ML14188B238
| ML14188B238 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/22/1986 |
| From: | Requa G Office of Nuclear Reactor Regulation |
| To: | Utley E Carolina Power & Light Co |
| References | |
| TAC-61653 NUDOCS 8610010141 | |
| Download: ML14188B238 (11) | |
Text
September 22, 1986 Docket No.:
50-261 DISTRIBUTION Docket File N. Thompson NRC PDR G. Requa Mr. E. E. Utley, Senior Executive Vice President Local PDR D. Miller Power Supply and Engineering & Construction PAD#2 Rdg ACRS (10)
Carolina Power and Light Company T. Novak Tech Branch Post Office Box 1551 OGC-Bethesda Gray File Raleigh, North Carolina 27602 E. Jordan B. Grimes
Dear Mr. Utley:
J. Partlow
SUBJECT:
H. B. ROBINSON 2 - PUMP AND VALVE INSERVICE TESTING PROGRAM, REQUEST FOR ADDITIONAL INFORMATION (TAC NO. 61653)
We have reviewed your May 2, 1986 Inservice Testing Program submittal.
In order to complete our review, we request your response to the enclosed questions and comments within 90 days after receipt of this letter.
Our staff is available to meet with your staff to clarify our position on this subject.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, Glode Requa, Project Manager PWR Project Directorate #2 Division of PWR Licensing-A
Enclosure:
As stated cc w/enclosure:
See next page PM:PA PD:P D2 91 er GReq (
LRubenstein 86 9/(
9/'>/86 8610010141 860922 PDR ADOCK 05000261 P
Mr. E. E. Utley Carolina Power & Light Company H. B. Robinson 2 cc:
Thomas A. Baxter, Esquire Mr. Dayne H. Brown, Chief Shaw, Pittman, Potts and Trowbridge Radiation Protection Branch 1800 M Street, N.W.
Division of Facility Services Washington, DC 20036 Department of Human Resources 701 Barbour Drive Raleigh, North Carolina 27603-2008 Mr. McCuen Morrell, Chairman Darlington County Board of Supervisors Mr. Robert P. Gruber County Courthouse Executive Director Darlington, South Carolina 29535 Public Staff - NCUC P.O. Box 29520 Mr. H. A. Cole Raleigh, North Carolina 27626-0520 Special Deputy Attorney General State of North Carolina P.O. Box 629 Raleigh, North Carolina 27602 Mr. D. E. Hollar Associate General Counsel Carolina Power and Light Company P.O. Box 1551 Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Commission Resident Inspector's Office H. B. Robinson Steam Electric Plant Route 5, Box 413 Hartsville, South Carolina 29550 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street Atlanta, Georgia 30303 Mr. R. Morgan General Manager H. B. Robinson Steam Electric Plant Post Office Box 790 Hartsville, South Carolina 29550
H. B. Robinson, Unit 2 IST Program Review A.
General Questions and Comments
- 1. Are all valves that require an Appendix J, Type C, leak test included in the IST program and categorized A or A/C?
- 2. Is H. B. Robinson Plant required to have an operational safety grade post accident sampling system? If so, the associated valves should be included in the IST program and be tested in accordance with Section XI.
- 3.
Does the control room ventilation system perform any safety-related function? If so, the appropriate support system valves should be included in the IST program.
- 4. The NRC staff will grant relief from the trending requirements of Section XI (Paragraph IWV-3413(c)) for rapid acting valves, i.e.,
those valves that stroke in 2 seconds or less, however, in order to obtain this relief the licensee must assign a maximum limiting stroke time of 2 seconds to those valves. Are any valves in the H. B. Robinson IST program affected by this staff position?
- 5.
Does the spent fuel pool cooling system perform a safety-related function at H. B. Robinson? If so, the appropriate pumps and valves should be included in the IST program and tested in accordance with the requirements of Section XI.
- 6.
Are any valves in the H. B. Robinson Plant required to be identified as pressure boundary isolation valves and categorized A or A/C as appropriate?
1
B. Main and Extraction Steam Systems
- 1. Describe the method utilized to verify the full-stroke capability of valves MS-261A, B, and C.
- 2.
Do valves MS-263A, B, and C perform a safety-related function in both the open and closed positions? How are these valves individually full-stroke exercised?
C.
Feedwater, Condensate, and Air.Evacuation Systems
- 1. Does valve AFW-9A, turbine driven auxiliary feedwater pump minimum flow line check, have to change position to provide pump protection during low flow conditions?
- 2. Review the safety-related function of the following valves to determine if they should be included in the IST program.
FCV-1424 (AFW-45)
(C-4)
FW-8A (F-6)
FCV-1425 (AFW-46)
(B-4)
FW-8B (E-6)
FCV-6416 (AFW-26)
(D-4)
FW-8C (D-6)
D.
Service and Cooling Water System
- 1. What is the safety-related function of valves 261 and 272 since valves 259 and 263 are shown normally shut?
- 2. What is the frequency of the reverse flow testing being performed to verify that valve 541 shuts?
- 3.
Valve disassembly and mechanically exercising the disk on a sampling basis each refueling outage is an acceptable alternate testing method for demonstrating proper operability of check valves individually. Relief Request 5.3.6 will be affected by this staff position.
2
e
- 4. Concerning valve 544, the NRC staff position is that disassembly/inspection should be performed during each refueling outage. The staff cannot justify an inspection interval longer than each refueling outage until the results of those inspections are supplied by the licensee in the form of a relief request that must subsequently be reviewed and approved before implementation. Relief Request 5.3.5 will be affected by this staff position.
- 5.
How is valve 545 verified.to shut during power operation?
- 6. Review the safety-related function of the following valves to determine if they should be included in the IST program?
V6-95A (B-6)
V6-95C (B-5)
V6-95B (B-7)
V6-95D (C-6)
E.
Fuel Oil System
- 1. Would failure of one of the two parallel fuel oil valves, FO-27A and FO-29A, or FO-27B, in the closed position be detected during the testing presently being performed? Reference Relief Request 5.3.12.
F. Penetration Pressurization System
- 1.
Provide the P&ID that shows the location of valves 274D and 275D.
- 2.
Valve EV-1721B is not identified as a Category A, passive, valve, therefore, it's stroke time must be measured quarterly.
- 3. Why are valves EV-1723 and -1724 identified as Category A, passive, and exercised without stroke timing during cold shutdowns?
3
- 4. Valves EV-1727 and -1728 are not identified as Category A, passive, valves, therefore, their stroke time must be measured quarterly.
- 5.
Valve EV-1743 is not identified as Category A, passive, therefore, its stroke time must be measured quarterly. Why is this valve exercised only during cold shutdowns?
G.
Isolation Valve Seal Water System
- 1. Why are all the check valves in this system categorized B/C instead of C?
Do any of the check valves listed have to change position to perform a safety function?
- 2.
Should valve AOV-26-E be categorized B instead of BC?
Do these air operated valves have a required fail-safe position?
H.
HVAC - Turbine, Fuel Auxiliary, and Reactor Building Systems
- 1. Provide a detailed technical justification for not full-stroke exercising valves V12-6, -7, -8, and -9 quarterly during power operation.
- 2.
Provide a detailed technical justification for not full-stroke exercising valves V12-12 and -13 quarterly during power operation.
I. Primary Sampling System
- 1. Is Category A valve 959 leak tested? Should this valve be Category B instead of Category A?
J.
Component Cooling Water System
- 1. Provide a more detailed technical justification for not full-stroke exercising valves 716-A and -B quarterly during power operation.
4
- 2. What are the consequences of a "disruption of flow" while exercising valve 730?
Can this valve be full-stroke exercised during power operation?
- 3. Provide a more detailed technical justification for not full-stroke exercising valves FCV-626 and 735 quarterly during power operation.
- 4.
Review the safety-related function of valves 737-A and 739 to determine if they should be categorized A. Do these valves have to change position to peFform their safety function?
K.
Chemical and Volume Control System
- 1. Provide a more detailed technical justification for not full-stroke exercising valves 202-A and 282 quarterly during power operation.
- 2.
Clarify the justification for exercising valves 204-A and -B during cold shutdowns on Page 1 of 7. Attachment 6.25, i.e., is normal charging flow secured periodically?
- 3. What is the safety-related function of valve 292-A?
- 4. Provide a more detailed technical justification for not full-stroke exercising valves 293-A, 293-C, and 295 quarterly.
- 5. Are the valves 297-A, -B, and -C locked or secured in a throttled position?
- 6. Provide a more detailed technical justification for not full-stroke exercising valve 351 quarterly during power operation.
- 7. How is full-stroke exercising of valves 397-A and -B verified quarterly?
5
- 8.
Should the justification for full-stroke exercising valve LCV-115-C during cold shutdowns be the same as that for valve 266?
- 9.
Review the safety-related function of valve HCV-121 (F-3) to determine if it should be included in the IST program.
- 10.
Are valves 312-C (F-5), 311 (E-7), and 313 (E-8) required to be operable to satisfy the requirements of Branch Technical Position RSB 5-1, "Design.Requirements of the Residual Heat Removal System"?
- 11.
Review the safety-related function of valves 298-D (B-8),
-E (B-6), and -F (B-5) to determine if they should be included in the IST program and categorized A/C.
L. Liquid Waste Disposal System
- 1.
Should valve 1713 be categorized A/C instead of C?
- 2. Why is Category A, passive, valve 1793 exercised quarterly?
- 3.
What is the safety-related function of valve 1966?
M.
Safety Injection System
- 1.
Provide a more detailed technical justification for not full-stroke exercising valves 845-A and -B quarterly. The justification for not exercising these valves does not agree with the exercising frequency of valves 844-A and -B stated on Page 1 of 9 Attachment 6.18, since it was stated that these four valves must be exercised simultaneously.
- 2.
Review the safety-related function of valves 860-A, -B, 861-A, and -B to determine if they should be categorized A.
6
- 3.
Do valves 868-A, -B, and -C have to change position to perform a safety function?
- 4. Valve disassembly and mechanically exercising the disk on a sampling basis each refueling outage is an acceptable alternate testing method for demonstrating proper operability of individual check valves.
The staff will not grant relief to never full-stroke exercise a safety-related valve. Relief Request 5.3.14 will be affected by this staff position.
- 5. Concerning valves 875-D, -E, and -F, the NRC staff position is that the sample disassembly/inspection should be performed during each refueling outage. The staff cannot justify an inspection interval longer than each refueling outage until the results of those inspections are supplied by the licensee in the form of a relief request that must subsequently be reviewed and approved before implementation. Relief Request 5.3.3 will be affected by this staff position.
- 6. How are valves 876-A, -B, and -C individually verified to full-stroke exercise during cold shutdowns?
- 7. What is the safety-related function of valves 883-L and 883-W?
- 8.
How are valves 889-A and -B full-stroke exercised?
- 9.
Describe the method utilized to verify the full-stroke capability of valves 890-A and -B. Reference Relief Request 5.3.8.
- 10.
Describe the method utilized to verify the full-stroke capability of valves 899-D and -E. Reference Relief Request 5.3.11.
- 11.
Review the safety-related function of the following valves to determine if they should be included in the IST program.
7
893-A (D-6) 839 (0-4) 893-B (E-6) 856-A (E-3) 893-C (G-6) 856-B (E-3)
N.
Residual Heat Removal System
- 1. Review the safety-related function of valves 744-A, -8, 750, and 751 to determine if they should be categorized A.
- 2.
Review the safety-related.function of valves FCV-605 (D-7) and HCV-758 (E-8) to determine if they should be included in the IST program.
- 1. Provide a detailed technical justification for not full-stroke exercising valves 567, 568, 569, 570, 571, and 572 quarterly during power operation.
- 2.
Are valves PCV-455-C and -456 used for low temperature-overpressure protection?
P.
Containment Vapor and Pressure Sampling System
- 1.
Should valve VCT-22 be included in the IST program and categorized A, passive?
Q.
Post Accident Containment Venting System
- 1.
Identify the valves affected when full-stroke exercising valve PCV-1716 during power operation.
- 2. What is the P&ID location of valve V8-5?
8
PUMPS
- 1. The NRC staff position concerning instrumentation is that lack of installed instrumentation is not an adequate justification for long term relief from performing the Section XI required testing. Pump Relief Request 5.2.3 will be affected by this staff position. Why is relief requested from measuring differential pressure on the service water pumps when no discussion of the request has been provided and.1 indicates that differential pressure is measured during testing?
- 2. In reference to Relief Requests 5.2.4 and 5.2.8, the staff position is lack of installed instrumentation is not a suitable long term justification for not performing the required Section XI testing. In addition, the staff requires that all parameters from Table IWP-3100-1 be measured or observed during pump tests unless specific relief has been requested and granted.
- 3.
What is the significance of the "R" in the differential pressure column for the service water booster pumps, SWBP-A and -B, on.1, Page 3?
- 4.
Is lubricant level or pressure observed during the testing of the boric acid transfer pumps and the diesel fuel oil transfer pumps?
9