ML17251A137
| ML17251A137 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/21/1988 |
| From: | Stahle C Office of Nuclear Reactor Regulation |
| To: | Kober R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| NUDOCS 8806300191 | |
| Download: ML17251A137 (18) | |
Text
June 21, 1988 Docket No.:
50-244 e
Please contact me when you are ready to meet with the staff.
Sincerely, Hr. Roger W. Kober, Vice President Electric and Steam Production Rochester Gas Im Electric Corporation 89 East Avenue Rochester, New York 14649 s
Dear Mr. Kober:
SUBJECT:
GINNA INSERVICE TESTING PROGRAM '
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Enclosed are general questions and preliminary commen'ts on the,GINNA Inservice Testing Program
( IST) which were used "as a basis'for.the inspec'tion at GINNA on Hay 16-20, 1988.
We understand that you pla'n to re-examine"theentire
.,'rogram as noted in your letter "to Region I of Hay. 27,a 1988.'e suggest a meeting on the long term IST Program after you have'had' sufficient time to complete your review of our enclosure.and take into consideration the results of the assessments o'n system operability.,',.Formal responses are not required prior to the proposed meeting.
However,'raft; responses prepared beforehand would faci litate, the discussions at,the proposed meeting.
Enclosure:
As stated
.OriBinal signed by:
Carl Stahle, Senior Project Manager Project Directorate I-3 Division of Reactor Projects I/II cc w/enclosure See next page DISTRIBUTION: LDocket Fige, NRC 6 Local
- PDRs, PDI-3 r/f, SVarga, BBoger, MRoshhrook,
- CStahle, Edor dao, ACRS (10),
- OGC, RWessman, BGrimes, TSullivan, CCowgill, RI DFt!
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NAME:MR ok: C e
DATE:06/@88
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Mr. Roger W. Kober Rochester Gas and Electric Corporation R.
E. Ginna Nuclear Power Plant CC:
Harry H. Voigt, Esquire
- LeBoeuf, Lamb, Leiby and MacRae 1333 New Hampshire
- Avenue, N.W.
Suite 1100 Washington, D.C.
20036 Ezra Bialik Assistant Attorney General Environmental Protection Bureau New York 'State Department of Law 2 World Trade Center New York, New York 10047 Mr. Bruce A. Snow, Superientendent Nuclear Production Rochester Gas 8, Electric Corporation 89 East Avenue Rochester, N.Y. 14649-0001 Resident Inspector R.E.
Ginna Plant c/o U.S.
NRC 1503 Lake Road
- Ontario, New York 14519 Stanley B. Klimberg, Esquire General Counsel New York State Energy Office Agency Building 2
Empire State Plaza
- Albany, New York 12223 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Supervisor of the Town of Ontario 1850 Ridge Road
- Ontario, New York 14519 Ms.
Donna Ross Division of Policy Analysis 5 Planning New York State Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223
ROBERT E.
GINNA NUCLEAR POWER PLANT PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS 1.
VALVE TESTING PROGRAM A.
General uestions and Comments l.
If a manual operator is used to full-stroke exercise check valves that cannot be full-stroke exercised with flow, is the force or torque that is applied to the mechanical exerciser measured to assure compliance with IWV-3522(b)?
2.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by
Relief from the Section XI leak rate testing requirements of paragraphs IWV-3421 through 3425 for containment isolation valves presents no safety problem since the intent of IWV-3421 through 3425 is met by Appendix J requirements,
- however, the licensee shall comply with Paragraphs IWV-3426 and 3427.
Does the Ginna IST program meet this staff position for testing containment isolation valves?
3.
Provide a listing of all valves that are Appendix J, Type C, leak rate tested which are not included in the IST program and categorized A or A/C?
4.
Provide the limiting values of full-stroke times for the power operated valves in the Robert E. Ginna Nuclear Power Plant IST program for our review.
What are the bases used to assign the limiting values of full-stroke time for these valves?
5.
Identify any cases where the remote position indicators are not being verified in accordance with the requirements of Section XI, IWV-3300 for applicable valves in the Ginna IST program.
6.
When flow through a check valve is used to indicate a full-stroke exercise of the valve disk, the NRC staff position is that verification of the maximum flow rate identified in any of the plant's safety analyses through the valve would be an adequate demonstration of the full-stroke requirement.
Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differential pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve.
Identify any valves in the Ginna IST program that are partial-stroke exercised and do not receive a full-stroke exercise as explained in this staff position.
7.
Section XI, IWV-3522, requires that check valves be exercised to the position(s) required to fulfilltheir function.
Provide a list of the safety function position(s) of all check valves in the Ginna IST program.
Identify any of these valves that are not exercised to their safety function position(s) during the indicated IST testing.
8.
The relief request and cold shutdown justification bases should 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.
9.
Which valves at Ginna are currently leak rate tested to verify a pressure boundary isolation function?
10.
The NRC staff position is that valves that serve both a pressure boundary isolation function and a containment isolation function must be leak tested to both the Appendix J and the Section XI requirements.
Identify the valves, if any, that serve both a
pressure boundary isolation function and a containment isolation function at Ginna.
What leak rate testing is performed on these valves?
11.
How are the remote position indicators being verified for solenoid operated valves in the Ginna IST program?
12.
Provide for our review, the PSIDs that show the following valves and identify their coordinates:
5129 6152 7226 7452 014 5392 6165 7443 7456 5393 6175 7444 8418 6151 7141 7448 8419 13.
IWV-3412 and 3522 permit valves to be tested during cold shutdowns if it is impractical to test them quarterly during power operation.
However, if valves cannot be tested during each cold shutdown (not to exceed one test every three months) a relief request should be provided instead of a cold shutdown justification.
14.
The NRC staff position is that the emergency diesel generators perform a safety function and that the appropriate pumps and valves in the emergency diesel air start, cooling water, and fuel oil transfer systems should be included in the IST program and be tested in accordance with the Code.
Engine driven pumps are considered to be part of the diesel and need not be tested separately.
15.
Identify any valves with fail-safe actuators in the Ginna IST program that are not tested in accordance with the requirements of Section XI, IWV-3415?
,16.
IWV-3412 states that if only limited operation of a valve is practical during plant operation, the valve should be part-stroke exercised during plant operation and full-stroke exercised during cold shutdowns.
Does the Ginna IST program comply with this Code requirement?
If so, identify those valves that receive a
partial-stroke exercise.
17.
Valves whose test frequency is required to be increased to once each month as required by IWV-3417 and which can only be tested during
cold shutdowns or refueling outages shall be repaired before plant start-up, or tested once each months 18.
There are many valves in Section 4.8, Category A Valves, of the Ginna IST program valve listing table that are check valves and as such should be categorized A/C and be tested to the requirements of both categories.
These valves should beleak rate tested to verify their category A leak tight integrity and tested as category C
valves in accordance with IWV-3520 to verify that they are capable of moving to their safety function positions.
19.
IWV-3417(b) states that if a valve fails to exhibit the required change of valve stem or disk position or exceeds its specified limiting value of full-stroke time, then corrective action shall be initiated immediately, and if the condition is not, or cannot be
~ corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the valve shall be declared inoperable.
Paragraph 4.4 of the Ginna IST program states that a valve which malfunctions during stroking will not be considered inoperable as defined by Technical Specifications when the malfunction does not prevent the valve from performing its safety function.
There appears to be a conflict between the IST program and the Code.
Provide a justification for permitting plant operation with degraded components which could have a high probability of failure if called upon to perform their safety function.
B.
Chemical and Volume Control S stem 1.
Is any credit taken for the use of auxiliary spray flow at Ginna to reduce RCS pressure to meet Branch Technical Position RSB 5-1? If so, review the safety function of valves HCV-142, 296,
- 297, 357, and 9313 to determine if they should be included in the IST program and tested to the Code requirements.
2.
Provide a more detailed technical justification for not exercising valves 204A, 371, and 427 quarterly during power operations (refer to Note 3)
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Provide a more detailed technical justification for not exercising valve 370B quarterly during power operations (refer to Note 2).
4.
Does valve 383B perform any active safety function other than containment isolation?
Is this valve exercised to the open position with flow quarterly during power operations?
5.
What is the safety function of valve 820?
6.
Could fai lure of either valve 112B or 112C in the open position during quarterly testing result in reactivity transients and possibly in a plant shutdown?
7.
Identify the emergency boration flow paths for which credit is taken at Ginna to shut the plant down and maintain it in a safe shutdown condition.
Are all of the pumps and active valves in these emergency boration flow paths included in the Ginna IST program?
C.
Reactor Coolant S stem 1.
Is credit taken for normally open manual valves 546 and 547 (shown as locked open on the P8 ID) to perform a containment isolation function at Ginna?
2.
Provide a more detailed technical justification for not exercising valves 853A and 853B quarterly during power operations (refer to Note 10).
Are these valves full-stroke exercised open as explained in guestion A.6?
3.
Provide a detailed technical justification for not stroke timing valves 430 and 431C during cold shutdowns.
4.
Provide a more detailed technical justification for not exercising valves 515 and 516 quarterly during power operations.
5.
Provide a detailed technical justification for not testing valves
- 590, 591,
- 592, and 593 during cold shutdowns.
6.
Are valves 852A and 852B Event V pressure boundary isolation valves?
If so, they should be category A valves and leak rate tested to the Section XI requirements.
Does the Ginna Technical Specifications require that these valves be leak rate tested after they are exercised?
7.
Passive valves are those valves which are not required to change position to accomplish a specific function.
Are valves 951 and 953 passive valves are defined by IMV-2100? If not, they must be exercised in accordance with the Code requirements.
8.
Provide a more detailed technical justification for not exercising valve 959 quarterly during power operation.
D.
Com onent Coolin S stem 1.
How is the reverse flow closure of valve 743 individually verified during the quarterly exercising test?
Does this valve perform any active safety function other than containment isolation?
2.
Are the following valves full-stroke exercised during each cold shutdown?
Do valves 750A and 750B perform any active safety function other than containment isolation?
Note 5 should be clarified to provide the negative consequences of exercising these valves quarterly during power operations.
749A 750B 749B
'59A 750A 759B 3.
Provide a more detailed technical justification for not exercising valves 813 and 814 quarterly during power operations (refer to Note 6).
4.
How are valves 723A and 723B verified to full-stroke open?
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0 5.
Review the safety function of valve 823 to determine if it sho'uld be included in the IST program and tested to the Code requirements.
E.
Safet In'ection S stem 1.
Valves 842A and 842B are never full-stroke exercised as required by the Code (refer to Note 28).
What alternate testing methods have been considered to verify the full-stroke capability of these valves?
2.
Is the maximum safety analysis flow (the highest flow rate through this flow path for which credit is taken in any safety analysis) verified through valves 867A and 867B during valve testing at refueling outages?
If not, how are these valves verified to full-stroke exercise (Refer to comment A.6 of this document)?
3.
Is the maximum safety analysis flow verified through valves
- 870A, 870B,
- 889A, and 889B during quarterly valve testing?
If not, how are these valves verified to full-stroke exercise?
4.
Note 11 identifies valves 877A, 877B,
- 878F, and 878H as passive valves.
Is credit taken for establishing post accident hot leg injection flow in any safety analysis at Ginna?
How are these valves individually leak rate tested to verify their leak tight closure capability?
5.
Why are valves 878G and 878J leak rate tested monthly?
Are these valves leak tested in accordance with the Section XI requirements to verify their ability to perform a pressure boundary isolation function?
6.
Review whether note 24 is applicable to valves 871A and 871B.
A reduction in redundancy is not a sufficient justification for not performing the Code required testing.
7.
Provide a more detailed technical justification for not testing valves 825A and 825B quarterly during power operation.
The safety injection pumps have redundant suction supplies from the refueling water storage
- tank, and therefore, Note 9 does not apply.
8.
Provide a more detailed technical justification for not performing testing of valves
- 826A, B,
C, and D when the normally open valve in the redundant flow path is inoperable while in the open position as stated in Note 25.
9.
Review whether Note 24 is applicable to valves 1815A and 1815B.
10.
Branch Technical Position RSB 5-1 establishes requirements for taking reactor plants from power operations to cold shutdown using only safety-grade equipment.
To comply with this position, credit is generally taken for either the safety injection accumulator vent paths or the accumulator discharge isolation valves.
Evaluate the safety function of the following valves to determine if they should be included in the IST program and tested to the Code requirements:
834A 8606A 8619A 841 8348 8606B 8619B 865 8603A 8616A 8630A 8603B 8616B 8630B ll.
Review the safety function the safety injection pump miniflow check valves 891A, 891B, and 891C to determine if they should be included in the IST 'program and be tested to the Code requirements.
If it is determined that these valves perform a safety function in the open
- position, how will they be verified to full-stroke open (see comment A.6 of this document)?
12.
Review the safety function of accumulator relief valves 830A and 830B to determine if they should be included in the IST program and tested to the Code requirements.
F.
Containment S ra S stem 1.
Is the maximum safety analysis flow verified through valves 862A and 862B during quarterly valve testing?
If not, how are these valves verified to full-stroke exercise (refer to comment A.6 of this document)?
2.
Provide a more detailed technical justification for not exercising the following valves quarterly during power operation (refer to Note 21).
What are the negative consequences of exercising these valves during power operation?
1819A 1819E 1819B 1819F 1819C 1819G 1819D 3.
Review whether note 24 is applicable to valves 860A, 860B,
- 860C, and 860D.
A reduction in redundancy is not sufficient justification for not performing the Code required testing.
4.
Provide a more detailed technical justification for not testing valves 897 and 898 quarterly during power operation.
Also, valve 898 is not referenced in Note 27.
5.
Provide a more detailed technical justification for not exercising valve 866A quarterly during power operation.
How are valves 866A and 866B exercised to the open position?
6.
Review the safety function of spray additive tank vacuum breakers 845C and 845D to determine if they should be included in the IST program and tested to the Code requirements.
G.
Service Water S stem 1.
Why are valves 4601,
- 4602, 4603, and 4604 categorized A in the Ginna IST program?
Is the seat leakage of these valves limited to a specific maximum amount in the closed position for fulfillment of their safety function?
Are these valves full-stroke exercised open as explained in guestion A.6?
2.
Valves that can be actuate'd by both system conditions, as simple check valves, and by power operators should be categorized 8/C and tested to the applicable Code requirements of both categories.
Review the categorization of valves 4561,
- 4562, and 4733.
3.
P&ID no.
33013-1250 shows the reactor compartment cooler outlet isolation as being valve 4755.
The Ginna valve program lists this valve as 4758.
What is the proper identification for this valve?
H.
Control Room Ventilation 1.
Are ventilation control valves 081 through 086 tested to all the Section XI requirements (i.e., stroke timed, fail-safe tested, etc.)?
2.
Review the safety function of valve 5850, the chilled water supply valve to the control room ventilation system, to determine if it should be included in the IST program.
Provide PE ID no. 33013-1920 for our review.
I.
Containment Ventilation 1.
If valves 5869 and 5879 are used for containment integrity during refueling outages, then they should be categorized A and leak tested to the Section XI requirements.
2.
Review the categorization of valves 7445 and 7478 to determine if they should be category A/C valves (refer to comment A. 17 of this document).
3.
Review the safety function of the following manual valves to determine if they should be included in the IST program as containment isolation valves and tested to the Code requirements.
1555 1567 1558 1570 1561 1573 1564 10
J.
Diesel Generator S stem 1.
Review the safety function of the following diesel generator air start system valves to determine if they should be included in the IST program and tested to the Code requirements (refer to comment A. 13 of this document).
5933A 5941A 5948A 5933B 5942A 59488 5934A 5943A 5948C 59348 5944A 5948D t
2.
Review the safety-related function of the following diesel generator fuel oil transfer system valves to determine if they should be included in the IST program and tested to the Code requirements (refer to comment A. 13 of this document).
5907 5959 5908 5960 5955 5961 5956 5962 K.
Auxiliar Feedwater 1.
Is the maximum safety analysis flow verified through the following valves during testing?
If not, how are these valves verified to full-stroke exercise (refer to comment A.6 of this document)?
3998 4004 4016 4000C 4009 4017 4000D 4010 4003 4014 2.
Valves that can be actuated by both system conditions, as simple check valves, and by power operators should be categorized B/C and tested to the applicable Code requirements of both categories.
Review the categorization of motor operated stop check valves 3996,
- 4007, and 4008.
How are these valves full-stoke exercised open'?
3.
How is valve 4023 verified to full-stroke exercise open during quarterly testing (refer to comment A.6 of this document)?
4.
Is credit taken for the service water supply flow path to the auxiliary feedwater system?
If so, evaluate the safety function of valves 4098,
- 4344, and 4345 to determine if they should be included in the IST program as category B valves and tested to the Code requirements'.
Review the safety function of solenoid operated valves 4324,
- 4325, and 4326 to determine if they should be included in the IST program as category B valves and tested to the Code requirements.
L.
Feedwater S stem 1.
Review the safety function of feed header check valves '3992 and 3993 to determine if they should be included in the IST program as category C valves and tested to the Code requirements.
M.
Standb Auxiliar Feedwater S stem 1.
Is the maximum safety analysis flow verified through the following valves during testing?
If not, how are these valves verified to full-stroke exercise (refer to comment A.6 of this document)?
9627A 9700B 9627B 9705A 9700A 97058 2.
Valves that can be actuated by both system conditions, as simple check valves, and by power operators should be categorized B/C and tested to the applicable Code requirements of both categories.
Review the categorization of motor, operated stop check valves 9704A I
and 9704B.
How are these valves full-stoke'xercised open?
3.
Review the safety function of check valves
- 9721A, 9721B,
- 9708A, and 9708B to determine if they should be included in the IST program as category C valves and tested to the Code requirements.
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N.
Fire Mater S stem 1.
What is the safety function of valves 5133 and 5136?
How are these valves verified to full-stroke exercise open during testing?
0.
Main Steam S stem 1.
Provide a detailed technical justification for not exercising valves 3516 and 3517 during cold shutdowns.
Can these valves be part-stroke exercised?
2.
Review the safety function of check valves 3504B and 3505B in the steam supply lines to the turbine driven auxiliary feedwater pump to deter mine if they should be included in the IST program and tested to the Code requirements.
Is each of these valves full-stroke exercised open with flow during the monthly testing of the turbine driven auxiliary feedwater pump?
If these valves perform a safety function in the closed position, how will their reverse flow closure be verified?
3.
Review the safety function of atmospheric dump valves 3410 and 3411 to determine if they should be included in the IST program and tested to the Code requirements'.
Review the safety function of non-return valves 3518 and 3519 to determine if they should be included in the IST program and tested to the Code requirements.
P.
Residual Heat Removal S stem 1.
Provide a more detailed technical justification for not testing valves 624 and 625 quarterly during power operation.
2.
Provide a more detailed technical justification for not exercising valves 701 and 720 quarterly during power operation.
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Are valves
- 700, 701,
- 720, and 721 Event V pressure isolation valves?
If so, they should be category A valves and leak tested to the Section XI requirements.
Does the Ginna Technical Specifications require that these valves be leak rate tested after they are exercised?
4.
Do valves 850A and 850B perform a containment isolation function?
If so, they should be categorized A and leak rate tested.
5.
Do valves 851A and 851B ever have to change position to perform any safety function?
If not, they should be categorized B passive.
6.
Provide a more detailed technical justification for not testing valves 857A, 857B, and 857C quarterly during power operation (refer id 857C degrade the injection phase of the residual heat removal pumps?
7.
Is the maximum safety analysis flow verified through valves 710A and 710B during valve testing?
If not, how are these valves verified to full-stroke exercise (refer to comment A.6 of this document)?
8.
Is the maximum safety analysis flow verified through valve 854 during valve testing?
If not, how is this valve verified to full-stroke exercise (refer to comment A.6 of this document)?
9.
Review the safety function of valves
- 1813A, 18138, and 822A to determine if they should be included in the IST program as category A valves and tested to the Code requirements.
10.
Review the safety function of valves 1812A and 1812B to determine if they should be included in the IST program as category C valves and tested to the Code requirements.
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2.
PUMP TESTING PROGRAM 1.
What safety related cooling is provided to the spent fuel pool?
Does the spent fuel pool cooling pump perform any safety function?
If it does, it should be included in the IST program and tested to the Section XI requirements.
2.
The diesel fuel oil transfer pumps perform a safety function and should be included in the IST program and tested to the Section XI requirements (refer to comment A. 13 of this document).
3.
Is the inlet pressure measured for the following pumps during monthly pump testing?
The system drawings do not show installed inlet pressure instruments, how are the required measurement taken?
Component cooling water pumps Containment spray pumps Residual heat removal pumps Safety injection pumps Service water pumps 4.
What flow paths are used for the monthly testing of the auxiliary feedwater pumps and the standby auxiliary feedwater pumps?
5.
How are the service water pump flow rates measured during monthly pump testing?
7.
Review the safety function of the boric acid transfer pumps to determine if they should be included in the IST program and tested to the Section XI"requirements.
8.
Are pump vibration measurements made in units of displacement or in units of velocity?
9.
Safety related pumps should be tested at the Code specified frequency even during cold shutdowns and refueling outages if they remain in service.
Components in systems out of service are not required to be tested until the system is returned to service.
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