1CAN129202, Forwards 90-day Response to NRC SE for Second 10-yr IST Program & Relief Requests,Revised Relief Request 10,which Provides Requested Details on Alternative Testing & Revised Relief Request 30,removing Valves Where Relief Denied

Forwards 90-day Response to NRC SE for Second 10-yr IST Program & Relief Requests,Revised Relief Request 10,which Provides Requested Details on Alternative Testing & Revised Relief Request 30,removing Valves Where Relief Denied

ML20126B856
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/18/1992
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
1CAN129202, NUDOCS 9212220249
Download: ML20126B856 (11)

Text

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December 18, 1992 F 1CAN129202

, U. S. Nuclear Regulatory Commission j Document Control Desk Mail Station P1-137

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f Washington, DC 20555 l

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Subject:

Arkansas Nuclear Ono - Unit 1 l Docket No. 50-313

License No. DPR-51 90._ Day Response to NRC 5 Safety Evaluation for Second Ten Year

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, IST Program and Relief Requests 3

i Gentlemen:

Entergy Operations has received the NRC Safety. Evaluation dated September-21, 1992, on the Second Ten Year pump and valve Inservice Testing (IST)

. Program for Arkansas Nuclear _One,. Unit.1 (ANO-1). This Safety Evaluation (SE) and the attached- Technical . Evaluation Report: (TER) reviewed the relief requests submitted by : ANO and requested a ninety _ day. response 4

providing additional justification ' for denied _ requests _. and additional information for two -provisionally approved requests. Followup responses 4

are requested within one -year- to describe- the process used in developing

-the ANO-1 IST Program and to address : ~ anomalies in the program. As-requested by the NRC: staff,-- any necessary chang 6s or- actions to resolve those anomalies that are in. agreement - with - the staff's - SE will - be

-completed within one year of the date of this letter,;or by the end of-the next refueling outage, whichever- is -later.

The attachments to this submittal provide - the information requested for the _ ninety-day : response.

Attachment:

'l provides- the_ additional-

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in formation requested' including the ANO-1 : response to - denied requests.

Attachment:

2; is revised . relief . request No. 10T which' provides the'

. requested ' ~ details 'on alternative testing.

Attachment _;3 contains a revision to request . No. 30 removing

the valves for which relief was denied and provides the additiccal irformation requested _ for thef EDG air start system valves.

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9212220249 921218 PDR P

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U. S. NRC Cecember 18, 1992

{ 1CAN129202 Page 2 4 Should you have any questions concerning this submittal, please contact-

, me.

1 Very truly yours,

- n James . Fisicato j Director, Licensing i

1 JJF/JRH/kic Attachments i cc: Mr. James L. Milhoan l Regional Administrator i U. S. Nuclear Regulatory Commission Region IV.

611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One - ANO-1 & 2 Number 1, Nuclear-Planc Road

) Russellville, AR 72801 Mr. Roby Bevan t- NRR Project Manager, Region IV/ANO-1 U. S. Naclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 Mr. Thomas W. Alexion NRR Project Manag er, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop L3-H-3 One White Flint North 111555 Rockville Pike Rockville, Maryland 20852 t

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ATTACHMENT 1 REQUEST FOR ADDITIONAL INFORMATION

1. Relief Request No. 10 e NRC Reauest Relief Request No. 10 requests relief from the remote position indication verification requirements of Section XI, Paragraph IWV-3300, for the listed solenoid operated valves. The licensee has not proposed alternate testing for these valves.

, The licensee should develop alternate means of determining valve position so the remote position indication can be verified accurate at least once every two years.

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• ANO-1 Resoonse These solenoid valves have enclosed stems and no external means of determining valve position locally. Therefore these valves cannot be - directly observed to verify the accuracy of the remote position indicators associated with them. ANO-1 therefore proposes to verify the accuracy of these remote valve position indicators using other indications as allowed by 0M-10, Section 4.1.

Attachment 2, revised Relief Request No. _ 10, provides additional information on the alternative testing for valve position indication verification.

II. Relief Request No. 28 i

e NRC Recuest Relief Request No. 28 was submitted by letter dated October-20, 1988 (1CAN108809) and has not been revised by subsequent submittals. This request is not affected by any of the positions delineated in -Attachment 1 of GL 89-04 and is, therefore approved by GL 89-04. Relief Request No. 28 requests l relief from the pump testing requirements of the Code for the diesel fuel oil transfer _ pumps. The licensee proposes to operationally test the pumps as part of the Emergency Diesel Generator (EDG). functional test and to perform a full flew test during refueling outages. [The emergency diesel fuel oil transfer pumps are centrifugal pumps.] The licensee's proposal does not provide an adequate means to monitor for hydraulic or mechanical degradation of these pumps.

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• ANO-1 Resoonse The subject pumps are positive displacement type pumps, instead of centrifugal pumps as presumed in the NRC TER. They are of the rotary gear design and operate at a nominal speed of 1200 RPM. The pumps have a rated capacity of 10 gpm. The Emergency Diesel Generators (EDG) which the fuel oil transfer pumps supply consume approximately four (4) gpm of fuel oil when operating at rated electrical output. The pumps therefore have a 250% capacity by design. The pumps discharge to day tanks located inside the EDG skid rails. These tanks are vented to atmosphere.

Each pump is automatically started and stopped by level switches on its respective day tank. Activation of the low level switch causes the pump to start while activation of the high level switch causes the pump to stop. The capacity of the day tank between these two level switches is 60 gallons.

During EDG operation the pump operates for approximately ten minutes to fill the day tank once the low level switch is

- activated and is idle for approximately 15 minutes while the day tank level is depleted. This cycle is repeated for the duration of EDG operation. The_ pump will operate for two or three such 10 minute periods during a typical EDG surveillance.

The total pump run time per EDG surveillance may then be conservatively estimated as being .30 minutes. The base frequency for EDG surveillances is once per month. By estimating a total of 18 surycillances per year, the total run time per year for each pump is 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> for routine surveillances. Accounting for refueling outage testing, inclement weather starts, auto starts, other surveillances and storage tank recirculation would conservatively yield a total annual run time of less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or a usage factor of approximately 1/2%.

Due to the limited pump run time and pump design, normal wear of - this pump would only result in gradually reduced capacity over time due to rubbing wear of the gear teeth faces. This type of wear does not typically introduce incipient failure modes beyond those present on a new pump. Because of the excess capacity present in the design, loss of. capacity due to normal wear is not_ considered to be a safety concern. However, because it is desirable to be aware of significant capacity reduction due to this type of wear, ANO-1 will continue to perform the capacity test referred to in Relief Request 28 on a refueling outage basis or following significant maintenance.

The operability limit of that surveillance is the design value of the pump capacity, 10 gpm. Therefore, the test is quite stringent in terms of acceptance criteria in that design capacity is 250% of required capacit j. In 18 years of operation, both pumps have maintained design capacity without requiring corrective maintenance or-replacement related to a.

loss of capacity.

In addition to the operational test of the pump performed as part of the EDG functional test, ANO-1 commits to perform vibration data collection and analysis on these pumps on-at least a quarterly basis. This additional test is considered adequate to further detect abnormal year, rubbit.g , bearing deterioration, gear tooth breakage and other conditions potentially affecting the operational readiness of these pumps.

In summary, due to the above decribed factors, including pump design, excess capacity, usage t e.co r and the lack of the required instrumentation to allow Code e auirements to be met, ANO-1 proposes to test the pump as follows.

1) On at least a quarterly basis pump capacity will be verified to no greater than that required for full load operation of the EDG.

2) On at least a quarterly basis vibration data collection and analysis will be performed in accordance with OM-6 requirements.

3) On a refueling outage basis and after significant maintenance a capacity test will be performed by measuring the time required to fill the day tank between two indicated tank levels. The number of gallons added to the tank is then divided .by the time in minutes required to add that volume in order to determino a pump flow rate.

III. Relici u. quest No. 30

• NRC Reauest The evaluation of Relief Request No. 30 has been broken up into two parts for clarity. The first part requests relief from the stroke time measurements of Section~XI, Paragraph IWV-3413, for the emergency diesel generator (EDG) air start valves, 'SV-5218, SV-5233, SV-5237, SV-5239, CV-5218, CV-5233, CV-5237, and CV-5239. The licensee-has proposed to stroke time test these valves indirectly by measuring the starting times of the diesel generators.

Based on the determination that compliance with the Code requirements is impractical and burdensome to the licensee, and considering the proposed alternate 1 testing, relief should be

-granted w1th the following provisions. The licensee should determine if the EDG can start in the required time with only one air start train available. If so, some method to-independently verify _the operational readiness of both sets of valves _ should- be developed and implemented within one year or -

by the next refueling outage, whichever is longer.

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The second part requested relief form the stroke time measurement requirements of Section XI, Paragraph IWV-3413 for the EDG service water cooling valves, CV-3806 and CV-3807. The licensee has proposed to verify the stroke time indirectly by the starting time of the diesel generator.

Based on the determination that the licensee has not adequately demonstrated that compliance with the Code requirements is impractical or a hardship, and that the proposed testing does not provide reasonable assurance of operational readiness, relit' should not be granted as requested.

• ANO-1 Resoonse With regards to the first part of the NRC request, Relief Request No. 30 has been revised (Attachment 3) to provide adaltional information concerning the SDG air start valves.

These valves do not have position indicating lights or other means of directly monitoring the time required for a change in valve position. Exercising of the valves is accomplished during EDG surveillances at a frequency which meets or exceeds Code requirements. The base frequency for EDG testing is once per month. Surveillance procedures are written such that every other month the EDG is started both locally and remotely. At this time local verification is performed to insure that the EDG starts from each of the two air start trains. This approach is consistent with that requested by the staff to assure verification of the operational readiness of the EDG air start valves.

In response to the second part, Service Water System valves, CV-3806 and CV-3807 have been removed from the attached relief request and testing will be performed within the ASME Code requirement.

- . 1 ATTACllMENT 2 REI,lEF REQUEST NO.10 S.5 stem / Valves: Reactor Coolay1 Svstem Vent Valves SV-1071, SV-1072, SV-1073, SV-1074, SV 1077, SV-1079, SV 1081, SV 1082, SV 1083, SV 1084, SV-1091, SV-1092, SV 1093, SV 1094 Beactor Buildinc flVAC Isglation i Valves SV-7457, SV-7459, SV-7467, SV 7469, SV-7454, SV-7456, SV-7510, SV-7512, SV-7479 Emercency Feedwater Flow Contiol Valves CV-2645, CV-2646, CV-2647, CV 2648 Sampic System Isolation Valves SV 1440, SV 1443, SV-1818, SV 1840 Main Steam to EFW Pumo Turbine Supply Valvg SV-2613 Function: Egaetor Coolant System Vent Vahrs SV-1077, SV 1079 - Pressurizer High Point Vents These solenoid operated valves are used to vent non-condensable gases from the pressurizer during startup operations and may be used whenevar reactor coolant system conditions are such that non-condensable gases may have accumulated in the pressurizer.

SV 1081, SV-1082, SV-1083, SV-1084 - RCS Loop A liigh Point Vents These solenoid operated valves are used to vent non-condensable gases from the "A" reactor coolant loop during startup and may be used whenever reactor coolant system conditions are such that non-condensable gases may have accumulated in the "A" reactor coolant loop.

SV-1091. SV-1092, SV-1093, SV-1094. RCS Loop B High Point Vents These solenoid operated valves are used to vent non-condensable gases from the "B" reactor coolant loop dunng startup and may be used whenever reactor coolant system conditions are such that non-condensable gases may have accumulated in the "B" reactor coolant loop.

SV-1071, SV-1072, SV-1073, SV 1074- Reactor Vessel High Point Vents These solenoid operated valves are used to vent non-condensable gases from the reactor vessel head during startup whencycr reactor coolant system conditions are such that non-condensable gases may have accumulated in the reactor vessel head.

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NITACllMENT 2 REl.lEF REQUEST NO.10 Reactor Buildina HVAC isolation Valves SV-7457, SV-7459, SV 7467, SV-7469 - Hydrogen Sampler Isolation Valves These solenoid operated valves serve as isolation valves for the redundant hydrogen sample systems. They are also the first valve outside the reactor building in this piping spiem and are credited with a containment isolation function.

SV-7454, SV-7456, SV-7479. RCS Leak Detectc.t isolation Valves These valves provide isolation of the monitors used for normal operation RCS leak detection. These valves are credited with a containment isolation function.

SV-7510, SV-7512 - Post Accident Sampling System (PASS) Isolation Valves These valves provide isolation of the PASS. These valves are credited with a containment isolation function.

E_m_qreency Feedwater_Elow Control Valves CV-2645, CV-2646, CV-2647, CV-2648 These modulating DC solenoid valves control the flow of EFW to the steam generators following an actuation of the Emergency Feedwater System.

Samole Sistem Isqlation Valves S

SV-1440, SV-1443 These normally closed valves provide a containmcnt isolation function for the Post Accident Sample System sample supply and return lines to and from the reactor building sump.

SV-1818, SV-1840 These normally closed valves provide a containment isolation for reactor coolant system sampling lines exiting the reactor building.

Main Steam Valve SV-2613 - Main Steam to Emerger.cy Feedwater Pump Turbine This valve is used in the startup sequence of the steam driven emergency feedwater -

pump. This valve provides a steam flow path to roll the turbine to an initial specci of -

900 RPM prior to opening of the main steam supply valve.

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ATTACilS1ENT 2 ,

REl.lEF REQUEST NO.10 Code Class: Reactor Coolant system Valves - Class 1 Reactor Buildine HVAC Valves - Class 2 EFW Flow Control Valves - Class 3 Sample Isolation Valves - Class 2 Main Steam Valve - Class 3 Code Category: Reactor Coolant System Valves - Category B j Reactor Buildine HVAC Valves -Category A EFW Flow Control Valves - Category B Samole Isolation Vahrs - Category A Main Steam Valve Category B Code Requirement: IWV-3300 VALVE PMITION INDIC-\ TOR VERIFICATION

" Valves with remote position mdicators shall be obscried at least once every 2 years to verify that valve operatio' is accurately indicated."

Relief Requested: The enclosed stem and lack of other loca. _ Ucation devices prohibits direct visual verification of valve position. ANO-1 therefore proposes to verify the accuracy of these remote valve position indicators using other indications as allowed by OM-10, Section 4.1.

Basis for Relief: These solenoid valves br c encbsed stems and no external means of determining valve position locclly. Tiierefore C.m ulves cannot be directly observed to verify the accuracy of the remote position indicators associated with them.

Alternative Testing: Valve position verification shall be performed on the subject valves by compliance with OM-10, Section 4.1, Valve Position Verification; specifically,"Where local obsen'ation is not possible, other indications shall be used for verification of valve opeiation." These 4 verifications employ system parameter indications and testing results to provide assurance that valve position is accurately indicated.

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ATTACllMENT 3 i

RELIEF REQUEST NO. 30 i

System: Emergency Diesel Generator Air Start l

l Valves: CV-5218, CV 5233, CV-5237, CV,5239, SV-5218, SV-5233, SV 5237 AND SV 5239 Fenetion: These valves comprise the means by which starting air is admitted to the Emergency 2

Diesel Ucnerators (EDG's) air start motors. An electrical signal from the EDG start circuitry causes one of the two solenoid valves associated with a particular EDG to -

l change position such that pressurized air is admitted to the pinion engagement l mechanism of the first of two air start motors arranged in series. As the pinion is

. engaged, a port is opened to allow air flow to the pinion engagement of the second air

! start motor. Air flow then continues to the associated control valve to cause it to open to -

i admit air to the vaned air start motors in order to crank the EDG. When the EDG starts,

, speed sensors cause the start signal to be removed at which time the solenoid valve repositions to isolate starting air to and depret surize the piping to the air start motors pinion engagement mechanism and the air supply control valve. This action allows the

air supply control valve to close ind the pinion to disengage from the EDG ring gear,

, One solenoid valve and one control vahc comprise one train of air start capability. An alternator switches the start signal such that the two trains operate in an alternating '

l fashion each time the start signal is generated.

Code Class: Non-Code components includ:d based on the safety function performed.

Code Category

Category B Code Requirement: IWV-3413 POWER OPERATED VALVES (b) The stroke time of all power operated valves shall be measured ta the nearest second, for stroke times of 10 seconds or less, or 10% of the specified limiting stroke for full-

stroke times longer than 10 see w henever such a valve is full-stroke tested.

Relief Requested: ANO-1 requests relief from the stroke timing requirement for these power operated vahes.-

Basis for Relief: These valves do not have position indicating lights or other means of directly -

monitoring the time required for a change ir. valve position Exercising of the valves is accomplished during EDG surveillances at a frequency which meets or exceeds Code requirements. The proper operation of the soleno..i valve and its associated air control valve can be monitored by virtue of proper starting operation of the EDG. The normal '

- time required from the receipt of a start signal for the EDG to start and achieve rated

- speed and voltage is 9 to 13 seconds based on surveillance test results. The required time per the ANO-1 Technical Specifications is less than 15 seconds. Therefore, by virtue of proper EDG starting operation, the air start solenoid and air control valves are verified to be operating properly. l i

' Alternative Testing

ANO-l will monitor proper operation of the air start solenoid and air control l valves by verification of EDG operability dt. ting the EDG surveillance. The base frequency for -  ;

EDG testing is once per month. Surveillance procedures are written such that every 1

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A'ITACllMENT 3 REl.lEF REQUEST NO. 30 other month the EDG is started both locally and remotely. At this time local verification is performed to insure that the EDO starts from each of the two air start trains. The time required to start and achieve rated speed and voltage on each train is monitored and recorded. If the requirca time is greater than 15 seconds for either train, the EDG is declared inoperable and corrective actions taken. Significant degradation or failure of any one valve would thatefore be identified by failure of the respectisc EDG to satisfy its t urveillance requirements.

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