ML17326B297
| ML17326B297 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/05/1987 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML17326B298 | List: |
| References | |
| AEP:NRC:0969H, AEP:NRC:969H, NUDOCS 8710130256 | |
| Download: ML17326B297 (37) | |
Text
a.'
REGULAT~ INFORMATION DISTRIBUTION STEM (RIDS) pl ACCESSION"NBR: 8710130256
'FACIL: 50-315 Donald DOC. DATE: '7/10/05 NOTARIZED: NO Nuclear Power Planti Unit ii Indiana DOCKET 05000315 I
C. Cook 8c 50-316 Donald C. Cook Nuclear Power Plant. Unit 2i Indiana 8c 05000316 AUTH. NAME AUTHOR AFFILIATION ALEX ICHOR M. P. Indiana Michigan Power Co.
REC IP. NAME REC IP IENT AFF I L I ATION MURLEYi T. E. Document Control Branch (Document Control Desk)
SUBJECT:
Forwards Rev 2 to "DC Cook Nuclear Plant Unit 1 Inservice Testing Valve Program" 5 ."DC Cook" Nuclear Plant Unit 2 Inservice Testing Valve Program. Fee paid.
5'+7J .
DISTRIBUTION CODE: A047D COPIES RECEIVED: LTR t ENCL l SIZE: C2 TITLE: OR Submittal: Inservice Inspection/Testing NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-3 LA 1 0 PD3-3 PD o WIQQINQTONi D 1 1 Jl INTERNAL: AEOD/DO* AEOD/DSP/TPAB ARM/DAF/LFMB NRR/DEST/MEB NRR/DEST/MTB Pt RB OQC/HDSi 01 RES/DE/EIB EXTERNAL: LPDR 1 1 d NRC PDR io NSIC 1 ie uoA~4 41>>
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TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 481
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Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 432i6 EHHMSLNSl MCMSGQH PQWM AEP:NRC:0969H Donald C. Cook Nuclear Plant Units 1 and 2, Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 UPDATED INSERVICE TESTING PROGRAM U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Attn: T. E. Murley October 5, 1987
Dear Dr. Murley:
Re: NRC Letter from Mr. D. L. Wigginton dated August 6, 1987, "Summary of Meeting Held on July 14-15, 1987, to Discuss Second 10-Year Inservice Testing Program" This letter and its attachments are in response to the above-referenced letter for the Second 10-Year Inservice Testing (IST) Program for Pumps and Valves for the Donald C. Cook Nuclear Plant. The Second 10-Year IST Program was submitted to your office by our letter AEP:NRC:0969, dated December 31, 1985. This submittal addresses the "Questions, Comments, and Resolutions" agreed upon in a meeting between the NRC staff, the NRC consultant (EG6G) and AEPSC on July 14-15, 1987. The attachments to this letter are as follows:
Attachment No. 1: Inservice Testing Program for Pumps - Units 1 and 2, Revision 1, dated September 1, 1987.
Attachment No. 2: Inservice Testing Program for Valves - Unit 1, Revision 2, dated August 31, 1987.
Attachment No. 3: Inservice Testing Program for Valves - Unit 2, Revision 2, dated August 31, 1987.
Attachment No. 4: Summary of Revision 2, IST Valve Program.
Attachment No. 5: Guide to Revised IST Valve Program.
87i013025b 871005 ( ";
PDR ADOCK 05000315'.
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Dr. T. E. Murley AEP:NRC:0969H The first three attachments comprise the revised IST Program for the second ten-year interval for pumps and valves. This submittal replaces the IST Pump and Valve Program submitted December 31, 1985.
The IST program enclosed has been revised to address the issues discussed in the meeting on July 14-15, 1987 between the NRC staff and our staff.
This letter is being transmitted to you prior to formal review by the Plant Nuclear Safety Review Committee (PNSRC) or the Nuclear Safety Design Review Committee (NSDRC). We do not anticipate any major changes resulting from NSDRC or PNSRC review, but should that occur, we will notify you as appropriate.
A check in the amount of $ 150.00 is enclosed with this letter for the NRC review of the Inservice Testing Program.
This letter has been prepared following Corporate procedures which
. incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Sincerely, M. . exich Vice President MPA/cm cc: John E. Dolan (w/o attachments)
W. G. Smith, Jr. - Bridgman R. C. Callen (w/o attachments)
G. Bruchmann (w/o attachments)
G. Charnoff (w/o attachments)
NRC Resident Inspector - Bridgman A. B. Davis - Region III
ATTACHYiEhT NO. j.
TO PEP:NRC:0969H
C DONALD C. COOK NUCLEAR PLANT UNITS NO. 1 AND 2 ASME B,& PV CODE SECTION XI Pum Inservice Test Pro ram The pump test program shall be conducted in accordance with Section XI, Subsection IWP of the 1983 Edition of the ASME Boiler and Pressure Vessel Code through Summer 1983 Addenda, except for specific code relief, requested in accordance with 10 CFR 50.55a(g)(5)(iii). Exemptions or ammendments are identified in Code Relief Requests I, II, and III This pump test program is for the 2nd ten year inspection/test interval commencing July 1, 1986 for both Unit 1 and Unit 2.
The pump test program was developed employing the classification guidelines contained in Regulatory Guide 1.26, Revision 2 for Quality Groups B and C, and the definition of the reactor coolant system boundary contained in 10 CFR 50.2 (v) for Group A. (Quality Groups A, B, and C are the same as ASME Class 1, 2, and 3, respectively). Using these guidelines and IWP-1100, the pump list attached as Table A was developed. Table A identifies the following:
The pump number and service it performs along with the drawing identification number on which it is found.
lie
~ ~
The applicabl test parameters:
- 1. Speed
- 2. Inlet Pressure
- 3. Differential Pressure Determined as the difference between measured discharge and suction pressures
- 4. Flow Rate
- 5. Vibration Amplitude
- 6. Bearing Temperature iii. The test frequency required.
Page 1 of 7 Revision 1 9/1/87
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,'ri I
DONALD C. COOK NUCLEAR PLANT UNITS NO. 1 AND 2 PUMP INSERVICE TEST PROGRAM TABLE A PROGRAM
SUMMARY
TEST PARAMETERS PUMP INLET DIFFERENTIAL FLOW VIBRATION BEARING TEST SERVICE PUMP SPEED PRESSURE PRESSURE RATE AMPLITUDE TEMPERATURE FREQUENCY DWG. NO. NUMBER N P P V
~
Q b (1)
AUXILIARY PP-3W NO YES YES YES YES YES QUARTERLY FEEDWATER PP-3E NO YES YES YES YES YES QUARTERLY 5106A PP-4 YES YES YES YES YES YES QUARTERLY ESSENTIAL PP-7W NO YES YES YES YES YES QUARTERLY SERVICE PP-7E NO YES YES YES YES YES QUARTERLY WATER 5113 CENTRIFUGAL PP-50W NO YES YES YES YES YES QUARTERLY CHARGING PP-50E NO YES YES YES YES YES QUARTERLY 5129 BORIC ACID PP-46-1 NO YES YES YES YES YES QUARTERLY TRANSFER PP-46-2 NO YES YES YES YES YES QUARTERLY (5131) PP-46-3 NO YES YES YES YES YES QUARTERLY PP-46-4 NO YES YES YES YES YES QUARTERLY COMPONENT PP-10W NO YES YES YES YES YES QUARTERLY COOLING PP-10E NO YES YES YES YES YES QUARTERLY WATER 5 35A SAFETY. PP-26N NO YES YES YES YES YES QUARTERLY INJECTION PP-26S NO YES YES YES YES YES QUARTERLY 5142 RESIDUAL PP-35W NO YES YES YES YES YES QUARTERLY HEAT REMOVAL PP-35E 5143 CONTAINMENT PP-9W NO NO YES YES YES YES YES YES YES YES YES YES QUARTERLY QUARTERLY
~
SPRAY 5'144 PP-9E NO YES YES YES YES YES QUARTERLY DIESEL FUEL OIL QT-106 ABl NO YES YES YES (2) YES NO (1) QUARTERLY TRANSFER QT-106 AB2 NO YES YES YES (2) YES NO (1) QUARTERLY (5151) QT-106 CD1 NO YES YES YES (2) YES NO (1) QUARTERLY QT-106 CD2 NO YES YES YES 2 YES NO 1 QUARTERLY SPENT FUEL PIT PP-31N NO YES YES NO (3) YES YES QUARTERLY COOLING 5136 PP-31S NO YES YES NO 3 YES YES QUARTERLY
- a. These pumps are tested on test, bypass or minimum flow loops - per Section XI Subarticle IWP-1400.
- b. Inlet pressure measurement is in head of liquid, ft.
- c. Bearing temperatures will be measured annually, per Section XI IWP-3300 except as noted.
Page 2 of 7 Revision 1 9/1/87
DONALD C. COOK NUCLEAR PLANT UNITS NO. 1 AND 2 PUMP INSERVICE TEST PROGRAM TABLE A (CONTINUED)
PROGRAM
SUMMARY
(1) Refer to Code Relief Request I (2) Refer to Code Relief Request II (3) Refer to Code Relief Request III Page 3 of 7 Revision 1 9/1/87
DONALD C. COOK NUCLEAR PLANT UNITS NO. 1 AND 2 PUMP ZNSERVICE TEST PROGRAM CODE RELIEF REQUEST I Bearin Tem erature Measurement We believe that the intent of Paragraph ZWP-4310 is to exempt those pump bearings in the main flow path from temperature measurement requirements. However, relief is required, we if code request that the Diesel Fuel Oil Transfer Pumps be exempt from bearing temperature requirements as stated in Section XZ Subarticle IWP-3300.
The inboard and outboard sleeve bearings on those 2 HP gear.
pumps are lubricated and cooled by the pumped fluid. Temp-erature readings'are therefore inconclusive since bearing measurement points are not responsive to the changes in bearing temperature.
Bearing problems on gear pumps can be more readily identified by degradation of pump capacity. Flow rate deterioration indicates the existence of excessive clearance due to bearing wear and problems.
In addition, the code required pump running time for yearly bearing temperature measurement can not be met due to the limited capacity of the diesel generator fuel oil day tank.
Page 4 of 7 Revision 1 9/1/87
DONALD C. COOK NUCLEAR PLANT UNITS NO. 1 AND 2 PUMP INSERVICE TEST PROGRAM CODE RELIEF REQUEST II Duration of Tests Request that the duration of pump operation for testing, per Section XI Subarticle INP-3500, be amended for the Diesel Fuel Oil Transfer Pumps.
These pumps supply the diesel generator fuel oil day tank. A conservative level is maintained in the tank to meet the minimum capacity per Technical Specification requirements.
Due to the limited capacity of this tank, the pump operating test range is restricted. It is requested to record test parameters immediately after pump operation has stabil-ized.
Page 5 of 7 Revision 1 9/1/87
DONALD C. COOK NUCLEAR PLANT UNITS NO. 1 AND 2 PUMP INSERVICE TEST PROGRAM CODE RELIEF REQUEST III Flow Measurement of S ent Fuel Pit Coolin Pum s We request that the Spent Fuel Pit Cooling Pumps be exempt from flow measurement as required in Section XI, Subarticle IWP-3100 and Table IWP-3100-1, of the 1983 ASME Boiler and Pressure Vessel Code since the original design of the spent fuel pit cooling system did not incorporate flow measuring devices for these pumps.
The primary function of the spent fuel pit cooling system is to remove the decay heat generated by the spent fuel elements stored in the pit. The water from the pit flows to the suction of the spent fuel pit cooling pump and is pumped, through a heat exchanger where it is cooled, back to the spent fuel pit.
Duplicate pumping loops are provided to assure proper back-up.
By setting the discharge valve downstream of the heat exchanger to a specific predetermined setting, a repeatable system with a fixed resistance has been established. We propose to measure the differential pressure of the spent fuel pit cooling pump(s) in this fixed configuration to ascertain their operational readiness and'etermine any potential degradation. The water in this system is of high purity which precludes the fouling of the system, hence changes in differential pressure would be a good indication of changes in pump performance. In addition, pump vibration is measured and trended which would indicate potential mechanical problems.
While the spent fuel pit system provides cooling of the spent fuel pit water, it is not required for the safe shutdown of the plant nor does it mitigate the consequences of an accident. It is the level in the pit that determines the adequacy of the spent fuel pit cooling system. Failure of the redundant pumps would not jeopardize the cooling system since makeup water is available from the following sources to maintain level:
Refueling water storage tanks via the refueling water purification pumps.
2 ~ Primary water storage tank.
3 ~ Auxiliary building fire header via temporary hoses.
Page 6 of 7 Revision 1 9/1/87
Pump Inservice Test Program Code Relief Request III The spent fuel pit cooling system is closely monitored. Low level and high temperature as well as spent fuel pit cooling pump failure alarms would annunciate to indicate an abnormal condition and specifically a loss of cooling water flow. This would allow for the timely switch over to the redundant cooling pump and/or to correct any system problems.
The redundant spent fuel cooling pumps are of the horizontal centrifugal type with stainless steel materials and very reliable, especially in a fixed system with good water such as exists in the spent fuel pit cooling system. A review of all maintenance records on these pumps indicate there have been no failures and, further, the maintenance performed has been routine in nature.
In view of the above, we contend that the spent fuel pit cooling pumps can be properly monitored without, measuring flow and without sacrificing any reliability to the spent fuel pit cooling system.
Page 7 of 7 Revision 9/1/87 l
ATTACHMENT NO, 4 TO AEP:NRC:0969H
ATTACHMENT 4 AEP:NRC:969H
SUMMARY
OF REVISION 2 IST Valve Pro ram REFERENCE 1: NRC letter dated August 6, 1987, "D. C. Cook Nuclear Power Station, Units 1 and 2 Pump and Valve Inservice Testing Program Questions, Comments, and Resolutions"
- 1. The IST Valve Program (Relief Requests Notes and Valve Summary Sheets, etc.) has been revised to provide additional technical justification to answer the unresolved questions from Reference 1.
They are indicated as Revision 2. Attachment 5, Guide to Revised IST Valve Program, indicates the page of the IST Valve Program that was revised to resolve each of the open questions. The following questions were resolved and no further response is required: A-l, A-2, A-3, C-l, D-l, H-l, H-4, H-5, H-10, J-l, N-l, and 0-1.
- 2. Revised relief request notes for valves 1-PA-343, Unit 1 and 2-PA-242 and 2-PCR-40, Unit 2. Deleted relief request notes for valves 1-PCR-40 and 2-PCR-40 (Units 1 & 2) as indicated on the valve summary sheets.
- 3. Revised relief request note "H" (Fig. 1) for Fast Acting Valve's limiting values from two seconds to five seconds.
- 4. Added/revised code relief requests for quarterly stroke testing for The following containment isolation check valves: (NRC Question No.
G-1)
Valve No. ~Dw . No. Valve No. ~Dw . No.
1-NS-357 1-5124 2-NS-357 2-5124 1-PW-275 1-5128A 2-PW-275 2a5128A 1-CCW-243-25 1-5135B 2-CCW-243-25 2-5135B 1-CCW-243-72 1-5135B 2-CCW-243-72 2-5135B 1-CCW-244-25 1-5135B 2-CCW-244-25 2-5135B 1-CCW-244-72 1-5135B 2-CCW-244-72 2-5135B 1-N-159 1-5128A 2-N-159 2-5128A
- 5. Additional technical justification has been provided in the revised relief request notes for valves 1-SI-148 and 2-SI-148 (NRC Question No. H-6). Our previous code relief for check valve SI-148, which is located in the RWST supply line to the RHR system, cited that partial stroking of this valve at power or cold shutdown frequency could introduce entrained air in the RHR system into the suction of ECCS pumps.
1
The air entrainment concerns have been addressed by changes to operating procedures. In particular, operation of the RHR system at 1/2 loop is restricted to only one operating RHR pump at all times to prevent vortexing and air entrainment. Two pump operation during pump transfer at 1/2 loop is believed to have been the primary source of air in this system. The administrative increase of the 1/2 loop level by 8" has also assisted in minimizing the potential for air introduction in the RHR system. Based on these administrative changes, RHR air entrainment, though still a concern, is controlled to a point where it would not restrict part stroke testing of SI-148 in accordance with Section XI requirements.
The testing for SI-148 is: part-stroke testing, every three months and full-stroke testing during refueling outages. Cold Shutdown Justification and Code Relief Request is provided in the Relief Request Note.
- 6. Minor editorial changes made to the valve program are as follows;
- a. Flow diagram changes (revision number, coordinates, valve, identifications, etc.)
- b. Revised Revision 2 date to August 31, 1987, except for Valve Summary Sheets)
C. Revised Figure 3 explanatory notes for clarity as indicated.
Also added ASME Code,Section XI, references as applicable.
- d. Added flow diagram 1-5105D and due to the latest revision, the listing of valves have been changed as follows:
From 1-5105 to 1-5105D From 2-5105 to 2-5105B 1-MRV-210,-220,-230,-240 2-DCR-310,-320,-330,-340
-211,-221,-231,-241
-212,-222,-232,-242 1-MS-108-2 and 1-MS-108-3 1-MCM-221 and -231 All (20) Unit 1 Main Steam Safety Valves From 1-5106 to 1-5101D 1-FW-118-1 through -4 2
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'I
ATTACHNENT NO, 5 TO AEP:NRC:0969H
~ ,~ ATTACHMENT NO. 5 TO AEP:NRC:0969H
- 0. C. COOK NUCLEAR POWER STATION, UNITS I ANO 2 PUMP ANO VALVE INSERVICE TESTING PROGRAM Mian 7o g~)sg~
QUESTIONS, COMENTS, AND RESOLUTIONS <5T <AL-46. PRoOMN
!. VALVE TESTING PROGRAM General uestions and Comments (IA(T -I uHIT- a.
A.
- 1. List any valves that are Appendix J, Type C, leak rate tested that are not included in the 0. C. Cook IST programs?
Resolution:
All valves, except those excluded by IWV-1200, that are ko CNAN6a ld0 C,HA~E Appendix i, Type C, leak rate tested are included in the OJZ PQpg~g DR PE5PONdi SPAZul C8 0 ~
PECQVIRE > .
- 0. C. Cook IST program.
- 2. The entry in the test mode column of the valve listing table is often misleading because it does not always reflect the frequency at which the Code testing requirements ar e being met (as an example, listing a "P"'or testing during power operations when a valve is being partial-stroke exercised quarterly and full-stroke exercised during refueling outages leads a person to believe that the testing is completed quarterly, when in actuality it is not completed until the refueling outage).
Resolution:
Procedures are prepared for the detailed testing. These h/y CHAhlWS IJO <H8105~
procedures identify the required test'.ng ana :he associated o gesp0g~
, 6+0 testing frequency.
How does the SLT-1 seat leakage test differ from the. leak rate testing requirements of Section XI, Paragraph IWV-3420?
Resol uti on:
(J pgI <- I ON)1- Z.
The SLT-1 testing designation refers to testing as per Po cease h)o CH Ad/
Section Xf requirements. The technical specifications four valves identified in the DP P~poN <~o identify as PIYs the same ha.Q'~ ~e'a .
first 10-year [ST program.
4 Has Testing Procedure No. 12THP-4030-STP-237 been approved by the NRC staff to be used in lieu of the Appendix J testing for those valves identified for the SLT-2A seat leakage test?
Resolution:
eula RA, ~V@ F ok.
The procedure has previously been approved by NRC. The bc.7'- a A, 5C.f 2A procedure will be described in the revised 1ST program and Sg 0
'~(
4'v'(ddt Pape I3 the history of procedure approval will be described. J3
- 5. Test method EF-8 is identified to be performed on a cold shutdown frequency in the introduction, however, in the valve listing table it is sometimes identified for a refueling outage frequency.
Resolution:
uo1s roe pote Fol The definition of EF-8 will be modified to include refuelin gP g ~ JISEb EF -g kc4v outage frequency. PA4b rl Po Oe II
- 6. What, criteria is utilized for assigning limiting values of full-stroke time for power operated valves?
Resolution:
The design data, manufacturers data and FSAR requirements I2el>060 Ravage~
have been reviewed and factored into the pnogram. PARAaaRA~5 P~a+aa' pa The-Q 'Aac H, H average of 4 stroke times was determined for a valve. The I=lGr. 1 I'Acje5 P~
2, limiting stroke time is 150~ of the average time which Is i'C -P, I
6-8 more restrictive than the code for valves that are trended
Oesignated fast acting valves with less than a 2 second stroke time are not trended and are treated as fast acting valves as per the NRC method for fast acting valves. The licensee will provide a summary of the criteria used for assigning limiting values of the full-stroke time in the [ST program resubmittal.
B. Main Steam S stem
- 1. What percentage of the steam flow required through valves NS-108-2 and -3 for the turbine driven auxiliary feedwater pump ump 900 gpm into the steam generators at operating pressures to pump is needed to pump 700 gpm through the pump test flow path? On what basis is this partial flow test considered sufficient to verify the fu11-stroke capabi li ty of these valves (refer to main steam system Note 2)?
Resolution; Ninety percent of the design steam flow is needed to pump R&disGD ( REV4$ &O NoT6 -a Oofy, $
The relief request will be modified to provide a 700 gpm.
PA+~ l+ iPh~ f5 more detailed justification and basis for the impracticality of full-stroke exercising the valves.
- 2. Radiography may be an acceptable alternate testing method to determine valve disk position, however, the reviewers are not aware of a method of testing by . adiography that provides a reasonable assurance of the reverse flow closure capability of check valves that perform a safety function in the closed position. How can radiography be used to assure the reverse flow capability of valves MS-108-2 and -3?
Resolution; The licensee will. provide a detailed justificat',on to Q gy)g ~@ Rc 4($ 6l7
~au uoggZ o~
support the use of radiography to provide assurance of valve < << ) PA4rg full-stroking. Also, the licensee will describe the method PA~~Pg , E .iF'ARACCRAf'~
< ~
! ~i &AE;Q
used to samp 1 e the valves and group the valves for disassembly.
C. !~I! ' Llg>T- i Ugt'T- ~
1 What flowrate is esta is e through the pump test flow paths t blished during the quarter y testing es of the motor driven auxiliary feedwater pumps? M Mh a t is the design accident flowrate through check valves FM-)24 and -128?
Resolution: hlO CHA~E Op ~~As uQ, g Greater than design accident flow is established during testing.
- 2. How is it ver>>e'f' that sufficient flow passes through valves FM-153 and -)60 to full-stroke them open with flow quarterly' Resolution:
A pressure decrease is used to determine that flow is Appr.=u h/s& Ac cs>
established in the mini,-flow line. The, test method for >age N usa ~o-.
P~< l7 )p stroking the valves will be described in the IST program. Vss 'R&l~s~ 'Vgq Qa~
- 3. What is the safety related function of valve )2-CRV-5)?
Resolution:
The IST program will be amended to show the valve safety function is closed and it will be tested as per Code ~<D ~Ye g requirements.
VSg"'g~s The NRC staff position is that verification of the maximum flow rate through a check valve identified in any. of the plant t s safety analyses would be an adequate demonstration of the full-stroke capability of tne valve. Provide a detailed
'/ SHEETS
Ox)iT- I technical justification why this cannot be done to quarterly full-stroke exercise valves FM-134 and -135.
Resolution:
Risen LFUI 5 5b The licensee will provide additional justification for not hX7f& S MVS testing these valves as per Section XI requirements. PAae <g PA&5 <'7
- 5. Is credit taken for the reverse flow closure of any of the check valves in the flow paths of the auxiliary feedwater pumps to the steam generators'. If so, how are these valves individually verified to close?
Resolution:
The temperature of the auxiliary feed line is monitored to R&y<se0 'Ravish>
determine valve closure at least quarterly. This method APT 200 toof+~o PwtaF p7 A,wr, will be described in the IST program and the closed safety PAG,E. 1-l ) ~rc + 4'"
vore g o~ i function of the appropriate valves wi;-1 be identified that P~e le '~ce IS JeS" Re are tested using this method.
D. Essential Service Water S stem
- l. If valves ESM-101E and -101M perform a safety function in the closed position to prevent reverse flow through an idle pump, they must be tested to the closed position to verify their aoility to perform that function.
Resolution:
The ESW trains are not cross-connected and further the C.RA466 informati'on is not required.
- 08. Regpo~c, ~R Rag~
R~ c> ~
4
~~
xJ~)Q I~
,g u~usA') 5~'<<~.
E. Reactor Coolant S stem
- 1. Provide a more detailed technical justification for not exercising valves NSO-021. -022, -023, and -024 during cold shutdowns.
Resolution:
gem <eeD Justification will be provided in the IST program for not testing these valves during cold shutdowns. P~e 22 p+~g 2,2 'j .
Vs% R6<<5Q VSs ~>>+
- 2. Provide a more detailed technical justification for not exercising valves NS0-061,,-062, -063, and -064 during cold shutdowns.
Reso1ution:
Same as Item E. 1 except the referenced information in the Q,gV<56> '&l<S6D QOTc technical specification will be inc)uaed in the IST program. aA po,Cv6 2+ OA P+66 2
/ crgtg<~j X/~ -'O'I '
F. Chemical and Volume Control S stem Explain how radiography can be used to verify reverse flow closure of check valve CS-292.
Resolution:
Justification for using radiography to test this valve will Qgv its p Remi Se>
be provided in the IST program. A radiograph of :nis valve gott gOP) gcrC~+ OW The radiograph showed that the valve was in
~5 was examined. Ace. ~<
the closed position and thus provided v'.sual observation of valve closure.
- 2. What is the safety function of control valves HARV-200 and -251?
The NRC staff position is that requests for relief will not be
OhfsT- )
evaluated for valves that do not perform 4 safety related func ti on.
Resolution:
6'8~i ~SO 'ge<~ zD Valves QRV-200 and -251 are used for emergency boration in Qo Ms 7 p)9 I Q~~> ~ g ~
Modes 5 and 6 and should be in the IST program. Note 7 for Pp~ gy M PhgggZgg ~.
valves gMO-200 and -201 will be corrected in the ISTprogram. The function of valves HARV-200 and -251 will be reevaluated and Notes 8 and 9 may be deleted. If these notes aren't deleted they will be modified to show impracticality of testing.
G. Post Accident Sam lin S stem Unless valve NS-283 is verified in the closed position during the quarterly exercising test, relief is still required from the Section XI requirement to full-stroke exer"ise this check valve quarterly.
Resolution:
valve list will be revised to show that relief is The requested. In addition, closure testing of other check Ao7e '-
Re>'~se D Agv !55 D
~8Z CH valves will be reviewed to 'see that relief is being o~ ~g4 PwA<
requested as appropriate and included in the IST program.
H. Emer enc Core Coolin S stem If valves IM0-51, -52, -=3, and -54 are ever required to change MO Cpo4C 530 c.ffA position to accompli sh a specific function, they are not passive < ~%p~ 4 R Res and must be exercised in accordance with the Code. ~li~ l Q~~D P
os>
Resolution:
These valves are passive and, therefore, need not be included in the program.
The use of IMV-3416 in emergency core cooling Note 2 for valves INO-128 and ICN-:29 is not appropriate since the RHR system is not out of service during power operations. An adequate justification is provided in the note which demonstrates the impracticality of exercising these valves during power operations and they should, therefore, be exercised on a cold shutdown frequency as provided for in the Code.
Resolution:
REvise C The last sentence in Note 2 will be deleted to el iminate QEvi58h i @ATE ova 2. ~~
reference to IMV-3416. The note will be modified to PA~ 3C 7'ac C QgS QEV identify and justify valve testing during shutdown.
VS&'pv'rs
- 3. If valve N-102 is opened during power operations to add nitrogen to the safety injection accumulators, then it is not a passive valve and should be tested to the requirements of IMV-3520 unless relief is reauested from the Code requirements.
Resolution:
pE ice~
" RKV 5 This is an active valve and a relief request will be (~0+ ~
Hef'E \+
provided for exercising the valve. P~4< 4I
- 4. If any credit is taken for closing valves IM0-110, -120, -130, and -140 in order to allow the reduction of RCS pressure to permit the RHR system to be placed into operation in the recirculation mode, they perform an active safety function and should be included in the IST program.
Resolution:
This is an open item for the NRC to determ'ine wnether these valves mus: be included in the program as active valives.
4 gular- I ~~+'r- 2
- 5. Is credit taken in any accident analysis f'r shifting low pressure safety injection (RHR) pump suet>on from the refuel)ng water storage tank to the containment recirculation sump? If so, valve INO-390 performs an active safety function to isolate the suction from the RMST and should be tested in accordance with the Code, Resolution:
gg ~pgg~S W CAW')Q galves IMO-310 and -320 are r equired to close and isolate oR gtsgo~ ',<k.~p, the pump suction from the RMST, therefore, IMO-390 does not 'Rse~o have to be in the program.
- 6. Have system modifications been performed to'llow full-stroke exercising check valve SI-148 in accordance with the Code without jeopardizing the availability of other safety systems?
Resolution:
The licensee will rewrite .the basis for requesting relief ,R6<<<<> Regrg6o flt7M 7 h)ofp g 0>
and will include in the resubmittal the resolution of the Pacha 38 air entrainment problem identified in the SER for the first cl n
~~+ R~<<en "V~~ Zunis.
10-year interval.
- 7. Provide a more detailed technical just".ication for not full-stroke exercising valves SI-'58-L1, -L2, -L3. and -L4 during cold shutdowns.
Resolution:
The licensee will add a justification for not ful',-stroking 60/'C I 2 OP Q~g these valves during cold shutdown to No.e 12. >~e ~l co~~ae
- 8. Provide a more detailed technical justificat'.on for not full-stroke exercis'ng valves SI-161-L1, -L2. -L3, and -L4 auring cold shutdowns.
. ONiT Re so l ut i on: l pgvlgd D QGvls&c NDTG @ ~~ I M>reGC)
Same as item H.7. 'p~y~ wQ Phbr6 provide the detailed technical justification for not full or partial-stroke exercising valves SI-170-L1, -L2, -', and -L4 either quarterly during power operations or during cold shutdowns.
Resolution:
The licensee will provide a more detailed justification R6 V'(55 D g~gy~~
N@76 g Oa .-
NoM I5 C including identifying partial-stroking during cold shutdown.
- 10. If valves ICN-311 and -321 are ever required to change position to accomplish a specific function, they are not passive and must be exercised in accordance with the Code.
Resolution:
These valves do not have to change position, are passive, Qc cscwd~ h3a cH~
and do not have to be included in the program. ~pynsS OQ +~i
~a'c.
I. Containment S ra S stem The NRC staff has concluded that, a valve sample disassembly and inspection utilizing a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke capability. This program involves grouping similar valves together and testing one valve in each group during each refueling outage, The sampling technique requires that each valve in the group be of the same design {manufacturer, size, model number and materials of construction) and have the same service condit'.ons. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
A differ ent valve of each group is required to be disassembled, inspected and manually full-stroke exercised at each refueling outage, until the entire group has been tested'f it is found that the disassembled vaive's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected and manually full-stroke exercised during the same outage.
Are valves CTS-103E, -103M, -13'.=, and -138M grouped together for sample disassembly and inspection? These valves do not appear to meet the NRC staff's criteria for grouping as explained above.
Resolution:
The licensee will either sample, group, inspect, and lZ<4 <Sell disassemble valves as per the stated NRC position or justify uoTe L a~
PA6La +2.
a deviation from this position.
Are valves CTS-127E, -127M, -131E, and -13'M, and valves RH-141 and -142 grouped together for sample disassembly and inspection?
These valves do not appear to meet the NRC staff's criteria for grouping as explained in guestion I. 1 above.
I ~
Resolution:
I A$
A~& I AQo~<
Same as Item I.l. GXCcSP T +eT6 ~g~pC dW 2.
J. Meld Channel P essurization S stem If valves CA-181-N and -S are opened during power operations, then they are not passive valves and should be tested to the requirements of IMV-3520 unless relief is requested from the Code requirements.
Resolution:
NO <HA~C NO cg~t These va1ves are not opened during power operation and are og Q~~pyu$ e <R AEspeA.'R6m'D passive and need not be exercised.
K. Ice Condenser Refri eration S stem
- l. Unless valves R-156 and -157 are verified in the closed position during the quarterly exercising test, relief is still required from the Section XI requirement to full-stroke exercise these check valves quarterly.
Resolution:
RGv'<s&c Pigvl5g D The valve list will be changed to indicate relief is being ',m
<c ~
requested and the basis for relief will be modified to Ppke ++ WIVE +-
include additional technical justification.
L. Emer enc Diesel Generator Subs stems Provide a more detailed technical justification for not measuring the stroke times for the following valves quarterly during power operations. Explain how the proposed testing individually verifies the operability of these valves. Do these valves have required fail-safe positions?
XRV-220 XRV"221 XRV-222 XRV-225 XRV"226 XRV-227 Reso'ution:
The licensee wi 1 1 provide a more detailed technical PgvI>So justification for not measuring the stroke time of these ~g~ g ~yJ 'VOTE $ C valves. The licensee wi 11 review the fail-safe position of p~~
+7 9mb PA@8 4, Nope 304 NME 3 if C
these valves and, appropriate, provide a relief request W~a~s.)
for not fai I-safe testing these valves. I I
I ~ ~ A
~< I I ()hlIT- ~
- 2. Review the safety related function of valves 2-OG-102C and -104C (PLIO 2-5151D-26 coordinates H-4 and F-4) to determine if they should be included in the [5T program.
Resolution:
These valves will be included in the licensee's IST program.
M. Com ressed Air S stem What are the consequences of loss of containment control air that make the quarterly testing of valves XCR-100, -101, -102, and
-103 impractical?
Resolution:
The licensee will provide a more detailed technical RMisew Qp.v <55 lO IDN6 3 09 QoTe 9 P4 justification that shows that full-stroking these valves P~a, J 4- ~ac a ~3 during power operation is impractical and will include a discussion of the consequences of loss of containment control air during operation.
N. Boron Nake-u S stem
- 1. If valves CS-415-1, -2, -3, and -4 perform a safety function in the c'.osed position to prevent 'reverse flow through an idle boric acid transfer pump, they must be tested to the closed position to verify their ability to perform that function.
Resolution:
Qo CH5446 tdg cHhplpa These valves do not have a safety function in the closed >R.@~~t.- uR ~pn~.
position and, therefore, do not have to be. tested to he closed position.
Ci.~ et 4 0
0 . S ent Fuel pit Cool in and Cl ean-u S stem I f val ves SF- 1 lBN and 5 Perform a safety function in the c'l osed position to prevent reverse flow through an i dl e spent fuel p i t, pump, they must be tested to the closed pos i ti on to verify their abi ity to perform that function.
1 Reso1 uti on:
These valves do not have a saf ety function i n the closed gd Ce&M ~o culm c)Q g$ $ptflgd ~R R55pc pos i ti on because suf f i c i ent water wi 1 pass through the heat exchanger pr i or to returning to the fuel stor age pool .
1 g~ ~D ~'
P . MOS Vents and Ora i ns S stem 1 . Provide a mor e detailed technical justification for not exer ci sing va1 ve N-160 during cold shutdowns .
Reso l uti on:
Rat (st.b The 1 i censee wi 1 1 provide just i f i cati on for testing this lhlOT5 ~ De valve during co 1 d shutdowns ~ 2+4 s s7
- g. PAL Sam 1 in and Instrumentation S stem inc
- 1. Reduct on of redundancy is not an adequate justification for not per formi ng the Code requi r ed testing; how ong can one of the 1 1 ower containment radiation mon i tor trains be inoperable before acti on must be taken?
%Meal Re so 1 ut i on:
~I The inlet valves wi 1 1 be tested as per the r equi rements of Pea'is so ge v'rs e 0 Section XI and reT i ef wi 1 1 be requested for the va l ve in the Qo T~ dorm I g common return 1 . Both trains are not requi red to be in 4+ P<~ M Og PA~
continuous operat i on by the technical spec i f i cat ions as Wc 4i 0@
Rgvt%
there is a 30 day LCO. Al so, additional justi f ication wi 1 1 L ~ ~
' A 0 a @kg eel 4 nf eanetsock'FA'I+