 months. Testing of the valves during power operations could result in a limited but uncontrolled blowdown should the associated upstream or downstream valve fail, inadvertently open, or experience excessive leakage. The result would be a loss of RCS inventory to the pressurizer relief tank or containment atmosphere in excess of Technical Specification 34.6.2.d limits, possibly resulting in unit shutdown.

Quarterly Part None. These valves are not equipped with part stroke Stroke Testing: exerciser s.

Alternate Test: 'Exercise valve for operability, observe proper operation of fail-safe actuators, and measure stroke time during a cold shutdown, if not performed within the previous 92 days.

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