ML17055E510
| ML17055E510 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/08/1989 |
| From: | Haughey M Office of Nuclear Reactor Regulation |
| To: | Burkhardt L NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 8902150240 | |
| Download: ML17055E510 (56) | |
Text
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'February 8, 1989 Docket No. 50-220 Mr. Lawrence Burkhardt III Executive Vice President, Nuclear Operations Niagara Mohawk Power Corporation 301 Plainfield Road
- Syracuse, New York 13212
Dear Mr. Burkhardt:
DISTRIBUTION
'RC PDR GLainas CVogan MHaughey MSlosson F.Jordan ACRS (10)
- Local PDR PDI-I Rdg BBoger LBMarsh RCapra OGC BGrimes HShaw JJohnson
SUBJECT:
INSERVICE TESTING PROGRAM FOR NINE MILE POINT, UNIT I The NRC staff and its consultants from Idaho National Engineering Laboratory (INEI ) have completed a preliminary review of the second ten year Inservice Testing (IST) Program for Nine Mile Point, Unit I submitted January 18, 1989.
Enclosed is a set of questions and comments developed as a result of that review.
The staff and its consultants would like to meet with you at the plant site on February 22 and 23, 1989, to resolve these concerns.
The enclosed list will be used as an agenda for discussions at that
- meeting, Formal responses to the enclosure are not required prior to the meeting.
However, draft responses for each of the questions should be prepared prior to the meeting and be available for the meeting discussion.
Sincerely, Original signed by
Enclosure:
NMP-1 ITP guestions and Comments Mary F. Haughey, Project Manager Project Directorate I-1 Division of Reactor Projects I/II cc:
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~.i Mr. L. BuAhardt III Niagara Mohawk Power Cor poratfon Nine Mile fnt Nuclear Station, Unit Ho.
1 CC:.
Mr. Troy R. Conner, Jr.,
Esquire Conner 8 Wetterhahn Suite 1050
';747 Pennsylvania
- Avenue, N.
W.
I.'ashinqton, D. C.
20006 Mr. Frank R. Church, Supervisor Town nf Scriba R.
D. ¹2
- Oswego, New York 13126 Mr, James L. Willis General Supt.-Nuclear Generation Nfagara Mohawk Power Corporation Nine Mile Point Nuclear Station Post Office Box 32
- Lycoming, New York 13093 Resident Inspector U. S. Nuclear Regulatory Commission Post Office Box 126
- Lycomfng, New York 13093 Mr. Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia.
Pennsylvania 19406 Ms.
Donna Ross New York State Energy Office 2 Empire State Plaza 16th Floor
- Albany, New York 12223 Mr. Kfm Dahlberg Unit 1 Station Superintendent Nine Mile Point Nuclear Station Post Office Box 32
- Lycoming, New York 13093 Mr. Peter E. Francisco, Licensing Niagara Mohawk Power Corporation 301 Plainfield Road
- Syracuse, New York 13212 Charlie Donaldson, Esoufre Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Hr. Paul D. Eddy State of New York Department of Public Service Power Division, System Operations 3 Empire State Plaza
- Albany, New York 12223
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ENCLOSURE NINE MILE POINT NUCLEAR STATION, UNIT 1
PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS 1.
VALVE TESTING PROGRAM A.
General uestions and Comments 1.
Revision 0 of the second ten year IST program for Nine Mile Point Nuclear Station, Unit 1, (NHPI) states on page I-4 that Section XI requires quarterly testing of components unless it is impractical to do so.
In Revision 1, the word "impractical" in that statement was replaced with "a burden."
Section XI permits deferral of valve testing to cold shutdowns if quarterly testing is impractical and 10CFR50.55a(g)(6)(i) authorizes the NRC to grant relief from the Code requirements if conformance is impractical.
Use of "a burden" in the identified statement may impart the erroneous idea that inconvenience is a justification for not performing Section XI testing at the Code required frequency.
What was the purpose for this program change?
2.
General Relief Request VG-3 proposes an audible indication and a drain pipe temperature measurement as means to detect the proper operation of excess flow check valves at NHP1.
The NRC has concluded that the use of audible indication does not provide an acceptable positive means'of verifying that a check valve has moved to its safety function position as required by IWV-3522(b).
The temperature measurement method may be acceptable.
Provide a more detailed description of this testing and the acceptance criteria that is utilized.
3.
The establishment of a second category of rapid acting valves, piston and diaphragm valves that stroke in 4 seconds or less (refer to General Relief Request VG-1), is not in agreement with the NRC staff position on rapid acting power operated valves.
Valves whose normal stroke times fall in the range of 2 to 4 seconds would have to vary greater than 1 second from one test to the next in order to require more
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frequent testing per IWV-3417(a).
This amount of allowed variance should more than compensate for stroke time deviations due to operator response times and normal data scatter due to changes in system conditions.
4.
General Relief Request VG-4 proposes to use the control room indicating lights to verify the proper fail-safe actuation of valves equipped with remote position indication.
This testing is in accordance with the Code and relief is not necessary as long as the applicable valves remote position indication is verified in accordance with IWV-3300.
5.
Control valves that do not have
~re aired fail-safe positions (i.e.,
credit not taken in any SAR analysis for the valve failing to a specified position),
are exempted from Section XI testing by IWV-1200.
However, if credit is taken for the fail-safe function of a control valve, it is an active power operated valve that must be tested to all of the applicable requirements of IWV-3400 and not just to the requirements of IWV-3415.
General Relief Request VG-5 is in conflict with this position.
6.
The NRC staff position is that as soon as test data is recognized as being within the required action range from Section XI, the associated component must be declared inoperable and the Technical Specification Action time must be started.
The "Analysis of Data
- Time Frame" paragraph on page II-3 of Revision 1 is in conflict with this staff.
position.
7.
The relief request and cold shutdown justification bases should specifically indicate the negative consequences that make testing at the Code required frequency impractical such as endangering personnel, damaging equipment, or resulting in a plant shutdown.
8.
The "Corrective Action - Time Frame" paragraph on page III-3 of the IST program does'not agree with the current staff position as expressed in Item 6 above.
What is the basis for the position stated in this paragraph?
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B.
Main Steam S stem 1.
Does motor operated valve 34-01 have remote position indication? If so, why was the remote position verification test deleted for this valve?
2.
What alternate test methods have been evaluated to assure that the force applied to open the ADS l.ine vacuum relief check valves is equivalent to the desired functional pressure differential force for the valves (refer to Relief Request MS-RR-2)?
C.
Control Rod Drive S stem 1.
Note No.
5 states that proper operation of the control rod during rod insertion time testing verifies proper reverse flow closure of the hydraulic control unit charging water isolation check valves.
The recent discovery of failed charging water isolation check valves at an operating BWR indicate that this statement may not be true unless the 1
charging water header is depressurized prior to the performance of the test.
Is the charging water header depressurized during rod insertion time testing at NMP1?
2.
Stroke time measurements of valves 44.2-15 and -18 in the test mode may not detect degradation of the normal valve control elements (refer to Relief Request CRD-RR-2),
- however, they would provide repeatable data that could detect degradation of the valves themselves.
Would the burden of performing this testing outweigh the possible increase in the level of quality and safety?
3.
Provide a more detailed technical justification for not verifying the reverse flow closure of valves 301-112 and
-113 quarterly or during cold shutdowns (refer to Relief Request CRD-RR-3).
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Hi h Pressure Coolant In 'ection S stem 1.
Cold Shutdown Test Justifications FW/HPCI-CS-1 and -2 state that exercising valve 31-07 or 31-08 closed during power operations would constitute entering an LCO on HPCI since it would be removing one train of two redundant trains.
However, in the Pump and Valve Inservice Testing Program Plan, Exclusion/Justification
- Document,Section II. 5.4, it is stated that no credit is taken for the HPCI system to mitigate the consequences of a LOCA and that the HPCI components outside the second isolation valve are not safety related.
Clarify the apparent conflict between these two statements in the IST program.
E.
Reactor Core S ra S stem 1.
What is the purpose of performing a "LA" leak rate test on valves 40-01,
-09, -10, or -11?
Since these valves serve as a boundary between the RCS and the low pressure core spray piping, should they receive a "LK" leak rate test to verify their pressure boundary isolation function?
2.
Provide the technical justification for not individually verifying the reverse flow closure of check valves 40-20,
-21, -22, and
-23 during each cold shutdown not to exceed once every 3 months (refer to Relief Request CS-RR-1).
How are these valves individually verified in the closed position?
3.
Are the differential pressures being measured across each of the following valves during quarterly testing to verify that they are open sufficiently to allow passage of the maximum analyzed flow rate (refer to Relief Request CS-RR-2)?
If not, the quarterly testing is only a part-stroke exercise of these valves and they are only full-stroke exercised during refueling outages.
Provide a technical justification for not performing a full-stroke of these valves during cold shutdowns.
40-03 40-13 81-07 81-08 81-27 81-28
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4.
Relief Request CS-RR-3 states that the check valves that provide core spray topp ing pump seal cool ing and 1 ubricati on are tested and observed at design flow rate and determined operabl e dur ing pump testing.
However, Relief Request CS - RR-2 indicates that the core spray topping pumps are tested at a flow rate of 2200 gpm compared to the requi red system flow rate of 3400 gpm.
Since pump testing is at a reduced flow rate, explain how the proposed alternate testing assures that degradation of these valves will not go undetected 5.
Provide the PS ID that shows valves CRS - 1 0 and CS-C-3 for our review.
What testing methods have been evaluated for testing these valves other than disassembly and inspection (refer to Relief Request CS - RR-4) ?
6.
What is the purpose of performing a
"LA" leak rate test on valves 81 -0 1, -02,
- 2 1, or - 22?
7.
Why are valves 40 -05 and -06 "LK" (pressure boundary isolation) leak
'ate tested?
These valves are in lines that connect to the torus ai r space.
F.
Emer enc Coolin S stem 1.
Provide the technical justification for not closing manual isolation valves 39-01 and
-02 to permit exercising valves 39-05 and
-06 quarterly during power operations (refer to Cold Shutdown Test Justification EC-CS-1).
2.
Relief Request EC-RR-1 alternate testing states that valves 39-03 and
.-04 will be tested by disassembly and inspection starting with the next refueling outage.
When was the last time that the full-stroke capability of these valves was verified?
G.
Containment S ra S stem 1.
Relief Request CTS-RR-2 states that approximately 2900 gpm is passed through valves 80-05,
-06, -25, and -26 during quarterly valve testing and that the required system flow rate is 3000 gpm.
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system flow rate be established through these valves during any plant operating mode to verify their ful 1 -stroke capability?
Provide the measured flow rates through these valves for the tests performed during the past year for our review.
2.
Is credit taken for the fail-safe operation of valves 80 - 1 5,
- 16, -35,
and
-36 in any Nine Hi 1 e Point Nuclear Station safety analysis?
Expl ai n how these valves have a safety related fail-safe function upon loss of electrical power but not upon loss of control a ir?
3.
The NRC staff position is that the full-stroke capability of safety related check valves must be verified on at least a refueling outage frequency.
Will modifications be made to allow full-stroke exercising the valves identified in Relief Request CTS - RR-1 prior to the startup from the next refueling outage?
H.
Reactor Cl eanu S stem 1.
Provide a more detailed technical justification for not verifying the reverse flow closure of valve 33 - 03 during cold shutdowns (refer to Relief Request RCU-RR-1 ).
I.
Nitro en Su l
S stem 1.
De valves 201.9-16, 201.9-35, 201.9-38, and 201.9-48 have
~re aired fail-safe positions?
If so, in addition to testing their fail-safe function, these valves must be exercised and have their full-stroke times measured in accordance with the Code.
J.
Reactor Li uid Poison S stem 1.
Provide a more detailed technical justification for not exercising valves 42-19 and -20 during cold shutdowns (refer to Relief Request LP-RR-3)?
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S ent Fuel Stora e Pool Filterin
& Coolin S stem What alternate test methods have been evaluated to determine if the force delivered to the disk of vacuum breaker valves FP-308,
-310,
-312, and -314 is equivalent to the desired functional pressure differential force-for these valves as required by IWV-3522(b) (refer to Relief Request SFSPFC-RR-2)?
2.
What is the safety related function of valve 85-160?
Does valve 49-53 perform the same function?
3.
Relief Request SFSPFC-RR-1 does not provide an adequate technical justification for not testing valve 54-49 quarterly during power operations or during cold shutdowns.
If this valve and the associated flow path do not perform a safety function during power operations or cold shutdowns, it could be declared out of service until needed for reactor refueling activities and be tested in accordance with IWV-3416.
L.
Reactor Buildin Closed Loo Coolin Water S stem 1.
Provide a more detailed technical justification for not full-stroke exercising valves 70-04,
-05, and
-06 quarterly during power operations (refer to Cold Shutdown Test Justifica'tion RBCLCW-CS-2).
2.
Is the maximum safety analysis flow rate verified through valves70-272 and -274 during quarterly valve testing?
If not, how are these valves full-stroke exercised?
3.
Provide a more detailed technical justification for not full-stroke exercising valves 70-NU-07 and 70-257 quarterly during power operations and during cold shutdowns (refer to Relief Request RBCLCW-RR-2).
4.
Can the reactor recirculation pumps be shut off during long duration cold shutdowns?
If so, why can't valves 70-92, 70-93, and -95 be exercised to the closed position during those cold shutdowns when the recirculation pumps are stopped (refer to Relief Requests RBCLCW-RR-1 and -3)?
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Condensate Transfer S stem l.
Is the maximum safety analysis flow rate verified through valves CT-9 and CT-10 during quarterly valve testing?
If not, how are these valves full-stroke exercised?
N.
Emer enc Service Water S stem 1.
What portions of the internals of valves 72-11 and -12 are visible when the inspection covers are removed for valve testing (refer to Relief Request ESW-RR-1)?
Is the force or torque applied to the external exercising arm measured when these valves are exercised as required by IWV-3522(b)?
2.
Provide a more detailed technical justification for not verifying the reverse flow closure of valves 72-21 and 72-22 quarterly during power operations and during cold shutdowns (refer to Relief Request ESW-RR-2).
What test methods other than valve disassembly have been evaluated to verify the reverse flow closure capability of these valves.
0.
Emer enc Diesel Generator Startin Air 8 Coolin Water S stem 1.
Review the safety-related function of the emergency diesel generator air start relay valves and pinion drive solenoid valves (DGA-SOV-1 and
-2) to determine if they should be included in the IST program.
P.
Instrument Air S stem 1.
Valve 94-19 appears to be an active power operated valve and should be exercised to its saFety position in accordance with IWV-3412 and have its full-stroke time measured per IWV-3413(b) to detect degradation.
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Emer enc Diesel Generator Fuel Oil Handlin S stem l.
Is the maximum safety analysis flow rate verified through the diesel fuel oil storage tank foot valves (82-03 and 82-04) during the monthly Technical Specification emergency diesel generator test?
If not, how are these valves full-stroke exercised?
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2.
PUMP TESTING PROGRAM 1.
General relief from the instrument accuracy requirements of IWP-4110 and Table IWP-4110-1 for all pressure instrumentation used for pump
- testing, cannot be granted as requested in General Relief Request PG-5.
The Code instrument accuracy requirements have been the same since the Code was originally published and instruments that meet these requirements have been commercially available.
Identify the specific cases where the Code required instrument accuracies cannot be met for individual pumps or groups of pumps.
Also, identify the actual accuracy values encountered for these cases and indicate if portable instruments that meet the Code requirements can be utilized.
Provide more specific information on when the necessary modifications will be made.
2.
The NRC staff position is that pump vibration measurements may be made in velocity units in lieu of displacement units.
However, to utilize a'ibration velocity program for pumps requires the approval of a relief request that describes in detail all aspects of the proposed program (e.g.,
instrument accuracies, measurement directions, measurement locations, acceptance criteria).
Relief Request PG-1 alternate testing proposes to use the allowable ranges of ANSI/ASHE OM-6, however, no reference is made to any other aspect of the proposed vibration monitoring program.
The NRC has determined that the OM-6 vibration allowable ranges are acceptable,
- however, in order to use these limits the licensee must use all of the pump vibration velocity criteria of ANSI/ASHE OH-6.
3.
The proposed alternate testing of Relief Request PG-2 states that the pump suction pressure for the listed pumps will be calculated from the level of the sQction supply.
Will these pressures be determined to the accuracy requirements of IWP-4110 to assure the ability to detect pump hydraulic degradation?
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Pump Relief Request PR-1 for the emergency diesel generator cooling water and the condensate transfer pumps is too vague to be evaluated for gr anting relief.
More specific information should be provided concerning the flow rate measurements made for testing and evaluating these pumps.
5.
Since the core spray and the core spray topping pumps are installed in
- series, the flow rate through both pumps would be the
- same, therefore, only one measurement need be made (refer to Pump Relief Request PR-2).
This test method is not seen as a deviation from the Code requirements and relief is not necessary.
Are the flow rate and differential pressures for each of these pumps being evaluated in accordance with IWP-3200?
6.
Pump Relief Request PR-5 for the emergency service water pumps is too vague to be evaluated for granting relief in regards to the temporary test equipment to be used for pump flow rate measurements.
Nore specific information should be provided concerning the flow rate measurement accuracies and further actions planned to correct this situation.
7.
Are the flow rate measurements for the emergency diesel generator fuel oil transfer pumps sufficiently accurate to allow the detection of pump hydraulic degradation (refer to Pump Relief Request PR-8)?
Are the Code allowable ranges of Table IWP-3100-2 utilized to evaluate these pumps?
8.
Are the pump bearing housings of the core spray and containment spray pumps totally submerged and inaccessible for vibration measurements (refer to Pump Relief Request PR-6)?
What locations on the pump drivers are being used to measure vibration for the pumps identified in this relief request?
How was it determined that these locations provide vibration data that is most represent'ative of pump bearing condition?
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9.
Provide a more detailed technical justification demonstrating why the emergency diesel generator fuel oil transfer pumps cannot be tested during the Technical Specification emergency diesel generator operability tests (refer to Pump Relief Request PR-9).
10.
Pump Relief Request PR-10 for the control room chilled water pumps is too vague to be evaluated for granting relief in regards to the temporary test equipment to be used for pump flow rate measurements.
Hore specific information should be provided concerning the flow rate measurement accuracies and further actions planned to correct this situation.
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FEB 8 1s89 Docket No. 50-220 Mr. Lawrence Burkhardt III Executive Vice President, Nuclear Operations Niagara Mohawk Power Corporation 301 Plainfield Road
- Syracuse, New York 13212
Dear Mr. Rurkhardt:
0 ISTR I BUT ION ace e
NRC PDR GLainas CVogan MPaughev MSlosson Elordan ACRS (10)
Local PDR PDI-1 Rdg RBoger LBMarsh RCapra OGC BGrimes HShaw JJohnson
SUBJECT:
INSERVICE TESTING PROGRAM FOR NINE MILE POINT, UNIT I The NRC staff and its consultants from Idaho National Engineering Laboratory (INEL> have completed a preliminary review of the second ten year Inservice Testing (IST) Program for Nine Mile Point, Unit 1 submitted January 18, 1989.
Enclosed is a set of questions and coments developed as a result of that review.
The staff and its consultants would like to meet with you at the plant site on February 22 and 23, 1989, to resolve these concerns.
The enclosed list will be used as an agenda for discussions at that meeting.
Formal responses to the enclosure are not required prior to the meeting.
However, draft responses for each of the questions should be prepared prior to the meeting and be available for the meeting discussion.
Sincerely, Ol'/foal sfgpg1 gy
Enclosure:
NMP-I ITP guestions and Coments Mary F. Haughey, Project Manager Project Directorate I-l Division of Reactor Projects I/II cc:
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Niagara Mohawk Power Corporation Nfne Mi ofnt Nuclear Station, Unit No.
1 CC:
Mr. Troy 8. Conner, Jr.,
Esqufre Conner 8 Wetterhahn Sufte 1050
'747 Pennsylvania
- Avenue, N. W.
l.'ashfnaton, D. C.
20006 Mr. Frank R. Church, Supervfsor Town nf Scrfba R.
D.
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- Oswego, New York 13126 Mr, James L. Willfs General Supt.-Nuclear Generation Nfagara Mohawk Power Corporatfon Nine Mile Point Nuclear'tation Post Office Box 3~
- Lycomfng, New York 13093 Pesfdent Inspector U. S. Nuclear Regulatory Commission Post Offfce Rox 126
- Lycomfna, New York 13093 Mr. Gary 0, Wilson, Esaufre Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, New York 13202 Regional Admfnfstrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia.
Pennsylvania 19406 Ms.
Donna Ross New York State Energy Office 2 Empfre State Plaza 16th Floor
- Albany, New York 12223 Mr. Kfm Dahlberg Unft 1 Station Superintendent Nine Mile Pofnt Nuclear Station Post Offfce Box 32 l.ycomfng, New York 13093 Mr. Peter E. Francisco, Licensing Niagara Mohawk Power Corporation 301 Plainfield Road
- Syracuse, New York 13218 Charlie Donaldson, Esoufre Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Hr. Paul D. Eddy State of New York Department of Publfc Servfce Power Dfvfsion, System Operations
. 3 Empire State Plaza
- Albany, New York 12223
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ENCLOSURE NINE MILE POINT NUCLEAR STATION, UNIT 1 PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS 1.
VALVE TESTING PROGRAM A. 'General uestions and Comments 1.
Revision 0 of the second ten year IST program for Nine Mile Point Nuclear Station, Unit 1, (NHP1) states on page I-4 that Section XI requires quarterly testing of components unless it is impractical to do so.
In Revision 1, the word "impractical" in that statement was replaced with "a burden."
Section XI permits deferral of valve testing to cold shutdowns if quarterly testing is impractical and 10CFR50.55a(g)(6)(i) authorizes the NRC to grant relief from the Code requirements if conformance is impractical.
Use of "a burden" in the identified statement may impart the erroneous idea that inconvenience is a justification for not performing Section XI testing at the Code required frequency.
What was the purpose for this program change?
2.
General Relief Request VG-3 proposes an audible indication and a drain pipe temperature measurement as means to detect the proper operation of excess flow check valves at NHP1.
The NRC has concluded that the use of audible indication does not provide an acceptable positive means of verifying that a check valve has moved to its safety function position as required by IWV-3522(b).
The temperature measurement method may be acceptable.
Provide a more detailed description of this testing and the acceptance criteria that is utilized.
3.
The establishment of a second category of rapid acting valves, piston and diaphragm valves that stroke in 4 seconds or less (refer to General Relief Request VG-1), is not in agreement with the NRC staff position on rapid acting power operated valves.
Valves whose normal stroke times fall in the range of 2 to 4 seconds would have to vary greater than 1 second from one test to the next in order to require more
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frequent testing per IWV-3417(a).
This amount of allowed variance should more than compensate for stroke time deviations due to operator response times and normal data scatter due to changes in system conditions.
4.
General Relief Request VG-4 proposes to use the control room indicating lights to verify the proper fail-safe actuation of valves equipped with remote position indication.
This testing is in accordance with the Code and relief is not necessary as long as the applicable valves remote position indication is verified in accordance with IWV-3300.
5.
Control valves that do not have
~re aired fail-safe positions (l.e.,
credit not taken in any SAR analysis for the valve failing to a
specified position),
are exempted from Section XI testing by IWV-1200.
However, if credit is taken for the fail-safe function of a control valve, it is an active power operated valve that must be tested to all of the applicable requirements of IWV-3400 and not just to the requirements of IWV-3415.
General Relief Request VG-5 is in conflict with this position.
6, The NRC staff position is that as soon as test data is recognized as being within the required action range from Section XI, the associated component must be declared inoperable and the Technical Specification Action time must be started.
The "Analysis of Data - Time Frame" paragraph on page II-3 of Revision I is in conflict with this staff position.
7.
The relief request and cold shutdown justification bases should specifically indicate the negative consequences that make testing at the Code required frequency impractical such as endangering personnel, damaging equipment, or resulting in a plant shutdown.
8.
The "Corrective Action - Time Frame" paragraph on page III-3 of the IST program does not agree with the current staff position as expressed in Item 6 above.
What is the basis for the position stated in this paragraph?
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Hain Steam S
te l.
Does motor operated valve 34-01 have remote position indication? If so, why was the remote position verification test deleted for this valve?
2.
What alternate test methods have been evaluated to assure that the force applied to open the ADS line vacuum relief check valves is equivalent to the desired functional pressure differential force for the valves (refer to Relief Request HS-RR-2)?
C.
Control Rod Drive S ste 1.
Note No.
5 states that proper operation of the control rod during rod insertion time testing verifies proper, reverse flow closure of the hydraulic control unit charging water isolation check valves..
The recent discovery of failed charging water isolation check valves at an operating BWR indicate that this statement may not be true unless the charging water header is depressurized prior to the performance of the test.
Is the charging water header depressurized during rod insertion time testing at NHP1?
2.
Stroke time measurements of valves 44.2-15 and -18 in the test mode may not detect degradation of the normal valve control elements (refer to Relief Request CRD-RR-2),
- however, they would provide repeatable data that could detect degradation of the valves themselves.
Would the burden of performing this testing outweigh the possible increase in the level of quality and safety?
3.
Provide a more detailed technical justification for not verifying the reverse flow closure of valves 301-112 and -113 quarterly or during cold shutdowns (refer to Relief Request CRD-RR-3).
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D.
Hi ressure Coolant In ec i n S t 1.
Cold Shutdown Test Justifications FM/HPCI-CS-I and -2 state that exercising valve 31-07 or 31-08 closed during power operations would constitute entering an LCO on HPCI since it would be removing one train of two redundant trains.
- However, in the Pump and Valve Inservice Testing Program Plan, Exclusion/Justification
- Document,Section II. 5.4, it is stated that no credit is taken for the HPCI system to mitigate the consequences of a LOCA and that the HPCI components outside the second isolation valve are not safety related.
Clarify the apparent conflict between these two statements in the IST program.
E.
Reactor Core S ra S stem 1.
What is the purpose of performing a "LA" leak rate test on valves 40-01,
-09,
-10, or -11?
Since these valves serve as a boundary between the RCS and the low pressure core spray piping, should they receive a "LK" leak rate test to verify their pressure boundary isolation function?
2.
Provide the technical justification for not individually verifying the reverse flow closure of check valves 40-20,
-21, -22, and -23 during each cold shutdown not to exceed once every 3 months (refer to Relief, Request CS-RR-1).
How are these valves individually verified in the closed position?
3.
Are the differential pressures being measured across each of the following valves during quarterly testing to verify that they are open sufficiently to allow passage of the maximum analyzed flow rate (refer to Relief Request CS-RR-2)?
If not, the quarterly testing is only a part-stroke exercise of these valves and they are only full-stroke exercised during refueling outages.
Provide a technical justification for not performing a full-stroke of these valves during cold shutdowns.
40-03 40-13 81-07 81-08 81-27 81-28
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4.
Relief Request CS-RR-3 states that the check valves that provide core spray topping pump seal cooling and lubrication are tested and observed at design flow rate and determined operable during pump testing.
However, Relief Request CS-RR-2 indicates that the core spray topping pumps are tested at a flow rate of 2200 gpm compared to the required system flow rate of 3400 gpm.
Since pump testing is at a reduced flow
- rate, explain how the proposed alternate testing assures that degradation. of these valves will not go undetected.
5.
Provide the PLIO that shows valves CRS-10 and CS-C-3 for our review.
What testing methods have been evaluated for testing these valves other than disassembly and inspection (refer to Relief Request CS-RR-4)?
6.
What is the purpose of performing a "LA" leak rate test on valves 81-01,
-02, -21, or -22?
7.
Why are valves 40-05 and
-06 "LK" (pressure boundary isolation) leak'ate tested?
These valves are in lines that connect to the torus air space.
F.
Emer enc Coolin S stem 1.
Provide the technical justification for not closing manual isolation valves 39-01 and -02 to permit exercising valves 39-05 and -06 quarterly during power operations (refer to Cold Shutdown Test.
Justification EC-CS-I).
2.
Relief Request EC-RR-I alternate testing states that valves 39-03 and
-04 will be tested by disassembly and inspection starting with the next refueling outage.
When was the last time that the full-stroke capability of these valves was verified?
G.
Containment S ra S ste 1.
Relief Request CTS-RR-2 states that approximately 2900 gpm is passed through valves 80-05,
-06, -25, and -26 during quarterly valve testing and that the required system flow rate is 3000 gpm.
Can the required
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system flow rate be established through these valves during any plant operating mode to verify their full-stroke capability?
Provide the measured flow rates through these valves for the tests performed during the past year for our review.
2.
Is credit taken for the fail-safe operation of valves 80-15,
-16,
-35, and -36 in any Nine Nile Point Nuclear Station safety analysis?
Explain how these valves have a safety related fail-safe function upon loss of electrical power but not upon loss of control air?
- 3. 'he NRC staff position is that the full-stroke capability of safety related check valves must be verified on at least a refueling outage frequency.
Will modifications be made to allow full-stroke exercising the valves identified in Relief Request CTS-RR-I prior to the startup from the next refueling outage?
H.
Reactor Cleanu S ste I.
Provide a more detailed technical justification for not verifying the reverse flow closure of valve 33-03 during cold shutdowns (refer to Relief Request RCU-RR-I).
I.
Nitro en Su 1
S ste 1.
Do valves 201.9-16, 201.9-35, 201.9-38, aed 201.9-48 have
~re aired fail-safe positions?
If so, in addition to testing their fail-safe function, these valves must be exercised and have their full-stroke times measured in accordance with the Code.
J.
Reactor Li uid Poison S stem I.
Provide a more detailed technical justification for not exercising valves 42-19 and -20 during cold shutdowns (refer to Relief Request LP-RR-3)?
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S n
Fuel Stora Pool ilte 1.
What alternate test methods have been evaluated to determine if the force delivered to the disk of vacuum breaker valves FP-308,
-310,
-312, and -314 is equivalent to the desired functional pressure differential force for these valves as required by IWV-3522(b) (refer to Relief Request SFSPFC-RR-2)?
2.
What is the safety related function of valve 85-160?
Ooes valve 49-53 perform the same function?
3.
Relief Request SFSPFC-RR-I does not provide an adequate technical justification for not testing valve 54-49 quarterly during power operations or during cold shutdowns.
If this valve and the associated flow path do not perform a safety function during power operations or cold shutdowns, it could be declared out of service until needed for reactor refueling activities and be tested in accordance with IWV-3416.
L.
Reactor Buildin Closed oo Coolin Water S ste 1.
Provide a more detailed technical justification for not full-stroke exercising valves 70-04,
-05, and
-06 quarterly during power operations (refer to Cold Shutdown Test Justification RBCLCW-CS-2).
2.
Is the maximum safety analysis flow rate verified through valves70-272 and -274 during quarterly valve testing?
If not, how are these valves full-stroke exercised?
3.
Provide a more detailed technical justification for not full-stroke exercising valves 70-HU-07 and 70-257 quarte'rly during power operations and during cold shutdowns (refer to Relief Request RBCLCW-RR-2).
4.
Can the reactor recirculation pumps be shut off during long duration cold shutdowns?
If so, why can't valves 70-92, 70-93, and -95 be exercised to the closed position during those cold shutdowns when the recirculation pumps are stopped (refer to Relief Requests RBCLCW-RR-I and -3)?
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H.
Condensate Transfe S st 1.
Is the maximum safety analysis flow rate verified through valves CT-9 and CT-10 during quarterly valve testing?
If not, how are these valves full-stroke exercised?
N.
mer enc Service Wate S ste 1.
What portions of the internals of valves 72-11 and
-12 are visible when the inspection covers are removed for valve testing (refer to Relief Request ESW-RR-1)?
Is the force or torque applied to the external exercising arm measured when these valves are exercised as required by IWV-3522(b)?
2.
Provide a more detailed technical justification for not verifying the reverse flow closure of valves 72-21 and 72-22 quarterly during power operations and during cold shutdowns (refer to Relief Request ESW-RR-2).
What test methods other than valve disassembly have been evaluated to verify the reverse flow closure capability of these valves.
0.
Emer enc Oiesel Generator Star tin Air & Coolin Water S ste 1.
Review the safety-related function of the emergency diesel generator air start relay valves and pinion drive solenoid valves (OGA-SOV-1 and
-2) to determine if they should be included in the IST program.
P.
Instrument Air S ste 1.
Valve 94-19 appears to be an active power operated valve and should be exercised to its safety position in accordance with IWV-3412,and have its full-stroke time measured per IWV-3413(b) to detect degradation.
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g.
Emer enc Diesel Ge erator Fuel Oil Handlin S ste l.
Is the maximum safety analysis flow rate verified through the diesel fuel oil storage tank foot valves (82-03 and 82-04) during the monthly Technical Specification emergency diesel generator test?
If not, how are these valves full-stroke exercised?
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1.
General relief from the instrument accuracy requirements of IWP-4110 and Table IWP-4110-1 for all pressure instrumentation used for pump
- testing, cannot be granted as requested in General Relief Request PG-5.
The Code instrument accuracy requirements have been the same since the Code was originally published and instruments that meet these requirements have been commercially available.
Identify the specific cases where the Code required instrument accuracies cannot be met for individual pumps or groups of pumps; Also, identify the actual accuracy values encountered for these cases and indicate if portable instruments that meet the Code requirements can be utilized.
Provide more specific information on when the necessary modifications will be made.
2.
. The NRC staff position is that pump vibration measurements may be made in velocity units in lieu of displacement units.
However, to utilize a'ibration velocity program for pumps requires the approval of a relief request that describes in detail all aspects of the proposed program (e.g.,
instrument accuracies, measurement directions, measurement locations, acceptance criteria).
Relief Request PG-1 alternate testing proposes to use the allowable ranges of ANSI/ASHE OH-6, however, no reference is made to any other aspect of the proposed vibration monitoring program.
The NRC has
'etermined that the OH-6 vibration allowable ranges are acceptable,
- however, in order to use these limits the licensee must use all of the pump vibration velocity criteria of ANSI/ASHE OH-6.
3.
The proposed alternate testing of Relief Request PG-2 states that the pump suction pressure for the listed pumps will be calculated from the level of the suction supply.
Will these pressures be determined to the accuracy requirements of IWP-4110 to assure the ability to detect pump hydraulic degradation?
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4.
Pump Relief Request PR-1 for the emergency diesel generator cooling water and the condensate transfer pumps is too vague to be evaluated for granting relief.
More specific information should be provided concerning the flow rate measurements made for testing and evaluating these pumps.
5.
Since the core spray and the core spray topping pumps are installed in
- series, the flow rate through both pumps would be the
- same, therefore, only one measurement need be made (refer to Pump Relief Request PR-2).
This test method is not seen as a deviation from the Code requirements and relief is not necessary.
Are the flow rate and differential pressures for each of these pumps being evaluated in accordance with IWP-3200?
6.
Pump Relief Request PR-5 for the emergency service water pumps is too vague to be evaluated for granting relief in regards to the temporary test equipment to be used for pump flow rate measurements.
More specific information should be provided concerning the flow rate measurement accuracies and further actions planned to correct this situation.
7.
Are the flow rate measurements for the emergency diesel generator fuel oil transfer pumps sufficiently accurate to allow the detection of pump hydraulic degradation (refer to Pump Relief Request PR-8)?
Are the Code allowable ranges of Table IWP-3100-2 utilized to evaluate these pumps?
8.
Are the pump bearing housings of the core spray and containment spray pumps totally submerged and inaccessible for vibration measurements (refer to Pump Relief Request PR-6)?
What locations on the pump drivers are being used to measure vibration for the pumps identified in this relief request?
How was it determined that these locations provide vibration data that is most represent'ative of pump bearing condition?
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9.
Provide a more etailed technical justification emonstrating why the emergency diesel generator fuel oil transfer pumps cannot be tested during the Technical Specification emergency diesel generator operability tests (refer to Pump Relief Request PR-9).
10.
Pump Relief Request PR-10 for the control room chilled water pumps is too vague to be evaluated for granting relief in regards to the temporary test equipment to be used for pump flow rate measurements.
Nore specific information should be provided concerning the flow rate measurement accuracies and further actions planned to correct this situation.
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