ML17300A714
| ML17300A714 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/28/1987 |
| From: | Licitra E Office of Nuclear Reactor Regulation |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 8704030122 | |
| Download: ML17300A714 (26) | |
Text
Docket Nos.:
50-528, 50-529 and 50-530 Mr. E.
E.
Van Brunt, Jr.
Executive Vice President Arizona Nuclear Power Project Post Office Box 52034 Phoenix, Arizona 85072-2034
Dear Mr. Van Brunt:
SUBJECT:
ASME SECTION XI PUMP AND VALVE INSERVICE TESTING PROGRAM-PALO VERDE, UNITS 1, 2 AND 3 By letter dated August ll, 1986, you submitted unit specific Pump and Valve Inservice Testing Programs for Palo Verde.
As a result of the staff's review of the submittal, we have determined the need for additional information.
The specific information required is identified in the enclosed request.
, We ask that your provide the requested information so that we may complete the review of your inservice testing programs.
In order to ensure a complete under-standing of what is required, the staff and its consultant are prepared to meet with your staff to discuss the questions and your proposed responses.
Please advise us within two weeks of receipt of this letter as to when you would be ready to meet with 'the staff regarding this matter.
If you have any questions concerning this letter, you should contact me.
Sincerely, E. A. Licitra, Project Manager PWR Project Directorate No.
7 Division of PWR Licensing-B
Enclosure:
As stated cc:
See next page EALicitra 3/ig/87 PBE D
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Mr. E.
E.
Van Brunt, Jr.
Arizona Nuclear Power Project Palo Verde CC:
Arthur C. Gehr, Esq.
Snell 5 Wilmer 3100 Valley Center Phoenix, Arizona 85073 Mr. James H. Flenner, Chief Counsel Arizona Corporation Commission 1200 West Washington Phoenix, Arizona 85007 Charles R. Kocher, Esq. Assistant Council James A. Boeletto, Esq.
Southern California Edison Company P. 0.
Box 800
- Rosemead, California 91770 Mr. Hark Ginsberg Energy Director Office of Economic Planning and Development 1700 West Washington - 5th Floor Phoenix, Arizona 85007 Hr. Wayne Shirley Assistant Attorney General Bataan Memorial Building Santa Fe, New Mexico 87503 Kenneth, Berlin, Esq.
Winston 5 Strawn Suite 500 2550 H Street, NW Washington, DC 20037 Ms. Lynne Bernabei Government Accountability Project of the Institute for Policy Studies 1901 gue Street, NW Washington, DC 20009 Mr. Ron Rayner P. 0.
Box 1509
- Goodyear, AZ 85338 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations Combustion Engineering, Inc.
7910 Woodmont Avenue Suite 1310
- Bethesda, Maryland 20814 Mr. Roy Zimmerman U.S. Nuclear Regulatory Commission P. 0.
Box 239 Arlington, Arizona 85322 Ms. Patricia Lee Hourihan 6413 S. 26th Street Phoenix, Arizona 85040 Regional Administrator, Region V
U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596
I.
I' I)
PALO VERDE NUCLEAR GENERATING STATION, UNITS l, 2, AND 3 IST PROGRAHS (REVISION 0)
REVIEW REQUEST FOR ADDITIONAL INFORHATION I.
VALVE TESTING PROGRAH A.
General Comnents and uestions l.
The NRC position for inservice testing of valves ident1f1ed to be tested during cold shutdown is that testing shall commence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching the cold shutdown condit1on rather than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> specif1ed 1n the Palo Verde IST program.
2, Are all valves that are Append1x 3, Type C, leak rate tested 1ncluded 1n the IST program and categorized A or A/Cl I
3.
The NRC has concluded that the appl1cable leak test procedures and requirements for containment isolat1on valves are determined by 10 CFR 50 Appendix J,
- however, the appl1cant must comply with the Analys1s of Leakage Rates and Correct1ve Act1on requirements of Section XI, paragraphs IWV-3426 and 3427 (see valve relief request no. 41).
4.
The note on page 7, Sect1on 2.3.K states that test1ng of spec1fic valves dur1ng cold shutdown 1s not requ1red 1f plant operating conditions will not perm1t the test1ng of those valves.
It 1s the staff posit1on that spec1f1c requests for rel1ef should be provided for any valves that fall i'nto this category.
5.
Are there any valves 1n the a1r/n1trogen supply to the HSIVs and ma1n feedwater 1solation valves whose failure could prevent these isolation valves from performing their safety related functionsl
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6.
A general relief from Code requ1rements cannot be granted for as yet unspec1fied valves (Refer to Valve Relief Request No. 42).
If a problem does arise w1th test1ng any part1cular
- valves, then a specific request for rel1ef should be subm1tted for those valves giving the deta1led Justification which should include the radiation f1eld 1ntens1ty, the t1me required to perform the
- test1ng, and any other pertinent 1nformation that should be cons1dered when evaluating the request.
7.
The NRC staff pos1t1on 1s that rel1ef may be obta1ned from the trending requ1rements of Section XI [Paragraph IMV-3417(a)] for rapid acting valves,
- however, in order to obtain this relief the 11censee 1s requ1red to ass1gn a maximum 11m1ting stroke time of 2 seconds to those valves and perform correct1ve act1on as requ1red by INV-3417(b) 1f the measured stroke times exceed the 2 second limit.
Valve Rel1ef Request No. 40 is not 1n compliance w1 th th1s staff pos 1 t 1 on.
8.
Mhen flow through a check valve 1s used to 1nd1cate a full-stroke exerc1se of the valve d1sk, the NRC staff pos1tion 1s that ver1ficat1on of the max1mum flow rate identified in any of the plant's safety analyses through the valve would be an adequate demonstration of the full-stroke requirements.
Any flow rate less than th1s w1ll be cons1dered partial-stroke exerc1sing unless it can be shown (by some means such as measurement of the d1fferent1al pressure across the valve), that the check valve's d1sk posit1on at the lower flow rate would permit maximum requ1red flow through the valve.
Does the Palo Verde IST program conform to th1s staff positions 9.
Valve relief request no.
43 1s not necessary and should be deleted, if routine operat1onal testing of check valves during the course of normal plant operat1on complies w1th the requ1rements of Sect1on XI of the Code.
I It
lO.
Concerning valve relief request no. l9, prov1de a more specif1c technical ]ustif1cat1on for not full-stroke exercising valves GAE-VOll, GAE-V015, IAE-V021, and WCE-V039 quarterly or dur1ng cold shutdown.
ll.
Are all valves with a requ1red fail-safe position tested to the requ1rements of IWV-34l57
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B.
Auxi11ar Feedwater S stem 1.
Review the safety function of valves AF-V012 and V096 (f1gure AFP-001; G-6 and G-7) to determ1ne 1f they should be included in the IST program.
2.
Review the safety funct1on of valves AF-V005 and V009 (figure AFP-001; E-7 and C-7) to determine 1f they should be included in the IST program.
3.
Prov1de a more specific techn1cal Justification for not full-stroke exerc1s1ng valves AFA-V015 and AFB-V024 during cold shutdown.
4.
Prov1de a more spec1f1c techn1cal )ustification for not full-stroke exerc1sing valves AFA-V079 and AFB-VOBO during cold shutdown.
5.
Prov1de a more specif1c technical Justification for not full-stroke exercis1ng valves AFA-V007, AFB-V022, AFA-Vl37, and AFB-Vl38 quarterly.
C.
Chemical and Volume Control S stem l.
Rev1ew the safety funct1on of valves CH-V154 and V155 (f1gure CHP-002; B-13) and CH-HV524 (f1gure CHP-001; E-15) to determ1ne 1f they should be 1ncluded 1n the IST program.
2.
Review the safety funct1on of valve PCN-V215 to determine if it should be 1ncluded 1n the IST program.
3.
Does valve CHE-PDV240 have a required fail-safe position2 4..
Does valve CHN-Vll8 perform any safety funct1on in the closed positions If so, how 1s th1s valve ver1fied closed2
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5.
Provide a more specif1c techn1cal Justification for not full-stroke exerc1sing valves CHA-Vl77, Vl90, HV536, and CHN-UV514 dur1ng cold shutdown.
6.
What alternate methods have been considered to verify that valves CHB-V305 and CHA-V306 full-stroke open?
7.
Prov1de the P&ID that shows valve CHE-HV239.
8.
Provide a more spec1f1c techn1cal )ustification for not full-stroke exercis1ng valve CHE-V440 dur1ng cold shutdown.
9.
Is RCS charging expected to be stopped dur1ng each cold shutdown to allow testing of valve CHN-UV5017 10.
How is valve CHE-V435 ver1fied to full-stroke open quarterly7 II ll.
How is valve CHN-V835 verified to full-stroke closed dur1ng cold shutdown7 12.
Provide a more specif1c technical Justification for not full-stroke exercising valves CHB-UV515, CHA-UV5l6, and CHB-UV523 dur1ng cold shutdown.
13.
Why was the exercise test for valve CHN-V494 deleted from the IST program7 0.
Conta1nment Pur' S stem l.
Are valves CPA-UV4A, UV4B, CPB-UV5A, and UV58 full-stroke exerc1sed quarterly7 E.
Condensate Transfer S stem l.
Prov1de a more techn1cal )ustification for not full-stroke exerc1s1ng valves CTA-V016 and CTB-V020 quarterly,
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2.
Rev*ew the safety funct ion of valves CT-V037 and V038 (f1gure CTP-001; C-4 and B-4) to determ1ne 1f they should be 1ncluded 1n the IST program.
l.
Review the safety funct1on of valves DGA-V002, V003, and V-006 and DGB-VOll, V012, and V015 to determine 1f they should be included in the IST program.
2.
Provide P&ID's 01-H-DGP-OOl, sheets 6 and 8.
G.
Essential Chilled Mater S stem l.
Review the safety funct1on of valves ECA-V041 and ECB-V072 to determine 1f they should be 1ncluded in the IST program.
2.
Do valves EC-TV29 and TV30 (f1gure ECP-001; E-7 and E-3) have a
requi r ed fa 1 l-sa fe pos 1 t 1 on2 H.
Essent1al Cool1n Mater S stem l.
Review the safety function of valves EMA-V018, EMB-V029, V077, EMA-V079, EMB-VOBO, and EMA-V103 to determine if they should be 1ncluded in the IST program.
2.
Provide a more specific technical Justification for not full-stroke exercising valves EMA-UV65 and UV145 quarterly.
I.
HVAC Containment Buildin S stem l.
Mhat 1s the basis for ass1gn1ng a
max1mum stroke t1me of one second to valves HCB-UV44, HCA-UV45, UV46, and HCB-UV47 (see rel1ef request no. 40)7
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Conta1nment H dro en Control S st'em l.
Do valves HPA-V002 and HPB-V004'perform any safety funct1on in the open posit ion7 2.
What 1s the basis for assigning a maximum stroke t1me of one second to valves HPA-HV7A, HV7B, HPB-HVBA, and HVBB (see relief request no.
40)7 K.
Instrument and Service A1r S stem l.
Provide a more spec1f1c techn1cal )ustification for not full-stroke exercis1ng valve IAE-UV2 quar;terly.
L.
Hain Steam S stem l.
How are valves SGA-V043, V044, SGE-V887, and V888 verified to full-stroke open quarterly dur1ng plant operation2 Do these valves perform any safety function 1n the closed positions 2.
Review the safety funct1ons of the following valves to determ1ne if they should be included in the IST program.
Valve PV306A V350 PV306B V360 PV313B V339 PV313A V334 V346 V348 V357 V358 Locat1on fi ure SGP-001 A-ll A-lo A-13 A-l2 6-13 6-12 H-l2 H-ll 6-12 6-12 A-12 A-12
3.
Prov1de a more specific techn1cal )ustification for not full-stroke exerc1s1ng valves SGB-HV178, SGA-HVl79, HVl84, and SGB-HV185 quarterly.
4.
Prov1de a more specific techn1cal )ustification for not full-stroke exerc1s1ng valves SGA-UV134A and UVl38A quarterly.
5.
Provide the technical )ustification for not full-stroke exercis1ng valves SGE-UVl70, UVl71, UVl80, and UV18l quarterly.
6.
Are valves SGA-UVll33, UVll34, SGB-UVll35A, UV1135B, UVll36A, and UVll368 full-stroke exerc1sed quarterly 1n accordance w1th the requirements of Section XI2 If so, what is the purpose of relief request no.
277 7.
Do valves SGE-V642, V652, V653, and V693 perform any safety function 1n the open position7 How 1s each of these valve's verified to close during cold shutdown testings 8.
Shat is the basis for ass1gn1ng a max1mum stroke t1me of one second to valves SGB-HV200 and HV20l (see rel1ef request no. 40)7 9.
Prov1de the techn1cal )ustification for not full-stroke exerc1sing valves SGB-UVl32, UV137, SGA-UVl74, and UVl77 quar ter ly.
10.
Review the safety functions of valves SG-V002, VOOB, V431, and V432 (f1gure SGP-002; F-l5 and B-15) to determine if they should be 1ncluded 1n the IST program.
ll.
Do valves SG-FVlll3 and FVll23 (figure SGP-002; H-14 and D-14) have a requ1red fa1l-safe positions
A I
H.
Safet In ection and Shutdown Cool1n S stem l.
How are valves SIA-Vl20 and SIB-V130 full-stroke exercised quarterly7 2.
How are valves SIB-V484 and SIA-V485 full-stroke exercised quarterly2 3.
What are the consequences of valves SIB-UV659 or SIA-UV660 fa111ng closed during the1r quarterly testings 4.
What alternate methods have been cons1dered for full-stroke exercising valves SIA-V205 and SIB-V206 dur1ng cold shutdowns or refuel1ng outages?
5.
How are valves SIA-V434 and SIB-V446 full-stroke exerc1sed quarterly2 6.
Is valve SI-V463 (figure SIP-001; 0-8) Appendix 3, Type C, leak rate tested7 7.
Provide a more spec1f1c technical Justification for not full-stroke exerc1s1ng valve SIA-Vl64 and SIB-V165 dur1ng cold shutdowns.
What alternate methods have been considered for full-stroke exerc1s1ng these valves7 8.
The NRC staff has approved valve sample disassembly/inspection for full-stroke exerc1sing check valves on a refueling outage frequency.
Provide a more specif1c techn1cal )ustification for not full-stroke exercis1ng valves SIE-V215,
- V225, V235, and V245 dur1ng refueling outages.
9.
How are valves SIE-V217, V227, V237, and V247 ver1fied to full-stroke open utilizing RCS shutdown cooling'
10.
Provide a more spec1f1c technical Justification for not full-stroke exerc1s1ng valves SIA-V522, V523, SIB-V532, and V533 during cold shutdowns.
ll.
Are the follow1ng valves Appendix J, Type C, leak rate tested'?
SI B-UV615 SIA-UV617 SI B-UV626 SIA-UV635 SIA-UV637 SIB-UV646 SIB-UV616 SIB-UV625 SIA-UV627 SIB-UV636 SI A-UV645 SIA-UV647 12.
What are the consequences of valves SIB-HV690 and SIA-HV69l failing open dur1ng the1r quarterly test1ng7 l3.
How is full-stroke exercising verified for each of valves'IE-V540, V541, V542, and V5432 14.
Provide a more spec1fic techn1cal Justification for not full-stroke exercising valves SIA-HV605, HV606, HV607, HV608, SIB-HV-613, HV-623, HV-633, and HV-643 dur1ng cold shutdown.
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II.
PUMP TESTING PROGRAM l.
What alternat1ve tests have been cons1dered to detect any mechan1cal degradat1on of the d1esel generator fuel oil transfer pumps'?
11 2.
How is the operational read1ness of the diesel generator
]acket water cooling pump, lube o1l pump, and fuel oil booster pump ascertained dur1ng the monthly d1esel generator techn1cal spec1f1cat1on surve1llance test?
3.
Concern1ng pump relief request no. 1;Section XI, Paragraph IWP-3100 requ1res that both pump different1al pressure and flow rate to be measured.
4.
Rev1ew the safety functions of the boric acid makeup pumps to determ1ne 1f they should be 1ncluded in the IST program.
5.
Review the safety funct1ons of the fuel pool cooling pumps to determ1ne 1f they should be included 1n the IST program.
6.
Table IWP-3100-1 requires the measurement of pump flow rate; why 1s th1s parameter listed as being observed in the pump listings2 7.
Concerning pump rel'ief request no. 6, lack of proper flow measurement instrumentation does not negate the Code requ1rement t'hat flow be measured.
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