ML17055E557

Summary of 890222-23 Meetings W/Util & Eg&G Idaho,Inc Re Issues Resulting from Review of Unit 1 Pump & Valve Inservice Testing Program.List of Attendees Encl

ML17055E557
Person / Time
Site:	Nine Mile Point
Issue date:	03/10/1989
From:	Mccree V Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8903150004
Download: ML17055E557 (46)

Text

March 10, 1989 I,J Docket Nos. 50-220 and 50-410 LICENSEE:

Niagara Mohawk Power Corporation (NMPC)

FACILITIES:

Nine Mile Point Nuclear Station, Units 1 and 2

SUMMARY

OF MEETING WITH NIAGARA MOHAWK POWER CORPORATION ON FEBRUARY 22 AND 23, 1989 TO DISCUSS THE PUMP AND VALVE INSERVICE TEST INTERFACE PROGRAM FOR NINE MILE POINT, UNIT 1 On February 22 and 23, 1989, the NRC staff and members of EG&G Idaho, Inc.,

met with Niagara Mohawk Power Corporation representatives to discuss issues resulting from a review of the Nine h1ile Point, Unit 1

Pump and Valve Inservice Testing (IST) program.

Enclosure 1 is a list of meeting attendees.

Enclosure 2 served as the meeting

agenda, and also documents the questions and responses derived from the meeting minutes.

Discussions during the meeting resulted in three OPEN ITEMS for the NRC which id ti i d i E

1 2.

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thd IST program as indicated in Enclosure 2 and submit the final IST program in March 1989.

Enclosures:

As stated cc:

See next page ORIGINAL SIGNED BY Victor M. McCree, Project Manager Project Directorate I-1 Division of Reactor Projects I/II

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20006 Mr. Frank R. Church, Supervisor'own nf Scriba R.

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Oswego, New York 13126 Mr, James L. Willis General Supt.-Nuclear Generation Niagara Mohawk Power Corpor ation Nine Mile Point Nuclear Statfon Post Office Box'32

Lycoming, New York 13093 Resfdent Inspector U. S. Nuclear Regulatory Comfssion Post Office Box 126

Lycoming, New York 13093 J

Mr. Aary D. Wilson, Esquire Niagara Mohawk Power Cor poration 300 Erie Boulevard Rest

Syracuse, New York 13202 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale R6ad King of Prussia.

Pennsylvania 19406 Ms.

Donna Ross New York State Energy Office 2 Empire State Plaza-16th Floor

Albany, New York 12223' J

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e Mr.'fm Dahlberg Unit 1 Station Superintendent Nine Mile Point Nuclear Station Post Office Box 32 Lycom'fng, 'Ndw York 13093

,Mr. Peter E. Francisco Licensing Niagarg Mohawk PoWer 'Corporation 301 Plainfield Road

Syracuse, New York 13212 Churl fe'onaldson, Esaufre

'Assistant Attorney G'e'neral New, York DepartmentJof L'aw 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 Pla~

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Mr. Lawrence Burkhardt III

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Suite 1050 1747 Pennsylvania Avenue,.W h'ashfngton, D.C."

20006 Mr. Richard Goldsmith Svracuse University"'ollege of Law E. I, White Hall Campus

Syracuse, New York,.12223

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ging of, - Prussia, 'Pennsyl va)nia 19406 Charlie, Dana1dson, Esquire Assistant Attorney General..

New.York Department, of Law."

1?0 Rraodway New York, New York 10271 Resident Inspector Nine Mfle Point Nuclear Power Station Mr. Richard,M.

Kessel P. 0.

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Lycomfng, New York,,13093 State Consumer Protection Board 99 Washington Avenue Mr. Gary D. Wilson, Esaufre

,,, Albany, New York I?210 Nfaaara Mohawk Power.Corporation 300 Erfe Boulevard Hest

Syracuse, New York

$ 3?D2 Mr. Richard Abbott,*Unit' Station Superintendent Mr. Peter E. Francisco, Lfcensfng Nine Mile Point Nuclear Station Niagara Mohawk Power Corporation Niagara Mohawk Power Corporation 301 Plafnffeld Road P. 0.

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Syracuse, New York'321'.

:"Lycominq, 'NY'13093 Ms.

Donna Ross Mr. James L. Willis', General Supt.,

New York State Energy 0'ffice

'"'luclear Gen'eration

2 Empire State Plaza Nine Nile Point Nuclear Station 16th Floor Niagara Moh'awk'ower Corporation

Albany, New York 12223 P. 0.

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ENCLOSURE 1

PLANT:

DATES:

ATTENDANCE LIST y ~ ~

e le INSERVICE TESTING PROGRAM WORKING HEETING..

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Nine Mile Point Nuclear Station, Unit 1

February 22 and 23, 1989

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Name Horace Shaw Victor HcCree Herb Rockhold Clair, Ransom Kenneth Thomas Brian Hurtha Roger Samson Robert Parry Richard Shelton Carlynann Johnson e

Niagara Mohawk e

Niagara Mohawk Niagara Mohawk Niagara Mohawk

Niagara Mohawk New York State ee Power Corp.

Power Corp.

Power Corp.

Power Corp.

Power Corp.

Public Service e resenti e

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EG8G Idaho, Inc.

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WORKING MEETING MINUTES NINE MILE POINT NUCLEAR STATION, UNIT 1

PUMP AND VALVE INSERVICE TESTING PROGRAM FEBRUARY 22 AND 23, 1989

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.NINE MILE'"POINT<NUCLEAReSTATIONj UNIT~ 'I a l c I.

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PUMP'N%'ALVE. INSERVICE<'TESIT'INGc PROGRAN"> a'i+

,QUESTIONS ANO'COQENTS' J.'a t< r ~;

"-1..: VALVE TEST'ING,. PROGRAM::

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General uestions and Comments Revision 0 of the second ten'year IST program for Nine Mile Point Nuclear Station, Unit 1, (NMPl)'."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 >fzquarterly testing is impractical and 10CFR50-.55a(g)(6)(o ); auth'orize5:the NRC to graht relief'rom: the Code requirements if conformance is impractical.

Use of, "a burden" in the identified:,statement..may

.impart the erroneous idea that inconven~iencec.isla

'justification. for. not performing Section.XI tes'ting"at'.the Code required"frequency.

What was the purpose for.,this program"changers F.

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Response

.This, word change,.was made due to a 'reference in-the draft-generic letter, -it will be changed back to "impractical".-.-

1 General=Relief Request VG-3 proposes;an'.

audible indication and a

drain piye temperature, measurement'as'eans.

to detect the=proper operation of excess,.flow check valves at NHPl.

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 s'afety 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.

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The temperature.-is not: measured or checked during testing of the excess'. flow,check valves.

The audible test involves hearing a loud hammer or hammering followed by a marked

,decrease.

in the flow noise through the litle.

This test appears to. be a credible test, however.,'it should be verified during a future IST inspection.

-The l.Icentee will provide a

more detailed"discussion about the testing and will delete reference to the temperature check.

The establishment of a second category of rapid acting valves, piston and diaphragm valves that strokein 4 seconds. or less (refer to Ge'neral Relief Request VG-l), is-not" in'.agreement: with the NRC staff position on rapid acting power operat'ed> valves.

Valves whose normal stroke times fall in the

@augh of'. 2" 4o 4. -"

seconds would have to vary greater than 1 second from one test to

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the neMt in order to require'ol'e frequent 'testirrg per

'WV-3417(4).

'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.

Respon'se:,

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'fhe licensee will delete the valves that normally stroke'n the'ange of 2 to 4 seconds from the'relief request and will use a system based on valve reference stroke times for evaluating the stroke -times of those valves'hat are not covered by the rapid acting valve r elief tr'equest.

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 acco'rdance with the Code and relief is not ne'cess'ary as long as the applicable valves remote ptosition'indication is verified in accordance with IWV-3300:.'":

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Relief Request VG-4 will be -deleted; Control valves that do not have

~re aired 'fail-safe positions (i.e., 'credit not taken in any'AR a'rjjlysis for the valve fa'i'ling to' specified position).,

are exempted from Section XI testfng 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 te'0ted 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.

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Those control valves wi'tfi requi'red "fail-safe positions as specified in appropriate safety analysis documents will be tested as required by"the Code. 'All other control valves not required, will be deleted from the plan and added to the justification book.

Specific relief requests for those "required valves" where the test requirements of IWV-3400 cannot be met for specific valves or groups of similar. valves will be submitted.,

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The NRC staff position is that as soon as'est data'is recognized as being within the required action'.rangeafroai Section XI, the associated component'must 'be,declar'hd inoperable and the Thchnical 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.

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Response

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Theutility "has 'custom Techn'ical Specificatiorih 'at=Nine=Mile

.Point; UfiitI, 'that require immediate actioh in some "

situation4 'when a c6mponent'is declared inoperable due td 'the

~ 'Limiting Ganditions for Operation Action Statements.

"'Thi-s is an OPEN'TEM for the NRC"to determine if compliance with'this

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staff position'ool-d "impose an undue burden on the licensee.

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.

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Response

The licensee will modify relief'equests and cold shutdown justifications where necessary to indicate the negative consequences that make testing at the Code -required frequency i'mpractical.

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 sfated in this paragraph?

Response

The utility has cu'stom Techn'ical Specifications at Nine Mile Point, Unit 1, that require immediate action in some situations when a 'component'is declared inoperable due to the Limiting Conditions for Operation Action'Statements.

This is atf OPEN ITEM for the NRC to determine if compliance with this staff position would impose an undue burden on the licensee.

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Does motor operated Calve 34-01 have remote position indication?

If'so, why was the. remote position verification test deleted for this valve?

Response

Hotor operated valve 34-01 does'have remote position indication an'd 'this 'remote indication'will be"verified in accordance with the Code.

2.

What alternate test methods have been evaluated to assure that the force applied to open tHe ADS lihe vacuum relief check valves is equivalent to the desired functional pressure differential force for the valves (refer to Relief Request HS-RR-2)?

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, The only test -that the licensee, has been~ab1e-to'develop for these valves is to ma'nual'ly eQercise~ them by hald.

'The

-.valves-vill'also be visually inspected when they are exercised.

Relief Request HS-RR-2 will be modified to provide more detail regarding the testing performed on these vacuum breakers.

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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 contra'1'nit charging water.,isolation check valVes.

The recent discovery of failed ch'airging Hater 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 NHPI?

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The charging water header is not depressurized during rod insertion time testing at NNP1, therefore, these valves are not verified in the closed position by the current testing.

The licensee will perform a scram accumulator pressure decay test during refueling outages which will verify the reverse flow closure of the charging water.. check-'valves.

A relief request will be provided for the charging water check valves.

In addition, the HCU 138 "valves are verified clos'ed during normal control rod motion and will, therefore, be deleted from Relief Request CRD-RR-I.

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.Reli.ef Request CRD-RR 2),,however, they.would provide repeat'able

'data tha't.cou1d detect deg'radation of the valves.themselves.

~Would the burden of performing this testing outweigh the possibl'e,increa'se

'in the.level of quality and safety?

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The licensee will test these valves by measuring the stroke

.times. quarterly. during power operations.,

Relief. Request CRD-RR-2 will be deleted from the IST program.

3.

Provide a more. detailed techni'cal 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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Response

The licensee will provide additional technical justification for not performing this testing quarterly or during cold shutdowns.

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Cold Shutdown 'Test Justifi'cations FW/HPCI-CS-I aAd -2 state that exercisirig v'wive 31-07 'or',31-08'l'osed 'during power operations would '<otistitute'ntering 'an LCO on'HPCI since it would be removing"one train of"two redundant trains. 'owev'er; in the Pump and Valve IriserVice Testing Program PTah; Exclusion/Justification

Document,Section II. 5.4 Attachment 4, it is. stated that'o 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 pro'gram.

Response

ef The licensee will provide a more detailed technical justification which will identify the specific negative consequences for not testing these valves quarterly.

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'I What is the pu'rpose of performing a "LA" leak'rate test'on valves 40-01; -09, -10, or -ll?

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?.

Response

2; These vaTves are not listed in 'the plant Technical Specifications a0'vent V pressure boundary isolation valves, therefore, they need not be "LK" leak rate tested.

The licensee elected to perform a leak test on these valves due to the importance of their leak tight integrity.

No further information is required for these valves.

Provide the technical just'ificltion 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 Reque'st

'CS RR-'I'):- 'ow are these valves individually verified in the closed position?

Response

'C The licensee will delete the inboard valves from Relief Request CS-RR-I since these valves are individually verified in-the closed position quarterly during pump tests.

The reverse flow closure of the outboard valves will be verified during those cold shutdowns when the-"LK" leak test is required.

The relief request Qil'1 be modified for the outboard valves.

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Are the-,differentialpressures being measured,across each of the following va1ves dur'ing quarterly testing,fo.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,.no),<performing a full.-stroke of

these valves during cold shutdowns.

40-03 40-13 81-07 81-08 81-27

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Response

The licensee will indicate that the quarterly test is a

partial-stroke exercise and they will include a justification for not full-stroke exercising these valves during cold shutdowns.

Relief Request CS-RR-2 does not apply to valves 81-07 and 81-27 since they cannot be full. flow,tested during refueling outages.

Valves 81-07 agd 81-27 w'i.ll be disassembled and inspected on a sampling basis during refueling,outages.

A relief request will be provided for valves 81-07 and 81-27.

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.

Response

These valves are an integral part of the core spray topping pump system and are.tqsted as a unit with the pumps, therefore, they need not be included ip the,IST program and tested separately.

Relief Request CS-RR-3 may be deleted from the IST program.

5.

Provide the,P&IO that shows valves CRS-10 and CS-C-3 for our review.

What testing methods. have been evaluated for testing these, valves other'han disassembly and inspection (refer to Relief Request CS-RR-4)?

Response

The licensee identified these valves on the P&IO, both are currently shown as CS-C-3,

,There is no testing that is -;

practical for these valves other than disassembly and inspection due to the lack of test taps and instrumentation.

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What is the purpose of performing a "LA" leak rate test on valves 81-01,

-02,

-21, or -22?

Response

P These valves are being leak rate tested using water (LA) instead of receiving an.Appendix::J, TypeC, leak rate test.

This was determined to be a reasonable alternative to the Appendix J, Type C~ leak rate testing.

Why are valves 40-05 and -06 "LK" (pressure=boundary isolation) leak-rate tested?

These, valves're in'lines,that connect to the

.torus air space.

Response

Since the affected portion of,'the Core. Spray 'System is considered part of"the reactor coolant-pressure

boundary, these valves are being added to the Technical; Specification PIV list and are leak rate tested to verify. the.:pressure isol'ation function.

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Emer enc Coolin S stem Provide the technical justification for not closing manual isolation valves 39-01 and'02 to permit exercising valves'9-05 and -06 quarterly during power operations ('efer to Cold shutdown Test Justification EC-CS-l).

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The licensee will augment the cold shutdown justification to indicate that the manual isolation valves are located inside the reactor containment and are inaccessible, during power operation because, the atmosphere is inerted.

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2.

Relief Request EC-RR-I alternate testing states that val'ves',.39-03 and -04 will be. tested by, disassembly and inspection starting with the next, refueling outage.

When was'he. last time that the full-stroke capability of these valves was verified?

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These valv'es were. both ful:1-stroke exercised during 1986.

The system must be:full flow tested once every fiue years,.

but should not be tested more frequently due to thermal stress considerations.

The Relief Request will be modified to include further clarification.

During those refueling outages where the system is not tested, one of these valves will be, disassembled and inspected on w rotati;ng basis.-..

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Rel ief;Request,:. C3'SaRR.,2i,states. that approximatelg<2900,-gpm,i s

jassed through.valves 80-05,,-06,

-,25,-and

-26 durirjg'.quarterly valve testing.and that the required system flow rate=is 3000 gpm.o Can the;required system flow rate be established through these valves during any plant operating mode to verify their full-stroke capabil,ity?,

Provide the measured flow rates through these valves for the tests performed during the past year for our review.

2.

Response

The measured test flows (over at least 12 tests) varied from 2840 to 3000 gpm; therefore, this represents a substantial part-stroke exercise.:.,This.is, an

~OP N'ITEM for the NRC'to determine if;the proposed test is satisfactory for verifying the full-stroke capability of these valves.

s Is credit taken for the fail-safe operation of valves 80-15,

-16,

-35, and,-36 in.anyiNine Mile Point Nuclear: Stati,on safety analysis?

Explain,how these valves have a;safetytrelated fail-safe:function upon loss ofeelectrieal:power,but not upon. loss of control air?

Response

Credit is taken, for the fail-safe operation of valves.80-15,

-16,

-35, and -36 in.the Nine Mile Point Nuclear Station safety analysis report.; These valves have piston actuators that do not have springs to position the valve upon loss of actuating air.

These valves are provided with a redundant safety grade instrument air supply, therefore, they need not be fail-safe tested on loss of control air.

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?

Response

The licensee will use an air test to exercise these valves this refueling outage and will make system modifications with the initial modifications beginning during the next (1991) refueling outage to permit verification of the full-stroke capability of these valves by sample disassembly and inspection.

There will be two groups of valves; one composed of four 12 inch valves and a second with six 3 inch valves.

At least one valve from each group will be disassembled and inspected each refueling outage and all valves will be tested at least once every 6 years.

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'S stem Provide a more detailed technical. justification:.for not-verifying the reverse fTow close.e of valve 33-'03 during cold shutdowns.

(refer to Relief. Request RCU-RR~1).

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Response

The reverse flow closure of valve 33-03 will be verified during cold shutdowns.

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Oo valves 201.9-15, 201.9-35, 201.9-38,'and 201.9-48 have re<euired fail-safe positions? 'f 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.

Response

sv; Valves 201,9-16, 201.9-35, =and 201.9-38 are functioning as pressure regulating valves that do not have required fail-safe positions.

Refer to Item A.5 for discussion on control valves.

Valve 201.9-48 may not have a required-fail-safe position, if riot, it need"vrot be tested by the IST program.

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Reactor Li uid Poison S stem 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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Response

The licensee stated that it is impractical to verify the reverse flow closure of these valves during cold shutdowns because it would require removing a relief valve or an accumulator, atta'ching test equipment, and returning the system to service which could delay startup from the cold

'hutdown;"

The licensee will provide additional information in the relief request.

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& Coolin S ste 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 the0'0 valves as required by IWV-3522(b) (refer to Relief Request SFSPFC-RR-2)?

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.Valves FP-312 and -314 are, lift checks which cannot-.be manually exercised by hand, therefore, the 1,'icensee may propose a pressure or vacuum 'test'or these valves.

These valves may be declared out of service so testing is not

.,required except within 30 days prior to returning them to service.

The only test that the licensee has been able to develop for valves FP-,308 and -310 is to manually exercise them by hand.

These valves will also be visually inspected when they are exercised.

Rel.ief Request SFSPFC-RR-2 will include a more detailed description of the testing performed on valves FP-308 and -310.,

2.

What is the safety related function of-valve 85-. 1607

" Does 'valve 49-53 p'erform the same function?

Response

Valve 85-160 is included in the IST program because it is on the active "g" list.

Valve 49-53 is listed as passive in the justification table and it need not be tested in the IST program.

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.

Response.:

This valve is ~in a subsystem that is out af service during power operations.

This valve may be declared out of service so testing is.not required. except within 30 days prior to returning it to service.

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Reactor Buildin Closed Loo Coolin Water S stem 1.

Provide a more detailed technical justification~fer not~

full-stroke exercising valves 70-04,

-05,,

and -06 quarterly during power operations (refer to Cold Shutdown Test Justification RBCLCM-.CS-2)'.

Response

I 'L Two pumps are required to be-operating during power operations, therefore, the pump discharge check valve cannot be individually verified to full-stroke open.

These valves w'ill be individually verified to full-stroke during cold shutdowns.

Cold Shutdown Test Justification RBCLCW-CS-2 will be augmented to include additional justifications.

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Is'the maximum safety analysis flow rate verified through valves70-272 and

-274 during quarterly valve testing?

If not, how are these valves'ull-stroke exercised?

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The licensee is verifying the'maximum'afety analysis flow r'ate through these valves by using strap-on ultrasonic flow measuring equipment.'

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Provide a more detailed technical'justification

'for not full-stroke exercising valves 70-MU-07 and 70-257 quarterly during power operations and during cold shutdowns (refer to Relief Request RBCLCW-RR-2).

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The 'licensee will'rovide a'more detailed technical justification for'not te'Sting these valves quarterly or during cold shutdowns.

Valve 70-MU-07 can only be tested by disassembly.

Valve 70-257 can not be isolated for testing.

A modification is proposed for the 1991 refueling outage that will permit quarterly testing.

~I Can the reactor recirculation pumps be shut off during long duration cold shutdowns?

If so, why canalves 70'-'92, 70-93, and -95 be-exercised to the 'closed'osition during those cold shutdowns when the recirculation-pumps are stopped (refer to Relief Requests-RBCLCW-RR-1 and -3)?

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Response

Valve 70-92 will be exerci'sed'ur'ing cold shutdowns.'elief Request RBCLCW-RR-I will be deleted. and a cold shutdown jbstification will be provided.

Valve 70-93 cannot be reverse f'low tested without stopping recirculation pump cooling flow for an extended period because a flange must be disassembled and a spec'ial'itting installed'o permit"

. testing.

Valve 70-95 cannot be reverse flow tested without entering,the'drywell wh'i'ch<<has'-.an.inerted atmosphere during power'peratibns'nd'-most cold shutdbwns.

The licen'see will augment the b'asis in Relief Request RBCLCW-RR-3 to include a

tttore( detai1ed technical justification for not testing these

'alves during'cold shutdowns.

A modification may be made during the 1991 outage to add a test connection to facilitate leak rate testing of these valves.

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's the maximum safe'tP 5h'alysis'low r'at'e'erifi'ed through valves

'CT-9 and CT-10 during quarterly valve testing?

If-not",: how are these valves full-stroke exercised?

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'<.'The'licensee is verifying, the maximum safety:anaTysis flow

.'"rate through these'valves by using'"strap-on ulCrasonic'flow measuring equipment.

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Emer enc Service Water S stem 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 exedcised

as'-'required by IWV-3522(b)?

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These valves will be full-stroke exercised with flow during

. refueling outages by using a strap-on ultrasonic flow measuring instrument.

Relief Request ESW-RR-1 will be modified to reflect this change in.alternate test method; A

modification has been proposed>>for the 1991 refueling outage to permit quarterly exercising of.these valves using= a manual operator.

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.

Response

The licensee will verify the rev'erse flow closure of these valves with flow during cold shutdowns and will provide a

cold shutdown justification which explains why quarterly valve testing is impractical.

The position arm indication will be used to verify valve reverse flow closure.

Relief Request ESW-RR-2 will be deleted from the IST program.

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Emer enc Oiesel 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 (OGA-SOV-1 and -2) to determine if they should be included in the IST program.

Response

The licensee indicated that these valves will be included in the IST program.

They propose to verify valve operability by satisfactorily performing the monthly diesel generator test.

A relief request will be provided for these valves in the IST program.

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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.

Response

This valve is a trip valve that trips open upon loss of instrument air.

This valve does not perform an active safety function and may be deleted from the IST program.

NOTE:

The entire instrument air system may be upgraded to a safety related system which may result in additional valves being included in the IST program.

Emer enc Oiesel 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?

Response

The diesel generator fuel oil transfer pumps are positive displacement pumps and the flow rate will be calculated during the monthly diesel generator tests.

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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.

Response

The licensee indicated that even though certain instrument loop accuracies can be greater than 2l, the as found calibration accuracies are well below 21..

Two level instruments have accuracies of 2.3% over their range.

However, these instruments are used to calculate pump inlet pressures For the containment and core spray pumps.

When the level is extended down to the pump suction impeller datum point, the added height improves the accuracy to within 21'.

Relief Request PG-5 will be modified to only address these two level instruments.

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 vibration 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-I alternate testing proposes to use the allowable ranges of ANSI/ASME ON-6, however, no reference is made to any other aspect of the proposed vibration mon'itoring program.

The NRC has determined that the ON-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/ASME OM-6.

Response

The licensee will use the vibration measurement requirements that are identified in ANSI/ASME OM-6.

Relief Request PG-I will be modified to further specify how this testing will be performed.

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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?

Response

These pressures will be determined to the accuracy requirements of IWP-4110 except where specific relief is requested as discussed in Item 2. 1 above.

4.

Pump Relief Request PR-I 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.

Response

The licensee has ordered non intrusive flow instruments that the manufacturer indicates will meet the

21. accuracy requirements,

however, the installation attributes (i.e.,

line size, velocity profile, pipe characteristics, etc.) in the plant may result in accuracies above the 2X limit.

The licensee will withdraw this relief request.

When the instrumentation is received and the actual accuracies are determined, the licensee will request relief from the accuracy requirements of the Code if necessary.

5.

Since the core spray and the core spr ay 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?

Response

The flow rate and differential pressures for each of these pumps is evaluated in accordance with IWP-3200.

Pump Relief Request PR-2 will be deleted from the IST program.

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.

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Response

Pump flow rate cannot be measured during quarterly pump testing due to.the system configuration which does not have any straight runs of piping sufficient for the installation of flow rate instrumentation.

Pump flow will only be measured during refueling outages.

The portion of this relief request dealing with flow rate measuring instrumentation accuracy is temporary until new instrumentation is delivered and calibrated.

After the necessary instrumentation calibration is performed, Pump Relief Request PR-5 will be modified to remove the discussion about flow rate instrumentation accuracy.

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?

Response

This relief request will be modified to indicate that the diesel fuel oil transfer pumps will be tested quarterly during a diesel generator full-load test by measuring the time required to make an identified change in the diesel generator day tank level.

The licensee stated that preliminary calculations indicate that the Code accuracies may be met,

however, actual test performance may yield results that do not meet the requirements of IWP-4110.

If test results indicate Code required accuracy limits cannot be met, relief will be requested accordingly at that time.

The procedure will provide a reference time to fill the day tank from the lower to the upper day tank limit switches.

The time limit acceptance criteria will be calculated from the flow r ate allowable ranges from Table IWP-3100-2.

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 representative of pump bearing condition?

Response

The core spray and containment spray pumps are enclosed in a can where the pumps.are totally submerged in water and inaccessible for vibration measurements.

Vibration measurements are being made on the upper driver bearing housing of these deep draft vertical pumps in accordance with the guidelines of Relief Request PG-5.

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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).

Response

Pump Relief Request PR-9 will be deleted from the IST program.

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.

Response

The licensee will withdraw this relief request.

When the instrumentation is received and the actual accuracies are determined, the licensee will request relief from the accuracy requirements of the Code if necessary.

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DISTRIBUTION FOR MEETING

SUMMARY

DATED:

March 10, 1989

~0ocket-~f3.le NRC PDR Local PDR J. Sniezek PDI-1 Rdg R. Capra V. McCree M. Slosson OGC E. Jordan B. Grimes H.

Shaw ACRS (10)

H. B. Clayton, EDO J.

Johnson, RI

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