ML17215B283
| ML17215B283 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/26/1978 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Reed C Commonwealth Edison Co |
| References | |
| Download: ML17215B283 (9) | |
Text
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OCT 2 6 1978
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DISTRIBUTION Docket Files NRC PDRs "LOCAL PDR ORB#2 Reading Docket
- DLZi emann HSmith P0 1Connor VStello OELD JRBuchanan TERA
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Commonwea1th Edison Company ATIN:
Mr. Corde1 l Heed Assistant Vice Pr~sident Post Office Box 767 Chicago, 111 ino'is 6069D DGEisenhut BKGrimes ACRS)l6)
ORR#3 x/cpy file (7)
ORB#2 x/cnv file (7)
Gentlemen:
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He are reviewing the Inservice. Inspectio:i Program proposed for Dresden Unit Nos. 2 and 3 by your letter dated Ju1y 31~ 1978.
To continue our review~ the additional information hientified in Enclosure 1 is required.
This request r;::1ates to the.pump and vnlve testinq portion of your proposed proqram~ At a futu:*e: date v.dditiona1 informo.t-lt1n _relative to the inservice inspection portion *of your request rr.ay he 1equired *
- t Please provide the requested information by November 30, 1978.
- Enciosures:
As stated cc w/encl:
- See next
- page
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Sincerely,
- 6rigtria1 o;.rs:i:-Jt *'y:":
- Dennis L. ziemm."'.n Dennis L. Ziemann, Chief Operatirig. Reactors Branch #2 Divis ion of Operating Reactors*
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NRC FORM 318 (9-76) NRCM 0240 U* s._GOVERNMENT PRINTINO OFFICEa 10~e -
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Commonwealth Edison Company cc Mr. John W. Rowe Isham, Lincoln & Beale Counselors at Law One First National Plaza, 42nd Floor Chicago, Illinois 60603 Mr. B. B. Stephenson Plant Superintendent Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 Anthony Z. Reisman Natural Resources Defense Council 917 15th Street, N. W. --
Washington, D. C.
20005 Morris Pu_b l i c Library 604 Liberty Street Morris, Illinois 60451 October 26, 1978 r***
REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION AND TESTING PROGRAM DRESDEN STATION UNIT NOS. 2 & 3
.DOCKET NOS. 50-237 & 50-249 NOTE:
Numbers shown refer to specific relief request notes in the CE inservice testing report.
Section* XI and Appendix J refer to the ASME code and 10 CFR 50, respectively.
GENERAL QUESTIONS AND COMMENTS Pumps
- 1.
The reasons stated in Notes A3 and A4 do not provide sufficient information fo*r grar.ting relief.
Provide specific technical information to support the determinatior. that measuring bearing tempe:--ature and all other pump parameters in accordance wit~1 the requirem2nts of Section XI is impractical.
- 2.
CE states that pump vibration tests will be conducted and analyzed quarterly.
What is the specific technical basis for not complying with the monthly requirement of Section XI?
SPECIFIC QUESTIONS AND COMMENTS Pumps A.
D i e s e l Coo l i n g Wa t e r Component Cocling Service Water Syste~
- l.
CE states in Note A2 that instrumentation to directly measure Pi does not exist.
How is 6P measured or calculated? What alternate met~ods to determine Pi have been considered and what specific technical basis was used to determine these methods impractical?
What supplies the NPSH for these pumps.?
How is diesel cooling pump flowrate measured?
B.
High Pressure Coolant Injection System Poison Injection System
- 1.
CE states in Note Al that instrumentation to directly measure Pi does not exist.
How is 6P measures or calculated? What steps are being taken to assure compliance with code requirements?
GENERAL QUESTIONS AND COMME~TS Valves
- 1.
Have valve tests E* and ET been incorporated into your operating procedures for all valves identified?
- 2.
What are valve tests PIT, HR, and FST?
- 3.
Provide specific technical reasons to justify why you do or do not agree with our category changes and valve additiona.
Consider each valve and explain the consequence if it failed to functirin properly or was left out of its required operating position during an accident situation.
- 4.
For those valves that you have proposed to exercise during cold shutdown:
48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is the time period that defines how long the plant will be at cold shutdo~n befo~e va1ve exercising wil 1 be initiated.
How will you assure that valves not exercised during a given cold shutdown will be exercised at subsequent cold shutdowns pribr to the next refueling outage? ApproximRtely how long will it take to exercise all the valves that you have proposed to test at cold shutdowns?
- 5.
Identify all valves that require a check of valve position indicate-rs per IWV-3300.. These valves should be listed for our review.
- 6.
In a November, 1976 letter, the NRC provided a document titled NRC Staff Guidelines for Excludin~~rcising (cycling)) Tests of Certai~ Valves During Plant Operation.
In particu1a~. this document stated that when o~e train of a redundant system such as ECCS is inoperable, nonredundant valves in the remaining train should not be cycled since their failure would cause a loss of total system function.
For instance, during power operation in some plants, there are stated minimum requirements for t~e ECCS which allow certain limiting conditions for operation to be true at any one time and if the system is not restored to meet th2 requirements within the time period specified in a plant's TS, the reactor is required to be put in some other mode.
Furthermore, prior to initiating repairs, all valves and interlocks in the system that provide a duplicate function ere required to be tested to demonstrate operability immediately and periodically thereafter during plant operation. This situation would be co~trary to the NRC guidelines as stated in the document mentioned above.
Identify where, if any, existing operating procedures or TS require-ments may
~e contrary to the above mentioned guideline and what action will be taken to meet the guidelines mentioned above.
~PECIFIC QUEST!ONS AND COMMENTS Valves A.
Reactcr-necirculation System
- 1.
The specific relief requested in note 82 for valve 205-27 does not apply.
What is the specific technical basis for not leak testing this valve in accordance with Section XI?
- 2.
Specific relief was requested in note B4 from exercising valve 205-27 every 3 months.
Provide more specific technical information to support the determination that exercising this valve each cold shutdown is impractical.
B.
Hydraulic Control Rod Drive ~ys~em
- c.
- 1.
Review the safety related function or closed system containment isolation valves CV-0305-127 and CV~305-126 to determine if they should be categorized A.
(Refer to valves - general questions and comments number 3 for your reply~)
- 2.
Specific relief was requested in note B3 from full stroke exercising valves 0305-114, 115, 126, 127, and 138 every 3 months.
Provide specific technical reasons why these valves cannot be full stroke exercised every 3 months.
Technical specification requirements are not suitable justification for not complying with Section XI.
- 3.
What is the specific technical basis for not stroke time testing AO valves 030~-~26, 127, and 0302-21A, 21B, 22?
- 4.
Revie~ the safety related function of the following valves to determine if they should be catego~ized as indicated:
(Refer to valves -
ge~eral questions and comments nu~ber 3 for your reply.)
Category E 2-0305-112 Category A./E 2-0399-504, 506 Category fa../C 2-0305-138
- 5.
The NRC staff considers the following *valves safety related, and therefore they should be included in your I.S.T.
progra~ and categorized as indicated:
(Refer to valves - general questions and comments number 3 of your reply.)
Category A/E Category A Category c 0301-94 FVC-0305-120, 123 302-23 S0-0305-121 S0-0305-122 Shutdown Reactor Cooling System
- l. Specific relief was requested in note B20 from leak checking valves 1001-lA, 18, 2A, SA and 5B.
These valves perform both a pressure boundary isolation and a containment isolation function, and shall t"I" be leak tested to meet the requirements of Section XI and Appendix J..
What is the specific technical basis for not leak testing these valves in accordance with the requirem2nts of Section XI?
- 2.
The NRC staff considers the following valves safety related, and therefore they should be included in your IST program and categorized as incicated:
(Refer to valves - general questions and comments number 3 for your reply.)
Category C Category 8 1001-3A, 38, 3C 1001-4A, 48, 4C D.
Standby Liquid Control System
- 1. Specific relief was requested in note 82 from leak checking valves 1101-15 and 16.
~!hat is the: specific technical basis for r.ot leak checking these pressure boundary.isolation valves in accordance with the requirements of Section XI?
E.
Reactor Water Clean-Up
- l. Specific relief was requested in note 88 from exercising valve 1201-158.
State the spscific reasons why this valve cannot.be exercised during cold shutdowns.
What alternate tests have been considered?
All tests should be identified and specific technical reasons given to support the determination that these tests are impractical.
F.
Core Spray System
- 1. Specific relief was requested in Note 820 from leak checking valves 1402-9A, 98, 25A and 258.
These valves perform both a pressure boundary isolation and a con:air,ment isolation functi0n, ar.d should be leak tested to meet the requir2ments of Section XI and Appendix J.
What is the specific technical basis for not testing t~ese valves in accordance with the requirements of Section XI?
- 2.
Specific relief was requested in note 810 from stroke time testing valves 1402-3$A and 388.
What is the specific technical basis fer not stroke time testing these valves?
What would be the safety related consequence if these valves failed to close in a reasonable amount of time during a LOCA?
- 3.
Review the safety rela~ed function of valve~. 1402-19A, 198, 18A, and 188 to determine if they should be categorized E.
What would
~e the consequence if these valves were left out of their required operating position during an accident situation?
- e. G.
Low Pressure Coola~t Injection
- 1. Specific relief was requested in note B20 from leak testing valves 1501-25A, 25B, 22A, and 22B.
These valves perform both a pressure boundary isolation and a containme~t isolation function, and should be leak tested to meet the requirements of Section XI and Appendix J.
What is the specific technical basis for not testing these valves in accordance with the requirements of Section XI?
- 2.
Co11tainment *isolation valves 150T-28A, 28B, 27A, 27B, 18A, 188, l9A, 19B, 20A, 208, 38A, and 388 are not closed syste;r. isclatio;.
valves as stated in 'relief request note 811.
Review GDG-57.
What is the specific technical basis for not leak checking these valves in accordance with the requirements of Appendix J?
- 3.
Specific relief was requested in note 810 from stroke time testing valves 150-138 and 13A.
What is the specific technical ba:;is for
~ot stroke time testing thes~ valves? What would be the safety related consequence if these valves failed to close in a reasonable amount of t1me curing a LOCA?
- 4.
The NRC staff considers valves 1501-75A, 8, C, D, and 150l-76A, B, C, D safety related, and therefore they should be included in your IST program and categorized E.
(Refer to valves - general questions and comments number 3 for your reply.)
H.
Pressure Suppression Piping
- 1. Specific relh:f was requested in note 811 for all valves identified in this system.
Tr.is is not a closed system and note 811 does not apply.
ihese *valves should bf' leak tested in accordance with the requirements of Appendix J?
- 2.
Review the safety related function of check valves 1601-32A through 32F and 1601-33A through 33F to determine if they should be included in your !ST program and categorized C.
(Refer to valves - general questions and comments number 3 for your reply.)
I. Fuel Pool Cooling
- 1.
P & IDOISI-31 is not clear as to which 1 ines penetrate the drywell.
Provide us with a more detailed drawing or explanation.
If the drywell is penetrated, review the safety related function of the associated valves to determine if they should be included in your IST program and categorized ~/E.
(Refer to valves - general questions-and comments number 3 for your reply.)
r *.
. J.
High Press~re Injection System
- 1. s*tate the speci fie reasons why motor operated valve 2301-J is not stroke time tested.
- 2.
Specific relief was requested from exerc1s1ng valves 2301-34 and 45 and 2301-71 in notes Bl7 and Bl8 respectively.
Provide specific techntcal information to support the determination that exercising these va1ves during other than refueling outa~es is impractical.
K.
Main Steam Syste~
- 1.
Should electromatic relief valves identified in reli2f rec,uest Bl9 actually be designated 203-3A through 3E?
- 2.
Should containment isolation valves identified in relief request B13 acutally be designated 203-lA through 10 and 203-2A through 20?
- 3.
State tne specific reasons why containment isolation valves 203-2A through 20 are not and cannot be stroke time tested.
L.
Reactor Feedwater
- 1.
Specific relief was requested in note B14 from exercising v~lves 220-58A and 220-62A 2nd 62B.
State the specific reasons why these valves cannot be exercised during each cold shutdown that the dry-well is accessible.
- 2.
Specific r~lief was requested in note BS from exercising valve 220-59.
What is the specific technical basis for not ex2rcising this valve each cold shutdown?
- 3.
Review the safety related function of in-line valve 220-57B to deter~iline if it should be categorized E.
(Refer to valves - general questions and comments number 3 for your reply.)
- 4.
What is the test mode for the "AT" test per:.:.ormed on valves 220-62A and 62B?
M.
Reactor Building Cooling Water
- 1.
Why does CE request relief in note Bl2 for leak testing valves 37')2 and 3703 when testing in accordance with Appendix..J meets the requirements of Section XI?
- e. N.
- 1.
Review the safety related function of diesel generator multi position water regulating valves 3930--525 and 3931-525 to determine if they should be categorized B instead of locked open category E.
What
_would be the consequence if these valves failed to properly regulate fl ow?
- 2.
The NRC staff considers the following valves safety related, and therefore they should be included in your IST program and c~tegorize~
E.
(Refer to valves - general quest ions and comments nur:~ber 3 for your rep1 y.)
Unit 2 3934-A & B & C-500 3999-280 through 284
- 0.
Well Water Syst::m Uni~ 3 39999-274, 276, 277, 279 and 293 3999-264, 265, 267, 268 and* 269
- 1.
Review the safety related function of containment isolation valves 4327-500 and 4327-502 to C.etermine if they should be categorized A/E.
(Refer to valves - general questions and comments number 3 f~r your reply. )
P.
Reactor Building Equipment Drain Syste~
- l.
Review the safety related function of valve 2001-3 instead of 20001-6 to determine if it should be categorized A.
This change would ~eet the in tent of GDC-57.
Q.
Corrosion Test and Diesel Startup Air System
- 1.
Review the safety related function of MOV-50001-3 to determine if it should be categorized B.
(R2fer to valves - general questions and comments number 3 for your reply.)