ML17309A413

Forwards Responses to Eg&G Questions Transmitted by NRC 880621 Ltr Re Pump & Valve Test Program.Status of Open Items & Changes to Previous Responses Provided

ML17309A413
Person / Time
Site:	Ginna
Issue date:	12/20/1988
From:	Mccredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Stahle C NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8901040433
Download: ML17309A413 (246)

Text

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-ACCESSION NBR:8901040433 DOC.DATE: 88/12/20 NOTARIZED: NO DOCKET I u1f- 05000240 AUTH.NAMEcW% AUTHOR AFFILIATION MCCREDY,R.C. Rochester Gas & Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION STAHLEFC. Assistant Director for Region I Reactors

SUBJECT:

Forwards response to EG&G questions a comments re pump 6 valve inservice testing program.

DISTRIBUTION CODE: A047D COPIES RECEIVED:LTR I ENCL I SIZE: /AS TITLE: OR Submittal: Inservice Inspection/Testing/Relief from ASME Code D

NOTES:License terminated on 4/2/73,at licensee's request. 05000240 8

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ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER, N.Y. 14649-0001 TSLSPHONS ARCA coos 71e 546-2700 December 20, 1988 U.S. Nuclear Regulatory Commission Document Control Desk Attn: Mr. Carl Stahle PWR Project Directorate No. 1 Washington, D.C. 20555

Subject:

Pump and Valve Testing Program Upgrade R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Stahle:

The purpose of this letter is to respond to questions transmitted by NRC latter dated June 21, 1988 relative to the Pump and Valve Test Program for Ginna Station, as well as to apprise the NRC of progress to date in the overall upgrade of this program.

A meeting between RG&E, NRC and EG&G representatives was held on November 1st and 2nd, 1988 during which responses to EG&G questions were presented. At the conclusion of this meeting, EG&G indicated concurrence with 95 of 99 responses, 'with four items that required additional information. Also, general agreement pertaining to approach, methodology, basis and program implementation was achieved. Final responses to the 99 EG&G questions are attached. for review.

In addition to the enclosed responses, the status of open items and changes to previous responses are discussed below.

The four open items have been acted on by RG&E and, are listed as follows:

a.- '-

How is full flow testing of valves 842 A&B licensee is to determine accomplished? OPEN ITEM: The if used.

discharging for full the flow accumulators testing or if into sample the RCS will be disassembly and inspection during refueling outages will be used as an alternate test method. )ht 8901040433 88i 220 ok~

PDR ADQCK 05000244 P PNU

Res onse to E-l Inservice testing will be accomplished by sample disassembly in lieu of full flow testing. This will be performed during the 1989 Refueling Outage using guidance established in ANSI standard OM-10. An alternative method of full flow testing for these valves will be pursued during subsequent test intervals. Full flow testing will be implemented only if a satisfactory test method is developed.

uestion E-2 How is full flow testing of valves 867 AGB accomplished? OPEN ITEM: The licensee is to determine if discharging the accumulators into the RCS will be used for full flow testing or if sample disassembly and inspection during refueling outages will be used as an alternate test method.

Res onse to E-2 Inservice testing will be accomplished by sample disassembly in lieu of full flow testing. This will be performed during the 1989 Refueling Outage using the guidance established in ANSI standard OM-10. An alternative method of full flow testing for these valves will be pursued during subsequent test intervals. Full flow testing will be implemented only if a satisfactory test method is developed.

How is full flow testing of valves 4601, 4602, 4603 and 4604 accomplished? OPEN ITEM: The licensee is to determine the test method to be used to demonstrate full stroke exercising of these valves.

Res onse to G-1 Inservice testing of these valves will be accomplished by sample disassembly in lieu of full flow testing.

This will be performed during the 1989 Refueling Outage using the guidance established in ANSI standard OM-10. An alternative method of full flow testing for these valves will be pursued during subsequent test intervals. Full flow testing will be implemented only if a satisfactory test method is developed.

estion P-9 Review the safety function of valves 1813A, 1813B and 822A to determine if they should be included in the IST Program as Category A valves and tested to code requirements. OPEN ITEM: The licensee is to determine what testing will be performed on these valves.

Res onse to P-9 Valves 1813A and 1813B perform a containment isolation function and will be tested in accordance with 10 CFR 50 Appendix J requirements. Valve 822A will not be individually tested. The system hydro test will include valve 822A and meet the closed system leakage requirements.

Additional action items were also noted during the November 1988 meeting, wherein technical agreement was reached, but schedule or administrative issues remained. The majority of these actions have been completed. Attached responses provide the basis needed to close all but one action item. Question A-1 requires test data to establish appropriate reference force/torque acceptance criteria. This activity will be complete prior to the end of the 1989 Refueling Outage.

Further evaluation of specific valves and systems has resulted in revised responses to Questions A-10 and G-2 which alter the position established at the November 1 6 2 meeting. The final response to Question A-10 has deleted valves 966A/B/C since they are not pressure boundary isolation valves, and added valves 852A/B, 200A/B and 202 to be identified. as Category A valves in the revised IST Program. In response to Question G-2, valves 4561, 4562 and 4733 have been determined to be butterfly valves (not check valves), and will therefore remain as Category B valves.

These decisions were accomplished in accordance with the following program guidelines established to facilitate orderly and timely review of pump and valve testing:

1) IST Program System Selection Criteria, Revision 1

2) IST Valve Program Test Requirements and Test Category Selection Guide for Ginna Station, Revision 1

3) IST Program Inservice Tests and. Test Methods, Revision 0

4) IST Program Review Methodology, Revision 1.

Resolution of technical issues within the IST Program is progressing on an aggressive schedule. Management and technical personnel from various departments including Ginna Station, Engineering and Quality Assurance have been coordinating efforts to complete this internal assessment. An organization charter

and implementing guidelines have been established. Staffing has been augmented with experienced contract personnel to support program completion. Issues relating to program upgrades for the next 10 year interval are being resolved concurrent with immediate corrective actions. If Program upgrades or immediate corrective actions require engineering/materials/or plant configurations not achievable on the proposed schedule, revisions to stated, actions will be submitted, for NRC review.

This intensive review effort has identified. detailed changes to be implemented no later than the 1989 Refueling Outage and has also identified upgrades consistent with the guidelines developed for incorporation in the next 10 year interval. It appears that the IST Program for the next 10 year interval will increase the total number of valves to be tested to approximately 440 from the current program scope of 324.

The present schedule requires that implementation of actions necessary to correct current program deficiencies be accomplished as soon as program/procedure changes will allow, but not later than the 1989 Refueling Outage. Additionally, program upgrades will be submitted as part of the next 10 year interval and factored into the schedule appropriately. RG&E will proceed with actions identified in response to the EG&G questions concurrent with the NRC review of this program. These actions will include deferrals and alternative test methods being substantiated by Cold Shutdown Justifications and, Relief Requests. An early NRC endorsement of RG&E's implementation of the program changes and. utilization of draft Relief Requests during the pre-1990 transition year is desired. Any deletions from the existing program will continue to be deferred throughout this transition year or pending NRC endorsement of the new program and changes involving correction of deficiencies or omissions. No changes will be less conservative than existing program commitments. Any NRC requests for additional information will receive prompt RG&E attention.

RG&E is pursuing the additional actions that must be completed as part of the program upgrade including review of test procedure adequacy, management and test personnel training, and preparation and submittal of the next 10 year IST Program. The submittal of the next 10 year IST program is scheduled for March, 1989. The other additional actions are scheduled for completion prior to the end of the 1989 Refueling Outage.

Very truly yours, Robert C. Mecre y General Manager Nuclear Production SFP/004

xc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

ROCHESTER GAS AND ELECTRIC CORPORATION R. E. GINNA NUCLEAR POWER PLANT PUMP AND VALVE INSERVXCE TESTING PROGRAM RESPONSE TO EGRG QUESTIONS AND COMMENTS TABLE OF COM.'ENTS PART 1: VALVE TESTING PROGRAM A. General Question and Comments Chemical and Volume Control System C. Reactor Coolant System D. Component Cooling System E. Safety Injection System F. Containment Spray System G. Service Water System H. Control Room Ventilation Containment Ventilation Diesel Generator System K. Auziliary Feedwater L. Feedwater System M. Standby Auziliary Feedwater System N. Fire Water System O. Main Steam System Residual Heat Removal System Q. Additional Questions 8901040433 PART 2: PUMP TESTING PROGRAM GFSN112

R. H. Ginna Nuclear Power Plant Pump and Valve, Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

1. 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)?

R~es onse:

Containment spray pump discharge check Valves 862A/B are presently the only check valves at Ginna that utilize manual operators to provide full-stroke exercising. The force applied to the mechanical exerciser on these valves had not been measured until recent testing. Presently, the force being exerted. on the operator to full-stroke exercise these valves is measured using a spring scale device. Test data indicates that the force exerted is minimal and. that no'inding or resistance is being observed.

Additionally, trending of these measurements is being done on a monthly basis. Reference valves are being determined to establish force/torque acceptance criteria for these valves, which will allow for testing consistent with the guidance of ASME/ANSI OM-10. This criteria will be in place prior. to the end of the next refueling outage.

(Also see response to Question 1.Pe1) gfsh056 11/21/88

R. E. Ginna Nuclear Power Plant, Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and. Comments question:

2. The NRC has concluded that the applicable leak rate test procedures and requirements for containment isolation valves are determined. by 10CFR50, Appendix J. Relief from the Section ZI leak rate testing requirements of paragraphs IWV-3421 through 3425 for containment isolation valves present 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 3427A. Does the Ginna IST program meet this staff position for testing containment isolation valves?

R~es ense:

All co n t ainment isolation valves (CIVs) at 'JGinna are leak rate tested in accordance with 10CFR50 Appendix requirements except as stated in responses 1.A.10 and 1.I.1. Additional testing is not performed via,IWV-3421 through 3425, therefore relief has been requested. accordi:ngly.

Analyses of leakage rates are compared to administrative leak rate limits but not to previous measurements, consistent with the guidance of ANSI/ASME OM-10. The administratively-controlled.

limits are based on the valve type and nominal size, as compared to the total allowable leakage through penetrations as designated in Plant Technical Specifications. Whenever these administrative leak rate limits= are ezceeded, corrective action is conducted in accordance with Plant Technical Specifications.

Regarding the trending requirements of IWV-3427(b), RG&E feels that the leakage rates for valves 6 inches and larger do not show enough consistency in the level of degradation prior to reaching the maximum leakage limit to justify maintaining these additional corrective action and trending requirements, and therefore will request relief from the trending requirements of IWV-3427(b).

This is consistent wi;th the current philosophy identified in ANSI/ASME OM-10 which does not require trending of leakage rates.

Correct ive actions will be taken on these valves only when the leak ra te limits are exceeded, as described above.

gfs~056 11/21/88

R is S

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Quests;ons and Comments

1. VALVE TESTING PROGRAM A,. General uestions and Comments question:

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?

~Res onse:

All valves required by Plant Technical Specifications to be Appendix J, Type C, Leak. Rate tested, are classified as Category A valves in the present Ginna IST Program, and will be categorized A or A/C in the upgraded IST program.

gfs~056 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments A. General uestions and Comments question:

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?

R~es onse:

The attached list provides acceptable stroke time values for power-operated valves currently in the Ginna IST Program.

Although these valves are stroke timed in both directions, the values listed pertain to stroke time in the safety function direction. It should be noted. that these Safety function position designations are currently being validated as part of the 1988 IST Program Review.

The basis used to assign these acceptable stroke time values is Owner specified. and was established following valve installation or maintenance.

First, a baseline reference value is established by stroking the subject valve three times. The average of these three stroke times is then multiplied by a factor of 1e25 (for valves with times > 10 seconds) or 1.5 (for valves with times < 10 seconds)

'to arrive at the acceptable stroke time value.

Should these values be exceeded when stroking to the safety function position, the valve would be declared inoperable and appropriate corrective action initiated immediately. If exceeded.

when stroking in the opposite (non-safety function) direction, the test frequency would be increased from quarterly to monthly and a Maintenance Work Request initiated to troubleshoot, repair or rework the valve as necessary.

14

}

The 1988 IST Program Review is currently exploring alternate methods of identifying and validating existing valve stroke time limiting values. Such methods would include evaluation of equipment performance ability and. component design, in comparison with the maximum system response time contained. in plant safety analyses and technical specifications. These evaluations may result in changes to the acceptable stroke times listed here, which would, be incorporated into revised test procedures.

gfs~056 12/07/88

Acceptable Stroke Time Valve I seconds/direction MOV 704A 142.0 close MOV 1815A 13 0 open NOV 515 42.0 close NOV 850A 155.0 open MOV 826A ,14.0 open MOV 826B 14.0 open MOV 826C 15.0 open NOV 826D 13.0 open MOV 871A 18.0 close NOV 841 14.0 open MOV 1813A 15.0 open MOV 875A 15.0 open MOV 876A 15.0 open MOV 516 40.0 close NOV 850B 156.0 open MOV 871B 20.0 close MOV 350 15.0 open MOV 865 14.0 open MOV 1813B 15.0 open MOV 875B 14.0 open MOV 876B 13.0 open MOV 1815B 13.0 open NOV 704B 143.0 close MOV 5171 28.0 close AOV 5873 26.6 close AOV 5871 28.6 open AOV 5872 30.1 open AOV 5874 26.7 close AOV 5875 29.5 open AOV 5876 36.0 open NOV 313 9.0 / close MOV 759A 17.0 / close MOV 759B 19.0 / close MOV 813 63.0 / close MOV 814 62.0 / close MOV 825A 3.0 / open MOV 825B 3.0 / open NOV, 856 153.0 / close MOV 896A 14.0 / close NOV 896B 14.0 / close MOV 852A 15.0 / open MOV 852B 15.0 / open MOV 749A 19.0 / close NOV 749B 19.0 / close MOV 857A 15.0 / open MOV 857B 15.0 / open MOV 817 54.0 / open MOV 700 146.0 / open MOV 701 137.0 / open MOV 721 139.0 / open

Acceptable Stroke Time Valve seconds/direction LCV 1003A 3.0 / close LCV 1003B 3.0 / close AOV 1721 4.0 close AOV 1723 3.0 close AOV 1728 3.0 close AOV 539 8.0 close AOV 1789 8.0 close AOV 1786 15.0 close AOV 1787 10.0 close AOV 508 10.8 close AOV 846 3.0 close AOV 7971 2.0 close AOV 745 3.0 close 017 3.0 close AOV 7970 2.0 close AOV 955 15.0 close AOV 7478 approx. 0.70 close LCV 112B 5.0 / ,open LCV 112C 5'.,0, / ,open AOV 5735 2.0 close AOV 5736 2.0 close AOV 5737 4.0 close AOV 5738 4.0 close AOV 966A 12.5 close AOV 966B 11.0 close AOV 966C 11.0 ,close AOV 4561 7.0 open AOV 4562 15.0 open AOV 1598 10.5 close AOV 1597 13.9 close AOV 1599 11.8 close SOV 921 0.49 close SOV 922 0.5 close SOV 923 0.46 close SOV 924 0.44 close AOV 7445 approx. 0.45 c'lose AOV 371 6.0 close LCV 427 3.0, / open AOV 959 7.87 close PCV 431C 5.0 open PCV 430 5.0 'open

Acceptable Stroke Time Valve seconds/direction AOV 5392 4.79 / close AOV 5879 3.6 / close AOV 5869 4.3 / close AOV 897 1.4 / close AOV 898 1.4 / close AOV 955 15.0 / close MOV 4609 29.0 close MOV 4780 30.0 close MOV 4613 33.0 close MOV 4670 35.0 close MOV 4616 38.0 close MOV 4735 33.0 close NOV 4663 26.0 close MOV 4733 32.0 close MOV 4664 35.0 close MOV 4734 32.0 close MOV 4615 39.0 close MOV 738A 143.0 open MOV 738B 146.0 open MOV 4614 33.0 close HCV 836A 16.0 open HVC 836B 16.0 open MOV 860A 16.0 open MOV 860B 16.0 open MOV 860C 15.0 open MOV 860D 15.0 open MOV 4000A 36.0 open MOV 4007 23.0 open MOV 4000B 34.0 open NOV 4008 22.0 open MOV 3996 15.0 open MIV 3504A 14.0 open MOV 3505A 10.0 open MOV 4027 33.0 open NOV 4028 30.0 open NOV 4013 31.0 open MOV 9701A 38.0 open NOV 9703A 35.0 open IIOV 9629A 21.0 open NOV 9701B 37.0 open NOV 9703B 35.0 open MOV 9629B 21.0 open NOV 9704A 35.0 open MOV 9704B 35.0 open AOV 8418 4.6 close AOV 959 7.87 close

R. E. Ginna Nuclear Power Plant.

Pump and Valve Inservice Testing Program Response to EGSG Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

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.

~Res onse:

The following list identifies those cases where remote position indication requirements are not being verified. per ASME Section XI, IWV-3300. Justifications for Continued Operation, Relief Requests (RR) and procedure changes (PCN) have been initiated. as appropriate.

Valve I ~Te Descri tion 430 PORV Pressurizer Power Operated Relief 431C PORV Pressurizer Power Operated Relief 590 SOV Reactor Head Vent SOV Reactor Head Vent 592 SOV Reactor Head, Vent 593 SOV Reactor Head Vent 434 Pressurizer Safety Relief 435 RV Pressurizer Safety Relief

Valve 5 T~e 921 GTV/SOV Loop A Hydrogen Monitor Inlet e>> GTV/SOV Loop A Hydrogen Monitor Outlet 923 GTV/SOV Loop B Hydrogen Monitor Inlet 924 GTV/SOV Loop B Hydrogen Monitor Outlet This list is subject to revision based on the results of the ongoing 1988 IST Program Review.

gfs~056 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve'Inservice,Testing Program Response to EG&G Questions and Comments 1- VALVE TESTING PROGRAM A. General uestions and Comments question:

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 analysis 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 exer cise as explained in this staff position.

~Res onse:

Check valves whose safety function is to open will be full-stroke exercised when possible. The following list identifies those check valves currently in the Ginna IST Program that are only partial-stroke exercised. Justifications for Continued Operation, Relief Requests (RR) and procedure changes (PCN) have been initiated. as appropriate.

Valve I Descri ti;on 842A" Loop A Accumulator Dump Line Check Valve 842B Loop B Accumulator Dump Line Check Valve 853A Core Deluge Check 853B Core Deluge Check 862A 1-A CSP Disch 862B 1-B CSP Disch gfs~056 12/07/88

Valve 5 Descri tion 867A Accumulator Dump and SI to Cold Leg Loop B 867B Accumulator Dump and SI to Cold Leg Loop A 870A 1-A to 1-C SI Pump Disch 870B 1-B to 1-C SI Pump Disch 4601 1A Service Water Pump Discharge 4602 1B Service Water Pump Discharge 4603 1C Service Water Pump Discharge 4604 1D Service Water Pump Discharge 710A 1-A RHR Pump Discharge 710B 1-B RHR Pump Discharge 854 RWST to RHR Pump Check 9627A 1C SAFP SW Suction 9627B 1D SAFP SW Suction This list is subject to revision IST Program Review.

based. on the results of the 1988 Check valves within the scope of the existing IST program are at least part-stroke exercised whenever any flow is passed through the valve. Some check, valves for which a full-stroke exercise can not be confirmed have been identified by appropriate Relief Request.

Justifications for Continued Operation have been written for those check valves currently in the program that are only part-stroke exercised and do not have appropriate relief request.

Cold Shutdown Justifications and Relief Requests are being developed, for these and any additional valves identified during the 1988 IST Program Review, and will identify any part-/full-stroke exercising that will be performed as well. as the associated. frequency.

gfs~056 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGKG Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

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 positions(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.

~Res onse:

The" following list provides the safety function position(s) of all check valves in the Ginna IST Program. An asterisk designates those valves not being exercised to their proper safety function position. Justifications for Continued Operation, Relief Request (RR) and procedure changes (PCN) have been initiated, as necessary.

Safet Function Valve I Position(s) 304A 1-A RCP Seal Injection open/closed.

304B 1-B RCP Seal Injection open/closed 370B Charging Line Isolation open/closed

'383B Alternate Charging LIne closed 528 N Supply to PRT closed 529 RNW to PRT closed 743 CC From Excess Letdown HX. closed 750A CC to A RCP closed 750B CC to B RCP closed

• 842A Loop A Accumulator Dump Line open/closed gfsh056 12/07/88

Safet Function Valve 5 Position(s)

• 842B Loop B Accumulator Dump Line open/closed

• 853A Core Deluge Check open/closed

• 853B Core Deluge Check open/closed

• 862A 1-A CSP Disch open/closed.

• 862B A-B CSP Disch open/closed.

• 867A Accumulator Dump and SI to Cold Leg Loop B open/closed

• 867B Accumulator Dump and SI to Cold Leg Loop A open/closed

• 870A 1-A to 1-C SI Pump Disch open/closed

• 870B 1-B to 1-C SI Pump Disch open/closed 877A High Safety Injection Loop B Hot Leg closed 877B High Safety Injection Loop A Hot Leg closed 878F High Safety Injection Loop B Hot Leg closed 878G 1-A SI Pump to Cold Leg Loop B open/closed 878H High Safety Injection Loop A Hot Leg closed.

878 J 1-B SI Pump to Cold Leg Loop A open/closed, 889A 1-A SI Pump Disch open/closed 889B 1-B SI Pump Disch open/closed 1713 N~ to RCDT closed gfsh056 12/07/88

Safet Function Valve 5 Descri tion Position(s)

• 4601 1A Service Water Pump Discharge open/closed.

• 4602 1B Service Water Pump Discharge open/closed

• 4603 1C Service Water Pump Discharge open/closed

• 4604 1D Service Water Pump Discharge open/closed 5393 Instrument Air to Containment Isolation closed 7226 Service Air Isolation Inside Containment closed 8419 Demin. Water to Contain-ment Isolation closed

• 8623 Nitrogen to Accumulator Isolation closed 9229 Fire Service Water Containment Isolation closed

• 710A 1-A RHR, Pump Discharge open/closed.

• 710B 1-B RHR Pump Discharge, open/closed 723A 1-A CC Pump Discharge, open/closed 723B 1-B CC Pump Discharge open/closed

• 847A A-CSP From Spray Additive Tank to Eductor open/closed.

• 847B B-CSP From Spray Additive Tank to Eductor open/closed

• 854 RWST to RHR Pump Check open/closed

• 866A CS Pump 1-A to Charcoal Filter Deluge open/closed 866B CS Pump 1-B to Charcoal Filter Deluge open/closed gfs~056 12/07/88

Safet Function Valve 5 Position(s) 3516 1B Main Steam Isolation closed 3517 1A Main Steam Isolation closed

• 3998 TAFP Discharge Check open/closed

• 4000C 1A MAFP Discharge Check open/closed

• 4000D 1B MAFP Discharge Check open/closed.

• 4003 TAFP to S/G 1A open/closed

• 4004 TAFP to S/G 1B open/closed.

• 4009 1A MAFP to S/G 1A open/closed

• 4010 1B MAFP to S/G 1B open/closed

• 4014 TAFP Suction open/closed.

• 4016 1B MAFP Suction open/closed

• 4017 1A MAFP Suction open/closed.

• 4023 TAFP Recirculation open/closed.

5133 Diesel Fire Pump Disch. open/closed 5136 Motor Fire Pump Discharge open/closed.

• 9627A 1C SAFP SW Suction open/closed

• 9627B 1D SAFP SW Suction open/closed

• 9700A 1C SAFP Discharge open/closed

• 9700B 1D SAFP Discharge open/closed

• 9705A 1C SAFP to S/G 1A open/closed

• 9705B 1D SAFP to S/G 1B open/closed

• 4561 Containment Vent Recirc.

Fan Discharge open 4562 Containment Vent Recirc.

Fan Discharge open gfs~056 12/07/88

Safet Function Valve 5 Descri tion Position(s) 4733 Air Cond.. Chillers SW Insolation closed 3996 TAFWP Discharge open

• 4007 MAFWP 1A Discharge open/closed

• 4008 MAFWP 1B Discharge open/closed It should be noted that the ongoing 1988 IST Program validating the safety function position designations Review is as they appear in the current IST program and test procedures.

Therefore, these position descriptions are subject to change pending the results of this review.

gfs%056 12/07/88

t I.

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R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

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.

~Res onse:

All Relief Requests and Cold Shutdown Justifications (CSJ) are being updated to clearly identify the adverse plant consequences of testing as required. by the Code. See attached, guidelines.

gfsh056 g s 11/21/88

R. E. Ginna Nuclear, Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and. Comments question:

9. Which valves at Ginna are currently leak rate tested to verify a pressure boundary isolation functions

~Res onse:

The following valves are currently leak rate tested to verify a pressure boundary isolation function:

Valve No.

842A Loop A Accumulator, Dump Line 842B Loop B Accumulator Dump Line 853A Core Deluge Check 853B Core Deluge Check 867A Accumulator Dump 6 SI to Loop B Cold Leg 867B Accumulator Dump E SI to Loop A Cold Leg 877A High Safety Injection Loop B Hot Leg 877B High Safety Injection Loop A Hot Leg 878A 1-A SI Pump Header to Loop B Hot Leg 878C 1-B SI Pump Header to Loop A Hot Leg 878F 1-A High Safety Injection to Loop B Hot Leg 878H 1-B High Safety Injection to Loop A Hot Leg 878G 1-A SI Pump Header to Loop B Cold Leg 878J 1-B SI Pump Header, to Loop A Cold Leg Valves 878A/C are motor-operated gate valves. Valves 853A/B, 867A/B, 877A/B, and 878F/G/H/J are Event V check valves which are tested as PBIV's per Ginna Technical Specifications. Check valves 842A/B are not Event V valves per Technical Specifications.

All of these valves, except 878A/C, are included, in the current IST Program as Category A valves and will be identified as Category A/C in the revised IST program. MOV-878A/C are presently being leak rate tested per Technical Specifications and.

will be included into the revised. IST program as Category A valves.

gfsh056 12/07/88

R. E. Ginna Nuclear Power Plant, Pump and Valve Inservice Testing Program Response to EGEG Questions and Comments

1. VALVE TESTING PROGRAM A. General. uestions and. Comments question:

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?

R~es onse:

There ar e no valves that are currently required. to be leak rate tested to verify both a pressure boundary isolation function and containment isolation function at Ginna. Eowever, the 1988 IST program review has determined that the following valves do serve both functions:

Valve No. Descri tion MOV-701 RHR Inlet Isolation from Loop A MOV-720 RHR Return Isolation to Loop B MOV-852A RHR Deluge Line to the Reactor Vessel MOV-852B RHR Deluge Line to the Reactor Vessel AOV-200A CVCS Letdown Orifice Stop Valve AOV-200B CVCS Letdown Orifice Stop Valve AOV-202 CVCS Letdown Orifice Stop Valve MOV-701/720 and 852A/B are not considered Event V pressure isolation valves at Ginna, nor do Technical Specifications require them to be leak rate tested after exercising.

Containment leakage testing is not required for these valves because these lines are water-filled when containment isolation is required, per letter dated 9/21/78 L. D. White to Ziemann (USNRC). These valves are therefore identified as Category B in the current IST program. However, they do receive hydro testing following each refueling to demonstrate acceptable low leakage rates , and, therefore will be identified in the revised IST program as Category A, requiring ASME XI leak testing each refueling outage.

Relief Request Format 1.0 ~Pur ose This guideline briefly describes the format and content of Relief Requests being prepared fox the 1988 IST Program Review.

2.0 Instruction 2.1 Relief Requests shall be formatted with sections identified in Figure 1.

2.2 A copy of relief request development guidelines shall be completed to document the evaluation. (Figure 2) gigzz gfsi036

. -o

RELIEF REQUEST NO.

SYSTEM: Enter system affected.

COMPONENT(S): Enter valve(s) affected. If request is for large group of valves, indicate attachment.

a CATEGORY: Enter valve category from program plan.

SAFETY CLASS: Enter safety class from program plan.

FUNCTION: Describe valves safety function.-

TEST REQUIREMENT: Describe tests and frequencies required by the IST program's implementation of ASME Section XI criteria requiring relief.

BASIS FOR RELIEF: Provide detailed information to support determination that test requirements are impractical. Utilize a relief request development guideline checksheet. (Figure 2)

ALTERNATE TESTING: Describe all alternate test methods or activities to program requirements that be performed when practical to provide an will acceptable level of assessing operational readiness.

Figure 1 gfsk036

8 RELIEF REQUEST DEVELOPMENT GUIDELINES 88-10 REVIEW FOR RELIEF REQUEST 5 VALVE(S)

In preparing a basis for Relief Requests (RR) from ASME Section ZI pump and valve test requirements, indicate review methods and.

considerations utilized by checking the appropriate column.

List additional considerations utilized as applicable.

Consi derations: (not all inclusive)

The Request is unique to Ginna's System/

sub system.

2.) The NRC has accepted. a similar request 3.) All efforts to meet requirement have been considered and found to be tech-nically un-feasible.

4.) Maintenance/Modif ication/Per formance history has been considered.

5.) Plant mode/system configuration is defined.

6.) The component has no operating-safety related function.

7.) Component failure during testing could compromise plant safety or Technical Specification compliance.

8.) Technical Specification compliance review (i.e. isolation and controlled power removed during power operation).

9.) a) Component/system modif ication can satisfy test commitment.

b) If yes, wi'll the modification practical/economical/feasible.

be 10.) Can previous or existing PTs and RSSPs be used. as credit for required test.

11.) Credit for post-maintenance testing was considered.

12.) Disassembly inspection in lieu of testing was considered.

Review of ASME Section ZI Code interpretations Are access provisions sufficient for testing.

15.) Are environmental conditions prohibitive.

Is test instrumentation adequately provided.

17.) Can valve cycling during power operation cause unsafe conditions.

Additional Consideration:

Figure 2 gfsh036

COLD SHUTDOWN JUSTIFICATION FORMAT 1.0 ~Per ose This guideline briefly describes the format, content and process for preparing Cold Shutdown Justifications (CSJ) as a result of the 1988 Inservice Test (IST) Program review.

2.0 Instructions Each CSJ shall be written in paragraph form for the purpose of subsequent compilation into a table of notes for the IST Program.

2.1 As a minimum, CSJs shall address the following items:

component identification/and description component function impracticalities of testing during power operation alternate testing frequency alternate test/relief request. references, if applicable.

2.2 Following preparation, the CSJ will be included into the appropriate IST program system review package.

2.3 CSJs will be assigned a CSI following final package review and approval.

2.4 Table of CSJs will be compiled following completion of all package reviews.

.S. 9/23/88 gfsk047 Rev. 0

AOV-200A/8 and 202 will be included in the revised. IST program as Category A valves, requiring Appendix J and ASME XI leak testing.

gfs~056 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM A. General uestions and. Comments question:

11. How are the remote position indicators being verified. for solenoid operated. valve (SOV),in the Ginna IST program?

R~es onse:

Presently, SOV remote position indication is verified by of a change in flow through the subject valve'erification whenever possible; or alternatively, by an inspection of the valve through a full cycle utilizing "hands on" verification of the vibration of the solenoid when changing position.

gfs~056 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and. Comments question:

12. Provide for our review, the P&IDs that show the following valves and identify their coordinates:

5129 5392 5393 6151 6152 6165 6175 7141 7226 7443 7444 7448 7452 7456 8418 8419 014 R~es onse:

The P&IDs listed below were given to EG&G during the Nov. 10, 1988 meeting at RG&E, with the above mentioned valves highlighted. It. should be noted that valve 014 appears on P&ID I33013-1273 as 2RCV-1014.

Valve I P&ID/UFSAR Fi ure Coordinates 014 1273/NA H-7 5129 NA/6.2-17 NA 5392 1893/NA A-9 e

5393 1893/NA A-10 6151/6165 1915/NA B-1 6152/6175 1915/NA D-2 7141 1886/NA C-7 7226 NA/6.2-65 NA 7443 1882/NA H-10 gfsi056 11/21/88

Valve I PRIED/UFSAR Fi ure Coordinates 7444 1882/NA 1.-8 7448/7452 1278/NA H-2 7456 1278/NA I-2 8418/8419 1908/NA glsi056 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and. Comments question:

13. IWV-3412 and. 3522 permit valves to be tested during cold shutdown if it power operation.

is impractical to test them quarterly during 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.

R~es onse:

RG&E recognizes and does comply with this position. The reference notes within the, current IST program identify exceptions and exemptions to the testing requirements of Article.

IWV which are considered to be approved relief requests. The upgraded IST program will include appropriate Cold Shutdown Justification and. Relief Requests as necessary. Valves which can be full-stroke exercised only at cold shutdown will be specifically identified and, justifications developed to, utilize cold shutdown testing. In the event full-stroke testing of any valve is not possible at a cold shutdown frequency, appropriate relief requests will be prepared.

gfsE,056 11/21/88

I R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

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.

R~es Oils e:

The service water cooling system for the diesel generators is currently in the Ginna IST Program. All appropriate safety-related pumps and valves in diesel generator support systems (specifically starting air and fuel oil transfer) have been incorporated in the revised IST Program, and will-be tested. in accordance with the Code unless specific relief is requested..

Also see response to Questions 2.2, 1.J.l, and 1.J.2 gfs~056 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G.Questions and Comments

1. VALVE TESTING PROGRAM A. General. uestions and Comments guestion:

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?

~Res onse:

All valves in the Ginna IST Program that have fail-safe actuators are solenoid-operated or air operated, and are tested to Section XI, IVV-3415 requirements by virtue of exercising. Exercising these valves locally or via control room switches causes the valve to energize and deenergize resulting in a fail safe position at some time during the testing. Should any additional valves be identified during the 1988 IST Program review as having fai1-safe actuators, they will be tested to the Code requirements or appropriate relief requested.

gfsh056 12/07/88

II l

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and, Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

16. IWV-3412 states practical during that, plant if only limited operation of a valve is 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.

~Res onse:

The Ginna IST program complies with the valve exercising requirements of IWV-3412, with relief requested to full-stroke exercise those power-operated. valves during cold. shutdowns and/or refueling outages which cannot be exercised during plant.

operation. Part-stroke testing of power-operated. valves is generally not possible. None of the electrically-operated valves identified in the Ginna IST Program can be part-stroked. because of the design logic of the operating circuits. These circuits are such that. when an open or close signal is received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other direction. Air-operated valves in the program are full-stroke exercised at the Code required frequency except where identified. by Relief Requests or Cold Shutdown Justifications.

gfs~056 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGEG Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

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 shutdown or refueling outages shall be repaired. before plant start-up, or tested once each month.

R~es onse:

Ginna currently follows suitable guidelines for corrective action in this matter, as described. in response to Question 'A.4.

Whenever any valve's established stroke time limit is exceeded when exercising to the safety function position, the valve would be declared inoperable and. appropriate corrective action initiated immediately. Valves which are tested only during cold shutdown or refueling outages would be repaired. prior to start-up. Appropriate clarifications and/or additions will be made to the new revision of the IST program.

gfs~056 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to,EGGG Questions and Comments

1. VALVE TESTING PROGRAM A.

'I General uestions and'omments question:

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 be leak 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 position(s).

~Res onse:

Check valves listed in section 4.8 of the Ginna IST Program are tested to verify their leak tight integrity and exercised., to verify the capabilities of stroking to their appropriate safety function position(s). In areas where testing has deviated from the requirements of IWV-3520, relief has been requested and/or Justifications for Continued Operation (JCOs) written to address any concerns. (See response to Questions 1.A.6 and. 1.Ae7)

The 1988 IST Program Review will assess and validate the functions and categorization of these valves. The valve table format is being changed in the revised IST Program, and. will categorize appropriate check valves as A/C.

gfsh056 11/21/88

tt J

t,

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGRG Questions and Comments

1. VALVE TESTING PROGRAM A. General uestions and Comments question:

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.

R~es onse:

Valves which exceed their stroke time limits when exercised to their safety function positions will be declared inoperable and appropriate corrective action initiated immediately. If stroke time limits are exceeded when a valve is exercised in the non-safety function direction, the testing frequency would be increased to monthly and a maintenance work request for repair/troubleshooting initiated.* The intent of para. 4.4 of the current IST program was to recognize that valves may show indications of degraded condition, but would still be considered operable if they can still operate to their safety function position within the specified. limits. Paragraph 4.4 will be deleted by the IST program revision that is now in progress.

• Also see response to Questions A.4 and A.17 gfsh056 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM B. Chemical and. Volume'ontrol S stem question:

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.

R~es onse:

Credit is not taken for use of auxiliary spray flow to'reduce RCS pressure during shutdown/accident conditions. Certain valves in this flow path require air to open. Instrument air at Ginna is not safety related and. may not be available post-accident.

should also be noted. that Ginna is not required to meet'ranch It Technical Position RSB 5-1.

gfsk075 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM B. Chemical and Volume Control S stem question:

2. Provide a more detailed technical justification for not exercising valves 204A, 371, and 427 quarterly during power operations (refer to Note 3).

R~es onse:

Exercising valves 204A, 371 and 427 during power operation would interrupt normal letdown flow from the RCS which could result in a loss of pressurizer level control and possible plant trip.

Furthermore, this testing may result in excessive thermal cycles to the regenerative heat exchanger which could cause premature equipment failure and reduction in its expected service life.

Note 3 will be rewritten as a Cold Shutdown Justification with the negative consequences of at power testing specifically stated.

gfsk075 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM B. Chemical and Volume Control S stem guestion:

3. Provide a more detailed technical justification for not exercising valve 370B quarterly during power operations (refer to Note 2).

~Res onse:

Valve 370B is required to be open during normal plant operation to allow for charging to the RCS. Exercising this valve during at power operation would interrupt normal charging flow to the RCS which could result in loss of pressurizer level control and possible plant trip. Additionally, this testing may result in excessive thermal cycles to the regenerative heat exchanger which could cause premature equipment failure and reduction in its expected service life. Note 2 will be rewritten as a Cold Shutdown Justification with any negative consequences of at power testing specifically stated.

gfsh075 11/21/88

R. E. Ginna, Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM B. Chemical and Volume Control S stem question:

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?

~Res onse:

The alternate charging path is not credited for supplying RCS makeup during shutdown or accident conditions. Valve 383B performs no other safety-related function than Containment Isolation, and therefore requires no open position exercising testing.

gfs%075 11/21/88

J V

P

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM B. Chemical and Volume Control S stem question:

5. What is the safety function of valve 820?

R~es onse:

Valve 820 provides a containment isolation function as stated. in Plant Technical Specification table 3.6-1. It is categorized A-passive and, is leak rate tested per Appendix J requirements.

This valve is mistakenly identified, as valve 821 on P&ID 33013-1264 and. in table 6.2-13 of Ginna's UFSAR. These documents will be updated. to correctly identify the CIV outside containment at penetration 112 as 820.

gf s%075 12/07/88

JI I i

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM B. ,Chemical and. Volume Control S stem question:

6. Could failure of either valve 112B or 112C in the open position during quarterly testing result in reactivity transients and possibly in a plant shutdown?

R~es onse:

Failure of valve 112B in the open position or valve 112C in the closed position during quarterly testing could . result in reactivity transients and. subsequently a plant trip. Cold Shutdown Justifications have been written which specifically address the negative consequences of testing these valves at power.

gfs%075 11/21I88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM B. Chemical and Volume Control S stem question:

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?

R~es ense:

The boration flow paths for which credit is taken at Ginna are:

1. Charging from, the RWST through the RCP seals into the RCS

2. Charging from the RWST through the normal charging path into the RCS

3. Safety Injection from the RWST or BAT to the RCS cold leg With the exception of the charging pumps, all of the pumps and active valves in these flow paths are included in the current Ginna IST program. The charging pumps will be included in the next revision to the IST program.

Use of the Boric Acid. Transfer Pumps and associated valves to provide direct boration to the RCS is not credited for the design basis accidents discussed in Chapter 15 of Ginna's UPSAR.

Therefore, these pumps and associated valves are not required to be included in the Ginna IST Program.

(Also see response to Question 2.7) gfs%075 11/21/88

R. E. Ginna Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EGGG Questions and. Comments

1. VALVE TESTING PROGRAM C. Reactor Coolant S stem question:

1. Is credit taken for normally open manual valves 546 and 547 (shown as locked open on the P&ID) to perform a containment isolation function at Ginna?

R~es ense:

Manual valve 547 has been changed to a locked closed valve with credit taken for performing a containment, isolation function.

Manual valve 546 is a normally open valve which performs. a containment isolation function although not automatic. NRC approval has been received on the V-546 configuration (see NUREG-0821 Final SEP Review for R.E. Ginna dated 12/82, Section 4.22.3).

Valve 546 is leak rate tested in accordance with Appendix J requirements and is exercised quarterly under the TST program.

Valve 547 has been recategorized A-passive, and is leak rate tested in accordance with Appendix J.

gfsh063 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing .Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM C. Reactor Coolant S stem Question:

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 Question A.6'?

R~es onse:

These valves, which are the discharge checks from RHR to the upper plenum of the reactor vessel, cannot be full or part stroked exercised open during power operation because the low pressure safety injection (RHR) pump discharge pressure is insufficient to overcome the higher reactor coolant system pressure. A full stroke exercise cannot be accomplished during cold shutdown because safety related flow cannot be achieved without a significant interruption of the normal RHR system lineup, and because. of excess cooldown considerations. A Relief Request has been generated. to replace Note 10, to allow part-stroke exercising during cold shutdowns with a full-stroke exercise being accomplished 'during cavity filling during refueling outages.

These valves had not been receiving a full-stroke exercise open as part of the IST Program and as explained in Question A.6. A, Justification for Continued Operation (JCO) has been prepared to address previous comparable stroking conducted on these valves during cavity floodingat each (annual) refueling.

gfs%063 12/07/88

~f R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM C. Reactor Coolant S stem Question:

3. Provide a detailed technical justification for not stroke timing valves 430 and 431C during cold shutdowns?

~Res onse:

These valves are stroke timed at cold shutdown. Note 16 has been re-written as a Cold Shutdown Justification.

gfsh063 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments N.

1. VALVE TESTING PROGRAM C. Reactor Coolant S stem question:

4. Provide a more detailed. technical justification for not exercising valves 515 and 516 quarterly during power operations.

~Res onse:

The safety function of valves 515 and 516 is to close to isolate a stuck open/leaky PORV. These valves are exercised. quarterly during power operation. However, when these valves are closed to isolate a PORV, it would then be considered, a system out-of-service and, exercising them would. not be required until returned to service. Note 10 is not necessary and will be deleted in the next revision of the Ginna IST program.

gfs%063 12/07/88

N A

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM

.C. Reactor Coolant S stem question':

5. Provide a detailed technical justification for not testing valves 590, 591., 592, and 593 during cold shutdowns.

R~es onse:

These solenoid-operated reactor vessel head vent valves are currently exercised at, refueling. Position indication, stroke timing and fail safe testing is not being conducted under the present IST program. A Justification for Continued. Operation (JCO) has been written to address these test deficiencies.

All Code required testing for these valves has been included in the- revised IST program. These valves will be tested during cold shutdowns, therefore a Cold Shutdown Justification has been written to document the adverse consequences of testing these valves during power operation. A test procedure is being written to enable these valves to be properly tested when next required.

. The cold shutdown testing frequency of these valves is being evaluated further in consideration of potential burping problems.

If problems are encountered, these valve will be tested. during refueling outages only, and an appropriate relief. request will be provided.

gfs%063 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM C. Reactor Coolant S stem question:

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'~es onse:

Valves 852A and B are not identified. as Event V pressure boundary isolation valves. These valves are not 'required by Plant Technical Specifications to be leak rate tested following exercising.

Although these valves were in our currently accepted Program as Category B valves, the 1988 IST Program Review position. on. these valves has changed and RG&E now feels that they should. be tested.

as reactor coolant pressure boundary valves. Valves 852A, and 852B will be changed to Category A valves in the revised. IST program, with leak rate testing conducted in accordance with. ASME Code Section XI requirements during the next ten year interval.

gfsk063 12(07/88

Ii R. H. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM C. Reactor Coolant S stem question:

7. Passive valves are those which are not required to change position to accomplish a specific function. Are valves 951 and 953 passive valves as defined by INV-2100? If not, they must be exercised in accordance with the Code requirements.

RESPONSE

Valves 951 and 953 are normally-closed, fail-close valves which are utilized during routine sampling. These valves are not considered passive as they are required to fail close on 'loss of instrument air and remain closed following CIV signal reset.

These valves are presently included in the program as Category B valves and will be exercised in accordance with ASME Section XI requirements. Note 33 will be deleted from the next revision to the Ginna IST Program.

gfsh063 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM C. Reactor Coolant S stem question:

8. Provide a more detailed technical justification for not exercising valve 959 quarterly during power operation.

RESPONSE

Valve 959 is located in the sampling line off the RHR system cold leg injection piping. This valve is normally closed. and. remains so during power operations to maintain the RHR system as a closed system. The RHR system forms the containment isolation boundary outside containment. Although valve 959 was previously used. to perform sampli;ng, this function is now'erformed via the RHR pump vents, both during operation and post-accident. This valve will remain in the IST program as a Category B-Passive valve with position indication verification conducted in accordance with ASME Section XI. Note 20 will be deleted. from the next revision to Ginna's IST Program.

gfsh063 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM D. Com onent Coolin S stem question:

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?

R~es onse:

Valve 743, a series check valve in the component cooling return from the letdown heat exchanger, does not provide any other active safety function other than containment isolation. There are currently no provisions to allow for individually verifying reverse flow closure of valve 743 during quarterly testing due to system piping configurations. This valve is tested simultaneously with check valve 743A which is considered an acceptable practice because only one valve is required to perform the safety function. A Justification for Continued. Operation has been prepared and addresses the ramification of the present test configuration. Relief will be requested in. the IST program revision to address the testing of two series check valves as a pair, when only one valve is required to perform the safety function. Additionally, a modification (EWR) has been initiated and submitted. to management for approval which will allow for individually testing valve 743 during the next 10 year interval.

gfsh076 11/21/88

.I II

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and, Comments

1. VALVE TESTING PROGRAM D. Com onent Coolin S stem question:

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 vales quarterly during power operations.

749A 749B 750A 750B 759A 759B

~Res oose:

Motor-operated valves 749A/B and 759A/B are exercised through a complete stroking cycle during cold shutdown and refueling outages. These valves cannot be full-stroke exercised during power operation because it would interrupt cooling water flow to the reactor coolant pumps, resulting in possible damage to the RCP seals. Also see response to Question A.16 regarding part-stroke exercising of power-operated valves during power operation.

Check valves 750A/B only active safety function is to perform containment isolation. These valves are leak rate tested to ensure containment. integrity and exercised during cold shutdown and. refueling outages to ensure prompt closure against reverse flow.

Note 5 will be rewritten and issued. as a Cold, Shutdown Justification (CSJ). The negative consequence of exercising these valves quarterly during power operation will be discussed in the CSJ.

gfs%076 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM D. Com onent Coolin S stem question:

3. Provide a more detailed technical justification for not exercising valves 813 and 814 quarterly during power operations (refer to Note 6).

R~es onse:

Valves 813 and 814 provide CCM inlet and outlet flow to the reactor vessel supports and cavity wall. These valves are external to containment, accessible and would only interrupt flow for a short period of time during testing. Although the time required for the test would not pose a vessel support or cavity cooling issue, a malfunction during testing would leave the valves unable to perform the containment isolation function necessary even though operations personnel could be dispatched to manually open these valves for cooling concerns. These valves will be exercised during cold shutdown, and a Cold Shutdown Justification will- be included in the revised IST program to replace Note 6.

gfsh076 11/21/88

I f

l'

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments 1., VALVE TESTING PROGRAM D. Com onent Coolin S stem question:

4. How are valves 723A and 723B verified to full-stroke open?

~Res orrse:

CCW pump discharge check Valves 723A/B are full-stroke exercised by circulating a 2500 GPM flow rate through the CCW pumps, CCW heat exchangers and RHR heat exchangers. FIT-619, located at the CCW heat exchanger discharge, is used to measure system flow rate during testing.

gfs%076 12/07/88

tl R. E. Ginna Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EGEG Questions and Comments

1. VALVE TESTING PROGRAM D. Com onent Coolin S stem question:

5. Review the safety function of valve 823 to determine if it should be included in the IST program and tested. to the Code requirements.

~Res onse:

Motor-operated valve 823 is located in the reactor makeup water discharge line to the CCW surge tank. This valve is normally closed. Opening of this valve to compensate for system leakage is not necessary based. on discussion documented in SEP topic VII.3 dated. 9/29/81. Additionally, the reactor makeup water pumps axe non-safety related and. may not be operational post accident. Since this valve does not perform a safety function need. not be included in the IST program, however Valve 823 will it be included. in the next revision to the Ginna IST program as Category B (passive) with appropriate position'ndication testing being accomplished per ASME Code Section XI.

gfsh076 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In ection S stem question:

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?

R~es onse:

The alternate testing methods considered to verify the full-stroke capabilities of valves 842A, and 842B during the current Program's ten year interval are described in a Justification for Continued, Operation. These alternatives include an accumulator discharge into the RCS or valve disassembly on a rotational sample basis during refueling outage. A Relief Request regarding these valves was submitted to the NRC with program revision 3A on June 20, 1983. A new Relief Request resulting from the 1988 IST Program Review will require disassembly of valves 842A/B and 867A/B on a rotating sample basis during refueling outages to verify their full-stroke open capability. (Also see response to Question E.2) gfs~066 11/21/88

l' R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In ection S stem QMSt1OQ:

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)?

~Res onse:

The maximum safety analysis flow identified in the Ginna UPSAR is not verified through valves 867A and B during valve testing. A Justification for Continued. Operation has been written to address this concern. Alternate test methods to verify full-stroke capability, similar to those discussed in response to question 1.E.1, have been considered. The revised IST program will require disassembly of valves 842A/B and 867A/B on a rotating sample basis during refueling outages to verify their full-stroke open capability, and relief will be requested accordingly.

gfsi066 11/21/88

I R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

3. Is the maximum safety analysis flow verified, through valves 870A, 870B, 889A, and 889B during quarterly valve testing?

If not, how exercise?

are these valves verified. to full-stroke

~Res onse:

Maximum safety analysis flow is not verified through SI pump discharge check valves 870A, 870B, 889A and 889B during quarterly valve testing. Full-stroke exercising of valves 889A and B is verified at refueling (annually) by verifying design flow (300 gpm) at flow indicators 925/924 when operating the A&B SI pumps respectively. Full stroke exercising of 870A/B can be verified by measuring the design flow at flow indicators 925/924 when operating the C SI pump with independent A/B SI discharge lineups respectively. Justifications for Continued. Operation (JCOs) have been prepared and address the concern of only part-stroke exercising these valves quarterly. These valves will be full-stroke exercised during cold shutdowns, and a cold shutdown justification will be provided accordingly. Test procedures will.

be revised as necessary to verify full-flow capability through valves 870A and 870B individually.

gfs/066 12/07/88

V R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGEG Questions and Comments g4

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

4. Note 11 identifies valves 877A, 877B, 878F, and 878K 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?

~Res onse:

Valves 877A/B and 878F/H are no longer required to actively operate to establish post-accident hot leg injection flow at Ginna, therefore the only safety function of these valves is for pressure boundary isolation. These valves are leak rate tested together in series, since these valves together provide only one of the two isolation boundaries required to be leak rate tested per plant Technical Specifications. A Justification for Continued Operation has been prepared, and provides a detailed discussion on these valves. The revised IST program will identify these valves as Category A/C, with leak rate testing performed per Technical Specifications.

gfs~066 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

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?

~Res onse:

Valves 878G and J are leak rate tested following each safety injection flow test per Technical Specification 4.3.3.2. Safety injection flow tests are performed on a monthly basis.

Leak rate tests performed on these valves to verify their ability to perform a pressure boundary isolation function are done in accordance with Plant Technical Specifications. These valves will be full-stroke exercised during cold shutdowns. A cold.

shutdown justification will be provided accordingly.

gfsk066 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

6. Review whether note 24 is applicable to valves 871A and

'871B. A reduction in redundancy is not sufficient justific'ation for not performing. the Code required testing.

Ries onse:

MOVs 871A and B are normally open valves in the discharge path of SI pump 1C. These valves remain open if all three SI pumps start or selectively close to direct SI pump 1C flow to the path of the failed pump. These valves are tested quarterly during power operation. Note 24 is not applicable and will therefore be deleted from the IST program.

gfs~066 12107/88

~ I 1

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

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 supplied from the refueling water storage tank, and therefore, Note 9 does not apply.

~Res onse:

Although Note 9 applies to certain valves in the IST Program, does not apply to these valves. Presently, valve 825A is it exercised monthly, valve 825B does not receive exercising during power operation, and. neither valve is stroke timed except during cold shutdown and refueling outages. A Justification for Continued Operation has been prepared to address the previous insufficient testing of these valves. Procedural changes are being initiated to exercise and. stroke time both valves at least quarterly to meet ASME Section XI requirements, and these testing requirements will be included in the revised IST program.

P gfs~066 12/07/88

t l

(

I

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

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.

R~es onse:

NOVs 826A-D provide redundant flow paths from the Boric Acid, Tanks to the SI pump suction header. Each path is provided with a normally open and, normally closed valve in series. These valves are tested quarterly during power operation, unless the system is out of service or the flow path is inoperable per Technical Specifications. Note 25 will be deleted from the IST program.

gfs~066 12/07/88

.R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGRG Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

9. Review whether Note 24 is applicable to valves 1815A and 1815B.

~Res onse:

MOVs 1815 A and B are series valves in the suction line to SI pump C. Should either of these valves fail during testing then SI pump 1C would become inoperable. Such a condition is allowable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> by 'entry into a technical specification action statement with SI pumps A and B both being operable. These valves are presently tested quarterly during power operation. Therefore, Note 24 is not applicable to these valves and. will be deleted from the IST Program.

gfsh066 12/07/88

1>>

4

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

10. Branch Technical Position RSB 5-1 establishes requirements for taking reactor plants from power operation 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 834B 8603A 8603B 8606A 8606B 8616A 8616B 8619A 8619B 8630A 8630B 841

RESPONSE

Ginna is not currently required. to comply with BTP RSB-5-1.

Therefore, Valves 834A/B (accumulator vent path), 841 and 865 (cold leg injection) are not required to be included in the IST program. During cold shutdown, manual actuation can be achieved.

These valves are stroked during cold shutdowns. The 1988 IST program review is evaluating these valves for possible inclusion in the revised IST program as asterisk items.

The 8600 series valves listed above are associated with the RCS ovexpressurization protection system and are not a means of venting the SI accumulators. Valves 8603A and 8603B are in non-Code piping and do not perform a safety function, therefore need not be included in the IST program. Valves 8606A/B, 8616A/B, 8619A/B, and 8630A/B will be included in the revised. IST program and. tested to the Code requirements unless specific relief is requested.

gfs~066 12/07/88

h R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM E. Safet In ection S stem question:

11. Review the safety function of 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. it If 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)?

~Res onse:

Valves 891A, B and C perform a safety function in the open position to protect the SI pumps by recirculating flow to the EST when the SI pumps start with the normal flow path blocked.

Under the current configuration, these valves do not perform a safety function in the closed position based. on the minimal (30 gpm) diverted. flow allowed by orifices in the recirculation flow path. These valves will be included in the revised IST program as Category C and tested to the applicable ASME Section XI requirements unless specific relief is requested. A Justification for Continued Operation is being written to address the ramifications of their omission from the current program. A modification has been proposed that will increase the recirculation flow path capacity to approximately 100 gpm, and.

will include the necessary equipment, to test these valves both full-stroke open and closed. Alternate test methods to verify the full-stroke open capability of these valves are being evaluated for use if the modification is not done. Procedure changes will be initiated as necessary to perform the required testing.

gfsh066 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM E. Safet In'ection S stem question:

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?

RESPONSE

Relief valves 830A and B provide overpressure protection for the SI accumulators. These valves will be included in a program upgrade as part of the next ten year submittal and tested in accordance with ASME Section ZI requirements.

gfsh066 11/21/88

J I

(1

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM P. Containment- S ra S stem Question:

l Is the maximum safety analysis flow verified through valves 862A and 862B during quarterly valve testing?

full-stroke If not, how are these valves verified to exercise (refer to comment A.6 of this document)?

~Res onse:

Valves 862A and. B had been receiving only part-stroke testing (38 GPM) on a quarterly basis prior to May 1988, therefore a Justification for Continued Operation has been prepared accordingly. These valves were demonstrated to full-stroke on May 20th, 1988 using an external mechanical exerciser and measuring the force applied, consistent with the guidance of ANSI/ASME OM-10. Procedural changes have been initiated to incorporate this form of testing on a quarterly basis,. A Relief Request will be included in the revised IST program to address using the guidance of OM-10 in lieu of DW-3522b for establishing the acceptance criteria when testing check valves with an external mechanical exerciser.

(Also see response to Question 1.A.1) gfsh077 12/07/88

I*

t

R. E. Ginna Nuclear Power Plant, Pump and. Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM F. Containment S ra S stem question:

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 operations 1819A 1819B 1819C 1819D 1819E 1819F 1819G

~Res onse:

Manual valves 1819A-G are normally open containment pressure transmitter isolation valves, which are closed only when the associated. transmitter is out-of-service for maintenance.

Exercising these valves during power operation defeats their containment pressure monitoring function and causes a loss of 2 of 4 actuation signals which may result in a failure to trip when necessary. Note 21 will he rewritten as a Cold Shutdown Justification to document the negative consequences of at power testing.

gfs/077 11/21/88

II R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM P. Containment S ra S stem guestion:

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.

~Res onse:

MOVs 860 A and. B are in the discharge path from containment spray pump A; MOVs 860 C and D are in the discharge path from pump B.

These valves are tested quarterly as required. Note 24 will be deleted from the next revision to the Ginna IST program.

gfs%077 11/21/88

jt K

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGEG Questions and. Comments

1. VALVE TESTING PROGRAM F. Containment S ra S stem'uestion:

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.

R~es onse:

Valves 897 and 898 are the safety injection recirc and test line return valves. Exercising these valves during normal operation is impractical as these valves are blocked open. Failure of one of these valves in the closed position during normal operation could cause a failure of all Safety Injection pumps by'solating the miniflow recirculation path for all pumps. These valves will be exercised during cold shutdowns. Note 27 is being rewritten as a Cold Shutdown Justification.

gfsh077 11/21/88

I

<<C

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGRG Questions and Comments

1. VALVE TESTING PROGRAM F. Containment S ra S stem question:

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?

R~es onse:

Valves 866A/B are required to open to supply suppression for charcoal filter dousing.

Valve 866A is not tested quarterly during power operation solely due to ALARA concerns. Both valves (866A/B) are exercised. open using air.

Based on the system selection criteria created during the 1988 IST Program review, these valves are not necessary to perform a shutdown or accident mitigating function. Therefore, valves 866A/B and Note 12 will be deleted from the next revision to the IST Program.

e

\

gfsh077;l 12/07/88

I 0

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM F. Containment S ra S stem question:

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.

R~es onse:

These vacuum breakers are overpressure protection devices therefore not included under the current program. They will be included as a program upgrade for the next ten year interval, and tested in accordance with IWV-3510.

gfs~077 11/21/88

I R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM G. Service Water S stem question:

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 Question A.6?

~Res onse:

Service water pump discharge check valves 4601-4604 were incorrectly categorized A in the current IST program to ensure proper back seating when the parallel pump is running. Specific seat leakage limits have currently not been set for these valves in the closed position. These valves will be recategorized as C valves in the revised IST Program and Note 31 will be deleted.

Check valves 4601-4604 do not receive full-stroke exercising as explained in Question A.6. Since flow indication is not available at the discharge of the service water pumps, flow measurements are taken at the discharge of the Containment fan coolers. A Justification for Continued Operation has been written and discusses the ramifications of the existing test configuration. The revised IST program will require disassembly of these valves on a rotating sample basis during refueling outages to verify their full-stroke open capability, and relief will be requested accordingly. This disassembly inspection program will commence during the next refueling outage.

Other alternative test methods for verifying full-stroke exercising are presently being pursued as part of the 1988 IST program review. These include the possible installation of flow indication at the pump discharge and/or the modeling of various SW system lineups to determine pump discharge flow.

gfs%078 11/21/88

(t H

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM G. Service Water S stem Question:

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 valves 4561, 4562, and 4733.

I

~Res onse:

Valves 4561 and 4562, and 4733 are air operated butterfly valves and will therefore remain in the IST program as Category B valves. PAID 33013-1250 will. be revised to correctly identify these valves.

gfs~078 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM G. Service Water S stem question:

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?

~Res onse:

The proper identification for reactor compartment cooler "A" outlet isolation valve is 4758; the P&ID will be corrected.

gfsh078 11/21/88

II 4

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM H. Control Room Ventilation Question:

1. Are ventilation control valves 081 through 086 tested to all the Section XI requirements (i.e., stroke timed, fail-safe tested, etc.)?

R~es onse:

These are non safety-related air operated dampers which are actuated using non-safety-related air. The Control Room ventilation system does not fall within the scope of ASME Section XI. Testing to ensure operability of this system is and will continue to be delineated by Plant Technical Specifications.

These dampers need not be included in the IST program and will therefore be deleted.

II s gfsh079 11/21/88

I" l~

R. E. Ginna Nuclear Power Plant Pump "and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM H. Control Room Ventilation question:

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 P&ID No. 33013-1920 for our review.

~Res onse:

The chilled water supply to the Contxol Room ventilation system does not perform a safety function, therefore its associated pumps and valves do not fall within the scope of ASME Section XI.

Testing to ensure operability of the CRHVAC system is specifically delineated in Plant Technical Specifications.

Valve 5850 will not be included into the Ginna IST program.

gfsh079 11/21/88

R. E. Ginna Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EGGG Questions and Comments 1 VALVE TESTING PROGRAM I. Containment Ventilation Question:

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.

~Res onse:

Valves 5869 and. 5879 are containment. (outside) purge supply and exhaust valves. They are presently listed as containment isolation valves in table 3.6-1 of Plant Technical Specifications however flanges located inside containment are provided with double seals and perform the containment isolation function for all modes of operation between cold shutdown and normal operation. These flanges are only removed during refueling outages with integri'ty, at this time, provided by valves 5869 and 5879. Therefore, these valves are normally considered out-of-service and. must be operable only when the flanges are removed. and their closure is required for refueling integrity, at which time leakage is not a concern. Valves 5869 and 5879 will be added. to the IST program as Category 8 valves, which will be exercised prior to placing them in service and quarterly while in service.

gfs~080 12/07/88

I i R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM I. Containment Ventilation question:

2. Review the categorization of valves 7445 and 7478 to determine comment if they should be category A/C valves (refer A.17 of this document).

to R~es onse:

Valves 7445 and 7478 are air-operated butterfly valves and will remain category A in the Ginna IST Program. Since these valves are not check valves, category C test requirements are not applicable.

gfs~080

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM I. Containment Ventilation question:

function of the following manual valves to

3. Review the determine containment ifsafety they should be included in the IST program as isolation valves and tested to the Code reguirements.-

I 1555 1558 1567 1570 1573 R~es onse:

The above mentioned valves are post-accident sample line vents that are normally closed and capped during power operation.

These valves are utilized only during leak rate testing of the secondary isolation valves. These valves are not required to he in the IST Program.

gfsh080 12/07/88

ih R. E. Ginna Nuclear Power Plant Pump and Valve T.nservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTlNG PROGRAM J. Diesel Generator S stem Question:

1. Review the safety function of the following diesel generator air start system valves to determine included in the IST program and tested iftotheythe should Code be requirements (refer to comment A.14 of this document).

5933A 5933B 5934A 5934B 5941A 5942A 5943A 5944A 5948A 5948B 5948C 5948D R~es ense: ~

With the exception of valves 5948A and. 5948D, all air start system valves mentioned above will be tested to ensure

~

operability.

Valve 5948A is a locked open manual. valve which falls under the category of passive and. will not be tested. Valve 5948D does not exist within the air'start system.

All appropriate diesel generator air start system valves have been added to the XST program, and will be tested. in accordance with the Code unless specific relief is requested..

gfsh064 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. 'ALVE TESTING PROGRAM J. Diesel Generator S stem question:

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.14 of this document).

5907 5908 5955 5956 5959 5960 5961 5962 R~es onse:

All appropriate diesel generator fuel oil transfer system valves, including those mentioned above, have been added to the IST program and will be tested in accordance with the Code unless specific relief is requested.

gfsi064 11/21/88

R. E. Ginna Nuclear Power Plant Pump and, Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM K. Auxiliar Feedwater question:

1. Is the maximum safety analysis flow verified. through the following valves during testings If not, how are these valves verified to full-stroke exercise (refer to comment A.6 of this document)?

3998 4000C 4000D 4003 4004 4009 4010 4014 4016 4017

~Res ense:

The AFN System is required to pass 200 gpm of feedwater to each Steam Generator during shutdown and post accident conditions.

The monthly auxiliary feedwater. system test utilizes this flow rate when individually testing the motor-driven and turbine-driven AFW pumps and flow paths. The test, flow-rate is verified via various in-line pressure and flow indicators and satisfies ASME Code Section XI full-stroke exercising requirements.

gfsh067 12/07/88

i, R. E. Ginna Nuclear Power Plant Pump and Valve Inservice. Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM

/

K. Auxiliar Feedwater question:

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 vales 3996, 4007, and 4008.

How are. these valves full-stroke exercised open?

~Res onse:

Valves 3996, 4007 and 4008 are presently listed as Category B valves in the Ginna IST program. These valves contain a motor operator but, are designed. to function like simple check valves.

The motor operator allows the valve disc to be forced closed., as necessary, to perform a flow regulating function. These valves will be recategorized as B/C in the new program plan.

Full-stroke exercising of these valves is accomplished during the monthly AFW system testing by passing full flow (200 gpm) through each AFW flow path as governed by Plant Technical Specifications.

gf sh067 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM K. Auxiliar Feedwater question:

3. How is valve 4023 verified to full-stroke exercise open during quarterly testing (refer to comment A.6 of this document)?

RESPONSE

Check valve 4023 is verified to exercise open by throttling the discharge flow to the point that opens the recirculation line isolation valve. Engineering is presently validating the minimum flow recirculation acceptance criteria for this testing.

gfsh067 11/21/88

fl I A

R. E. Ginna. Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM K. Auxiliar Feedwater question:

4. Is credit taken for the service water supply flow path to the auxiliary feedwater syst: em? 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.

~Res onse:

Credit is taken for the service water system providing an alternate flow path to the auxiliary feedwater system. This path would be utilized. in the event that the path from the condensate system was interrupted or if the Condensate Storage Tank was depleted. Manual valves 4098, 4344 and 4345 are presently locked closed during normal plant operation, and. must be opened. during post-accident shutdown prior to depletion of the CST. These valves are presently exercised during monthly AFH system testing.

A Justification for Continued, Operation has been issued to address the omission of these valves from the current IST program.

Engineering is conducting a further evaluation of the APN system requirements related to these valves. These valves will either be included in the revised IST Program (next ten year interval) as Category B valves, or changed to locked open valves and the upstream motor-operated valves 4013, 4028, and 4027 included in the revised IST Program as Category B valves.

gfsh067 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM K. Auxiliar Feedwater question:

Review the safety function of solenoid operated. valves 4324,

. 4325,'nd the" 4326 to determine if they should be included in IST program as category B valves and tested to the Code requirements.

~Res onse:

Valves 4324, 4325 and 4326 are normally closed, and open to provide an alternate cooling path to the AFW pumps and lube oil coolers. These valves would be required to operate and supply cooling water to the pumps and coolers should the main. path become blocked. These valves are stroke-tested during the associated monthly auxiliary feedwater pump testing. These valves will be added to the next revision of the IST Program as Category B valves, and tested to the Code requirements unless specific relief is requested.

gfsh067 11/21/88

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R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM L. Feedwater S stem question:

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.

R~es onse:

Check valves 3992 and 3993 are normally open active valves which are required to close following a reactor trip. Failure to close may prevent sufficient auxiliary feedwater from reaching the steam generators. These valves have been added to the IST program as Category C valves. Reverse flow closure will be verified during performance of the steam generator secondary hydrostatic tests each refueling outage, and a Relief Request will be provided accordingly. A Justification for Continued Operation (JCO) has been written to address the ramifications of the lack of previous testing on these valves.

gfsh065 12/07/88

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R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGKG Questions and. Comments

1. VALVE TESTING PROGRAM M. Standb Auxiliar Feedwater S stem question:

1. Is the maximum safety analysis flow verified through the following valves during testing? If not, how are these valves verified to full-stroke'xercise (refer to comment A.6 of this document)?

9627A 9627B 9700A 9700B 9705A 9705B R~es onse:

Check Valves 9700 A/B and 9705 A/B are full-stroke exercised during monthly SAPW system testing by passing the required. post accident flow of 200 GPM through each train to each steam generator.

Check Valves 9627 A and B (SW to SAPW pump suction) have been receiving only part-stroke testing, however, recent disassembly indicated the valves were functioning properly. A Justification for Continued Operation has been prepared for these valves, and a Relief Request prepared as a result of the 1988 IST Program Review addresses alternate testing (disassembly) on a refueling (annual) basis to verify the full-stroke open capability of these valves.

gfs%068 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM M. Standb Auxiliar Feedwater S stem question:

2. Valves that can'e 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 and 9704B. How are these valves full-stroke exercised open'P R~es ense:

Valves 9704A and B are presently listed as category B valves in the Ginna IST program. These valves contain a motor operator but are designed to function like simple check valves. The motor operator allows the valve disc to be forced closed as necessary to perform a flow regulating function. These valves will be recategorized as B/C in the new program plan, and tested accordingly.

Full-stroke exercising of these valves is accomplished by passing full flow (200 gpm) through each SAFW flow path as designated by Plant Technical, Specifications.

gfsh068 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and, Comments

1. VALVE TESTING PROGRAM M. Standb Auxiliar Feedwater S stem Question:

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.

~Res onse:

Valves 9708A/B and. 9721A/B are located. in the condensate supply tank (CST) and condensate pump discharge lines respectively.

Valves 9708A/B are required to open when using the CST as a source of feedwater for the SAFW pumps. However, this source of feedwater is only used during monthly testing of the SAFW system and not relied on for use during shutdown or accident conditions.

This flowpath has normally closed. manual valves upstream to prevent service water supply from being diverted. away from the SAFW pump suction. Since these valve do not perform a safety function, they axe not required. to be included. in the IST Program.

Valve 9721A/B are required. to open to maintain the SAFW suction line full prior to operation. These valves are required to close to maintain service water flow to the SAFW pumps. Therefore, valves 9721A/B will be included. in the IST program as category C valves and tested. to the appropriate ASME Section ZI requirements. Procedure. changes are being initiated to address these testing requirements.

gfsh068 12/07/88

R. E. Ginna Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM N. Fire Water S stem question:

1. What is the safety function of valves 5133 and 5136? How are these valves verified. to full-stroke exercise open during testing?

R~es onse:

valves 5133 and 5136 are located at the discharge of the I,

Check diesel and motor-driven fire pumps, respectively. Each valve is required to open upon pump initiation to allow flow to the various fire suppression systems throughout the plant.. Currently these valves are exercised (>2000 gpm) to the open position on a monthly basis as required by Plant Technical Specifications.

Valves 5133 and 5136 will be removed from the IST program (next ten year interval) as these valves are not within the scope of ASME Section XI or the 1988 IST Program Review System Selection Criteria.

~

~

gfsh081 12/07/88

R. E. Ginna Nuclear Power Plant.

Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM

0. Main Steam S stem gue'stion:

1. Provide a. detailed technical justification for not exercising valves 3516 and 3517 during cold shutdowns. -Can these valves be part-stroke exercised?

R~es ense:

Valves 3516 and, 3517 are the MSIVs. These valves cannot be stroked (full or part) during power operation as this would cause a turbine trip and subsequent plant shutdown. These valves are presently being stroked at refueling outages. However, these valve can be exercised. at cold shutdown and. appropriate procedure changes are being made to. perform testing at this frequency. A Cold Shutdown Justification (CSJ) has been prepared and will discuss the negative consequences of at power testing. This CSJ will replace existing Note 14 in Appendix C in the QA Manual.

gfsh082 11/21/88

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R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM

0. Main Steam S stem guestion:

2. Review the safety function of check valves 3504B and 3505B in the steam supply lines to the turbine driven auxiliary feedwater pump to determine 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?

R~es onse:

Valves 3504B and 3505B are required to open when the TAFW system is used during shutdown and post accident conditions.

Additionally, each valve is required to close on reverse flow when the opposite line's steam is used to supply the APW pump turbine. These valves are presently full-stroke exercised open with flow during the monthly TDAFP testing. Steam flow testing through these valves is conducted individually such that the forward flow of one and back flow seating of the opposite line check valve is verified. Reverse flow closure is verified by observing the position of the external operator arm on the valve. Valves 3504B and 3505B have been added, to the Ginna IST Program as Category C valves. Procedure changes have been made where necessary to address additional testing requirements and methods. A Justification for Continued, Operation has been prepared to address the ramifications of the omission of- these valves from the IST program and their previously insufficient testing.

gfsh082 12/07/88

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R. E. Ginna. Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING, PROGRAM'.

Main Steam S stem guestion:

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?

~Res ense:

Valves 3410 and. 3411. are required, to operate during post-accident and shutdown conditions to dump steam to cooldown the plant.

These valves will be added to the Ginna. IST program as Category B valves and tested in accordance with. ASME Section XI.

These valves are presently stroked during refueling outages. The procedure will he revised to accomplish the necessary valve testing at cold shutdown. A Cold Shutdown Justification has been written to discuss the negative consequences of at power testing.

A Justification for Continued Operation has been written to address the omission of these valves from the IST program.

gfs%082 12/07/88

Cl R. E. Ginna Nuclear Power'Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and. Comments

1. VALVE TESTING PROGRAM

0. Main Steam S stem question:

4. 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.

~Res onse:

Main steam stop checks 3518 and 3519 are required to close following an upstream steam line break. This function protects against reverse flow from the good, steam generator to the area of the break. These valves will be added to the IST program as Category C valves and tested to the appropriate Code requirements. A Cold Shutdown Justification has been written and addresses the negative consequences of at. power testing. A procedure will be developed to perform the necessary testing.

gfsh082 12/07/88

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R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

1. Provide a more detailed technical justification for not testing valves 624 and 625 quarterly during power operation.

R~es onse:

Valves 624 and 625 are the RHR heat exchanger outlet temperature control valves. A review of the Technical Specifications and.

flow diagrams has determined that testing these valves during power. operation would not degrade the low pressure safety injection function as presently stated in note 26 of Appendix C.

However, these valves are normally open, fail open, and are required only for reactor coolant temperature control during shutdown cooling operations. Their open position is verified each operating shift. These valves would. be considered Category B Passive, but they are further exempt from testing per IWV-1200. These valves will be deleted from the next revision to the IST Program.

gfs%083 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

2. Provide a more detailed technical justification for not exercising valves 701 and 720 quarterly during power operation.

R~es ense:

Valves 701 and 720 form one of the two pressure boundaries separating the RCS (2501I) and the RHR system (6011). Testing of these valves during power operation, would leave only one valve protection at this high/low pressure boundary. Additionally, as stated in Note 8 of Appendix C, an interlock system prevents th'ese valves from opening when'he RCS is at operating pressure.

,This note will be rewritten as a Cold Shutdown Justification with the negative consequences 'of testing at power specifically stated.

Oi gfs%083 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

3. 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 exercisecP.

~Res onse:

Valves 700, 701, 720 and 721 are not considered Event. V pressure boundary isolation valves at Ginna nor do Technical Specifications required them to be leak rate tested after exercising. Therefore, these valves are listed as category B valves in the current Ginna IST program. (Also see response to Question A.10)

The safety functions and testing requirements for these valves have been reassessed during the 1988 IST Program Review. The revised IST Program (next ten year interval) will identify valves 700, 701, 720, and 721 as Category A valves.

gfsh083 12/07/88

IS R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments III 1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

4. Do valves 850A and. 850B perform a containment isolation function'?

tested.

If so, they should. be categorized. A and leak rate R~es onse:

Valves 850A and B are listed as containment isolation valves in s Plant Technical Specification Table 3.6-1. These valves are

,located in the containment sump discharge lines to the RHR pumps and are open following an accident. Based on this post accident function these valves are not providing containment isolation.

Therefore, valves 850A/B are not required to be leak rate tested and will remain as Category B valves in the Ginna IST Program.

gfs%083 11/21/88

R. E. Ginna Nuclear'Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

" 1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

5. Do valves 851A and 851B ever have to change position to perform any safety function? If not, they should he categorized B passive.

R~es onse:

Valves 851A and, B (containment sump to RHR pumps) are locked open in their required safety function position with power removed.

These valve are listed as containment isolation valves however, they are not required to operate during LOCA conditions and do not provide containment isolation. (see response to Question Pe4) These valves are and will remain Category B (passive) in Ginna's IST Program.

gfs%083 11/21/88

R. E. Ginna Nuclear Power Plant.

Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING'ROGRAM P. Residual Heat Removal S stem question:

6. Provide a more detailed technical justification for not testing valves 857A, 857B, and 857C quarterly during power f l.. 1 exercising valves 857B and 857C degrade the injection phase of the residual heat removal pumps?

R~es onse:

Valves 857A and B are the residual heat removal pump discharge to safety injection pump suction cross connect valves. These valves are required for high head recirculate'on. Should one of these valves fail open during testing, one loop of low pressure safety injection would be inoperable since discharge flow would recirculate back to the refueling water storage tank. However, the redundant RHR train is still operable, and in accordance with the plant technical specifications, one train of the RHR system may be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Therefore 857A G B can and will be exercised. quarterly during power operations. Note 27 will be deleted from the revised IST program.

Valve 857C is an administratively controlled valve that is locked open with its power removed. This passive valve is not required to be tested per the Code therefore included in the IST program.

it need not be gfsh083 11/21/88

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R. E. Ginna Nuclear Power Plant Pump and, Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

7. Is the maximum safety analysis flow verified through, valves 710A, and 710B during valve testing? If not, how is this valve verified to full-stroke exercise (refer to comment A.6 of this document)?

Ries onse:

RHR pump discharge check valves 710 A/B. cannot be full-stroke exercised. during power operation since the downstream valves cannot op'n against RCS pressure. Current procedures provide partial flow (approx. 200 gpm) testing (monthly) of valves 710A and B. These valves also cannot be, full-stroke exercised during cold shutdowns because of excess RCS cooldown considerations.

These valves are therefore partial-flow (approx. 700 gpm) exercised. during cold shutdowns. The ramifications of this part-stroke testing're discussed in a Justification for Continued, Operation. Pull-stroke (1560 gpm) testing of these valves can only be accomplished on a refueling basis. Appropriate relief is being requested. in the IST program resubmittal, and procedure changes initiated. as necessary.

gfsh083 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGEG Questions and Comments

1. VALVE TESTING.PROGRAM P. 'esidual Heat Removal S stem question:

8. Is the maximum safety analysis f3-.ow verified through valve 854 during valve testing? If not, how is this valve ver'ified to full-stroke exercise (refer to comment Ae6 of.

this document)?

R~es onse:

Valve 854 can only be partial-stroke exercised during power operations and cold shutdowns. Valve 854 presently receives a partial flow (approx. 200 gpm) test on a monthly basis. The ramifications of this. part-stroke testing are, discussed in a Justification for Continued Operation. This valve can only be full-stroke tested during cavity filling at refueling outages.

Appropriate relief is being requested in. the IST program resubmittal, and procedural changes initiated. as necessary.

gfsh083 12/07188

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

9. Review the safety function of valves 1813A, 1813B, and 822A to determine if they should be included in the IST program as category A valves and tested to the Code Requirements.

~Res onse:

Valves 1813A & 1813B are motor-operated gate valves from containment sump B to the reactor coolant drain tank pumps which are blocked closed boundary valves between a safety-class 2 system and a non-class systems. Valves 822A is a normally closed manual globe valve which is the boundary valve between a high pressure (600 psi) and low pressure (150 psi) safety class systems.

These normally-closed valves all perform a containment isolation function for RHR as a closed,-loop system outside containment, and, are not required. to open to perform any safety function. Valves 1813A/B will be included in the IST Program as Category A valves, and. leak tested per Appendix J requirements. Valve 822A will be included in the revised, IST program as Category A Passive, and relief will be requested. from Code leak testing requirements because this valve is tested to closed, system requirements as part of a system hydrotest per SEP Topic VI-4. Appendix J testing of valve 822A is not required because the. system is always water filled when containment isolation is required.

gfsk083 12/07/88

M R. E. Ginna Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM P. Residual Heat Removal S stem question:

10. Review the safety function of valves 1812A and 1812B to determine category C ifvalves they should be included in the IST program and tested to the Code requirements.

as

~Res onse:

These valves are presently shown as a class break on P&ID 33013-1247. The upstream manual isolation valves 1811A and 1811B are normally closed. Engineering has reviewed the material in this short run of piping and. determined that the manual valves can become the class break. The drawings will be revised accordingly-. and valves 1811A &, B will be included in the revised IST program, therefore valves 1812 A & B need not be included in the IST program.

gfsh083, 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

1. VALVE TESTING PROGRAM Q. Additional Valve uestions question:

1. Provide a more technical justification for not exercising valve 5392 and 5393 quarterly or during cold. shutdown (refer to Note 19). Identify the specific equipment that will lose instrument air if these valves are exercised, and the consequences of loss of air to these valves.

Ries onse:

Valves 5392 and, 5393 provide containment isolation for the instrument air line. Stroking these valves would interrupt instrument air supply to containment, which would, cause all air-operated valves in containment to actuate to their fail-safe position. During power operations this would result in a subsequent reactor trip. During cold shutdowns this would.

compromise plant operations due to the loss of various components necessary to maintaining the reactor in a cold shutdown condition. Valve 5392 will be full-stroke exercised during refueling outages. Due to the valve and system design, closure of check valve 5393 can only be verified. during valve leakage testing, therefore verification of valve closure will be done in conjunction with the Appendix J Type C leak tests. Note 19 will be replaced. with appropriate relief requests in the revised IST progl Bm ~

The following list identifies the valves in containment which would lose instrument air if 5392/5293 are exercised, and the consequences of such a loss of air to these valves:

gfsi115 12/07/88

l, Valve No. Descri tion Conse ences at Power HCV-123 Excess Letdown Control Valve FC, No affect CV-133 RHR Letdown FC, No affect OV-200A Letdown Orifice Isolation, 40 GPM FC, Normally closed AOV-200B Letdown Orifice Isolation, 40 GPM FC, Lose letdown AOV-202 Letdown Orifice Isolation, 60 GPM FC, No affect AOV-427 Letdown from Suction line Loop B FO, Lose letdown AOV-270A 'A'CP 51 Seal Leakoff FO, No affect AOV-270B 'B'CP 51 Seal Leakoff FO, No affect AOV-386 A&B RCP g1 Seal Leakoff Bypass FC, No affect AOV-294 Charging to B Cold Leg FC, Lose charging AOV-296 Auxiliary Spray FC, No affect AOV-310 Excess Letdown from Loop A FC, No affect AOV-312 Excess Letdown Divert Valve No affect AOV-392A Charging to 'B'oop Hot FC, Acts as a Relief Valve, can charge AOV-392B Charging to 'A'oop Cold FC, Isolated-No affect AOV-430 PRZR PORV FC, Lose RCS relief capability AOV-431A PRZR Spray. Loop A FC, Lose spray AOV-431B PRZR Spray Loop A FC, Lose spray AOV-431C PRZR PORV FC, Lose RCS relief capability WOV-521 RV flange Leakoff FO, No affect V-526 PRT drain FC, No affect OV-527 PRT to Vent Header FC, No affect AOV-548 RMW to PRT No affect AOV-550A RMW to 'A'CP No affect AOV-550B RMW to 'B'CP No affect AOV-754A CCW from 'A'CP thermal barrier FO, No affect AOV-754B CCW from 'B'CP thermal barrier FO, No affect AOV-834A N~ Loop B SI Accum. FC, No affect.

AOV-834B N~ Loop A SI Accum. No affect AOV-835A AOV-835B SI SI filltoto SISI Accum.

fill Accum'.

FC, FC, FC, No affect No affect AOV-839A SI Accum. Test Line FC, No affect AOV-839B SI Accum. Test Line FC, No affect AOV-840A SI Accum. Test Line FC, No affect AOV-840B SI Accum. Test Line FC, No affect AOV-844A SI Accum. to RCDT FC, No affect AOV-844B SI Accum. to RCDT FC, No affect AOV-945 HCV, SI Accum. Vent FC, No affect AOV-951 PRZR Steam Space Sample. FC, No affect AOV-953 PRZR Liquid Space Sample FC, No affect AOV-955 B Loop Sample FC, No affect AOV-1090 'A'NMT Recirc Fan Moisture Dump FC, No affect AOV-1091 'B'NMT Recirc Fan Moisture Dump FC, No affect AOV-1092 'C'NMT Recirc Fan Moisture Dump FC, No affect OV-1093 'D'NMT Recirc Fan Moisture Dump FC, No affect

.OV-7478 Mini Purge Supply Valve (Inside) FC, No affect AOV-7970 CNMT Mini Purge Exhaust (Inside) FC, No affect

t Valve No. Conse uences at Power AOV-8603A AOV-8603B

. Accum. V-801A N~

Accum. V-801B N fill, fill FC, No affect FC, No affect OV-10,024 PASS CNMT Sump 'A'ample Pump FC, No affect Other E i ment Affected b Loss of Instrument Air:

'A'ost

'A'ost Accident Charcoal Filter Inlet Damper Accident Charcoal Filter Outlet Damper

'A'NMT Recirc Fan Damper

'C'ost Accident Charcoal Filter Outlet Damper

'C'NMT Recirc Fan Damper

'C'ost Accident Charcoal Filter Inlet Damper.

'D'NMT Recirc Fan Damper

'B" CNMT Recirc Fan Damper Reactor Compartment Cooling Fan Dampers Control Rod Drive Cooling Fan Dampers CNMT Auxiliary Filter System Dampers Refueling Crane Control Cabinet CRDM Area Educator Penetration Penetration Pressurization System fsh115 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGEG Questions and Comments

2. PUMP TESTING PROGRAM question:

1. What safety related. cooling is provided to the spent fuel pool?'oes 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 ZI requirements.

n

'H R~es onse:

Cooling is provided to the spent fuel pool via the Spent Fuel Pool Cooling (SFPC) system. Although the SFPC system is not designated as a safety related system because it is not needed to safely shutdown the plant nor to mitigate the consequences of an accident, RG&E considers this system important to safety during refueling and full core offload situations. Therefore, this system (SFPC pumps and. applicable valves) will be included in the IST program, and tested as necessary to ensure cooling to the spent fuel pool.

gfsh084 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments,

2. PUMP TESTING PROGRAM question:

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.14 of this document).

R~es onse:

The diesel fuel oil transfer pumps have been tested to ensure their operability, even though they were not included in the IST program. They have been included in the revised Ginna IST program, and will be tested to the Code requirements unless specific relief is requested.

gfsh084 11/21/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

2. PUMP TESTING PROGRAM question:

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 measurements taken?

Component cooling water pumps Safety injection pumps Containment. spray pumps Service water pumps Residual heat removal pumps

~Res onse:

Component cooling water pump inlet pressure is measured using a local pressure gauge.

The inlet pressure for the Safety Injection, Containment Spray and Residual Heat Removal pumps is calculated using the 9- RWST level at the time of testing and converting it to PSIG.

Service water pump inlet pressure is calculated by using the screenhouse level indicator LI-3006 reading at the time of testing and the net pump suction head of the service water pumps and converting it to PSIG.

gfs~084 12/07/88

)l II 1

R. E. Ginna Nuclear Power Plant Pump and>> Valve Inservice Testing Program Response to EGGG Questions and. Comments

2. PUMP TESTING PROGRAM question:

4. What flow paths are used for the monthly testing of the auxiliary feedwater pumps and the standby auxiliary feedwater pumps?

R~es onse:

The Auxiliary Feedwater Pumps (motor and turbine-driven) are tested. using a flowpath from the condensate storage tank to the steam generators.

The Standby Auxiliary Feedwater Pumps are tested using the flow path from the condensate supply tank to the steam generators.

gfsi084 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Xnservice Testing Program Response to EGKG Questions and Comments

2. PUMP TESTING PROGRAM question:

5. How are the service water pump flow rates measured. during monthly pump testing?

~Res onse:

Service water pump flow rates are measured via local flow indicators at the discharge side of the containment fan coolers.

(See response to Question 1.G.1).

(There is no Question 6) gfsi084 12/07/88

R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EG&G Questions and Comments

2. PUMP TESTING PROGRAM question:

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 ZI requirements.

R~es ense:

The boric acid transfer pumps circulate boric acid solution through the boric acid tanks and inject boric acid into the charging pump suction header. However, credit is not taken for this method of boration in plant safety analyses. Therefore, these pumps are not required to be included in Ginna's IST Program.

The boration flow paths for which credit is taken at Ginna are:

1. Charging from the RWST through the RCP seals into the RCS

2. Charging from the RWST through the normal charging path into the RCS

3. Safety Injection from the RWST or BAT to the RCS cold leg With the exception of the charging pumps, all of the pumps and active valves'n these flow paths are included in the current Ginna IST program. The charging pumps will be included in the revised IST program.

Also see response to Question 1.B.7.

gfs%084 11/21/88

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R. E. Ginna Nuclear Power Plant Pump and Valve Inservice Testing Program Response to EGGG Questions and Comments

2. PUMP TESTING PROGRAM question:

8. Are pump vibration measurements made in units of displacement or in units of velocity?

~Res onse:

Pumps are evaluated based. on;units of displacement (mils).

gfs/084

R. E. Ginna Nuclear Power Plant Pump and. Valve Inservice Testing Program Response to EG&G Questions and. Comments

2. PUMP TESTING PROGRAM question:

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.

R~es onse:

Presently, all pumps in the Ginna IST program are tested on a monthly basis with the exception of some pumps which are not tested monthly during cold shutdown or refueling outages.

However, these pumps are required to be tested, prior to start up if the time since the last test exceeds one month. Any components in systems out of service are not tested until the system is returned to service.

gfs~084