L-95-277, Forwards Third 10-Yr ISI Interval Inservice Testing Program for Pumps & Valves
| ML17353A429 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/26/1995 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17353A430 | List: |
| References | |
| L-95-277, NUDOCS 9511010102 | |
| Download: ML17353A429 (27) | |
Text
PRXORXTY 1 (ACCELERATED RZDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9511010102 DOC.DATE: 95/10/26 NOTARIZED: NO DOCKET g FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 P
50-251 Turkey Point Plant, Unit 4, Florida P wer and Light C 05000251 AUTH.NAME AUTHOR AFFILIATION PLUNKETT,T.F.
Florida Power
& Light Co.
RECIP.NAME, RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
I
SUBJECT:
Forwards "Third 10-Yr ISI Interval Inservice Testing Program for Pumps
& Valves."
0 DISTRIBUTION CODE A047D COPIES RECEIVED LTR ENCL SIZE
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TITLE: OR Submittal: Inservice/Testing/Relief from ASME Code GL-89-04 4
NOTES:
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RECIPIENT ID CODE/NAME PD2-1 LA CROTEAU,R INTERNAL: AEOD/SPD/RAB NRR/DE/ECGB NRR/DE/EMEB OGC/HDS3 EXTERNAL: LITCO ANDERSON NRC PDR COPIES LTTR ENCL 1
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P.O. Box 029100, Miami, FL, 33102-9100 OCT 88 1995 L-95-277 10 CFR 50.55a U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Inservice Testin Pro ram By letter L-94-001, dated January 12, 1994, Florida Power and Light Company (FPL) submitted revision 0 ofthe Third Ten Year Inservice Testing (IST) Program for Turkey Point Units 3 and 4.
By letter dated October 27, 1994, the NRC provided the Safety Evaluation (SE) related to the IST Program.
Attachment 1 provides the response to the Recommended Action Items identified in Section 5 ofthe Technical Evaluation Report (TER) issued as part ofthe NRC SE. is revision 1 ofthe Third Ten Year IST Program for Turkey Point Units 3 and 4. The IST Program changes from the initialrevision 0 version are identified by a revision bar on the right hand margin of the page. is a status of the relief requests associated with the IST Program.
The IST Program incorporates six relief requests, ofwhich five are reliefs from pump testing requirements, and one is a relieffrom valve testing requirements.
Ofthe six active relief requests, five have been granted on a permanent basis, and one has been granted with provisions.
ReliefRequest PR-2 was revised to indicate that pump vibration is being measured quarterly. Relief Request PR-4, which was approved with provisions, has been revised to provide clarification on the pump difFerential pressure calculations, per Recommended Action Item 5.2 ofthe TER, and to specify to which pumps it applies. ReliefRequest PR-4 is resubmitted forNRC review and approval. Relief Request PR-S, although previously approved, has been revised to address the &equency response of a new vibration measuring device. ReliefRequest PR-5 is resubmitted forNRC review and approval.
The revised sections ofthe reliefrequests are identified within each a6ected request.
NRC approval ofReliefRequests PR-4 and PR-5 is requested by May 1, 1996. FPL willcontinue to comply with revision 0 ofthe IST Program until NRC approval ofrevision 1 to ReliefRequests PR-4 and PR-5 is received.
Please contact us ifthere are any questions about this submittal.
V I
- urs,
)f,+<Ztrn T. F. Plu ett Vice President Turkey Point Plant OIH Attachments CC:
9511010102
'251026
'DR ADOCK 05000250 9
PDR S. D. Ebneter, Regional Administrator, Region II, USNRC T. P. Johnson, Senior Resident Inspector, USNRC, Turkey Point Plant LOQQOj 5 t
an FPL Group company,
t Attachment 1 to L-95-277 Page 1
ATTACHMENT1 IST PROGRAM NRC RECOMMENDEDACTIONITEMS RECOMMENDED ACTIONITEMS SECTION 5.1 The IST Program's scope was reviewed for selected systems.
The pumps and valves in the Component Cooling Water, Residual Heat Removal, and Safety Injection Systems were reviewed against the requirements ofSection XIand the regulations.
The review results showed compliance withthe Code, except for the items below. The licensee should review these items and make changes to the IST Program, where appropriate.
Additionally, the licensee should verify that there are not similar problems with,the IST Program for other systems.
FPL RESPONSE As part ofthe response to the specific questions provided in the Technical Evaluation Report, Turkey Point took the following additional actions to ensure that the comments are addressed generically:
The basis for exclusion ofall Quality Group A, B, and C reliefvalves was reviewed.
As a result ofthis review, two additional valves withinthe CVCS system tRV-3(4)-0382] are being added to the IST Program and two reliefvalves [RVQ-1451A&B] on the Unit 4 emergency diesel generator cooling water expansion tanks are being deleted from the IST Program due to their design and Quality Group classification.
The responses to Unit specific questions were reviewed and found to be valid for the other Unit.
RECOMMENDED ACTIONITEMS SECTION 5.1.A - GENERAL Several reliefvalves are not in the IST Program.
For example, on PAID 5613-M-3030-2, RV 747A &B, the reliefvalves on the bypass lines around the normally closed CCW outlet isolation valves MOV-3-749 A&B fiom the RHR Heat Exchangers, are not in the Program.
Also other relief valves on this drawing are not in the Program.
The Code requires testing ofall reliefvalves installed in systems that perform a function to achieve or maintain safe shutdown conditions or in mitigating an accident.
An inquiry has been submitted to the ASME to clarifythe Code requirements concerning thermal reliefvalves which are only required to function when components, e.g., heat exchangers are isolated.
The licensee should review the basis for excluding those reliefvalves fiomthe IST Program and ensure that the basis agrees with the
, Code interpretation when published.
i-951 1010102)
Attachment 1 to L-95-277 Page 2 FPL RESPONSE RV-3-747A&B open to protect the associated Residual Heat Removal (RHR) heat exchanger Gom damage should the component be isolated and subjected to internal heating and expansion ofthe contained fluid. The only scenario for which this could occur is when the shell side of the heat exchanger is isolated for maintenance, forwhich the heat exchanger would be declared out ofservice and isolated from the remainder ofthe system.
Failure ofthe heat exchanger and associated piping or the reliefvalve in this scenario would not impact the abilityofthe system to perform its design function.
In March 1995, the Code Subcommittee on Valves approved the inquiry regarding testing ofthermal reliefvalves, stating that thermal reliefvalves require testing under the ASME OM Code "provided they fallwithinthe scope ofISTC 1.1 as determined by the Owner." Since the scope ofapplicability for the ISTC 1.1 is the same as the scope specified in OMa Part 10, 1988, the above basis for exclusion still remains valid.
RECOMMENDEDACTIONITEMS SECTION 5.1.B - COMPONENT COOLINGWATER SYSTEM ITEM 1 The licensee should verify that there are no Category Aisolation valves for the component cooling water (CCW) system, as none are listed in the Program.
FPL RESPONSE AtTurkey Point, the CCW system is a closed system inside containment and is designed as a seismic Class I system that is capable ofwithstanding the efFects ofincreased pressure and temperature inside containment following an accident.
For closed systems inside containment, the closed piping loop provides the first barrier to containment leakage into the piping and therefore is mechanically comparable to an extension ofthe containment liner plate. Based on the design requirements ofthis system, there is no credible failure that willcause the permanent, passive boundary ofthe system to be breached.
Additionally, the system is maintained pressurized during normal operation and any system leakage would be quickly identified through changes in the CCW surge tank level. Based on the preceding, leakage testing ofsingle isolation valves used in conjunction with closed systems such as the CCW system is not required, and therefore none ofthe valves are required to be classified or tested as Category Avalves withinthe IST Program.
Attachment 1 to L-95-277 Page 3 ITEM2 Control valve RCV-3-609 (P&ID 5613-M-3030-1 C7), on 4"-AC-153R, the CCW Surge Tank outlet line to the Waste Disposal System, appears to be normally or intermittently open, and is designated to fail closed, is not in the program. The licensee should review the function ofthis valve and revise the Program as necessary.
FPL RESPONSE RCV-3-609 is located on the CCW system which, as discussed in the previous response, is a closed system inside containment forwhich there is no credible failure that willcause the permanent, passive boundary to be breached.
This system design precludes the necessity for this valve to close to mitigate the consequences ofan accident.
Additionally, the valve performs no functions in regards to shutting down the reactor or maintaining cold shutdown conditions.
Based on the preceding, the function ofRCV-3-609, including failure position upon loss ofvalve actuator power, was determined not to fall within the scope ofthe program as defined in OM Part 10.
ITEM3 Control valve TCV-3-144 (P&ID5613-M-3030-2@DS) is not in the Program.
The P&ID indicates that it is actually Out ofService but is required to Pail Open.
FPL RESPONSE TCV-3-144 does not perform a function with respect to accident mitigation or achieving and maintaining cold shutdown conditions and therefore, has been determined not to fall under the scope of OM Part 10.
This basis is further substantiated by the fact that CCW flow through the nonregenerative heat exchanger is set by throttling the manual bypass valve around TCV-3-144 and CCW flowis unaffected by the position ofTCV-3-144 since the manual inlet valve to this control valve is maintained closed.
ITEM4 Six inch check valve 3-0717, (P&ID5613-M-3030-5 E3) normally open, and appears to have a safety related function to close as a Containment Isolation Valve for P-03 to isolate CCW flowto the Reactor Coolant Pumps, is not in the Program.
The licensee should review the function ofthis valve and revise the Program as necessary.
Attachment 1 to L-95-277 Page 4 FPL RESPONSE The safety related function ofisolation ofCCW flowto the Reactor Coolant Pumps is performed by MOV-3-716B, which is included and tested as a Category B, active valve within the current IST Program. Containment isolation forthis penetration is provided as previously discussed, by the closed system inside containment.
RECOMMENDED ACTION ITEMS SECTION 5.1.C - RESIDUAL HEAT REMOVAL SYSTEM Air-operated, fail open butterfly valve, HCV-3-0758 (P&ID5613-M-3050-1 CS) from the RHR heat exchanger to the normal RHR/low head injection to the RCS cold legs is not in the program.
The licensee should review the function ofthis valve and revise the Program as necessary.
FPL RESPONSE HCV-3-0758 is normally open during Modes 1, 2 and 3 with the non-safety related instrument air isolated and the valve physically verified to be failed open against its mechanical stop.
During a design basis accident the valve is not utilized to throttle flowto the reactor coolant system. In Mode 4 and below, instrument air is unisolated and HCV-3-0758 is utilized to control RCS temperature.
This temperature control function during cooldown is categorized as a non-safety related function withinthe design basis documents and the categorization ofthis function is further substantiated by its use of a non-safety related air supply.
Based on the preceding, the valve is categorized as B, Passive, with no exercise test required.
However, based on the necessity for the valve to be failed open against its backstop, it has been determined that failsafe testing should be performed in accordance with the IST Program.
This requirement has been included in revision 1 of the IST Program.
RECOMMENDED ACTIONITEMS SECTION 5.1.D - SAFETY INJECTION SYSTEM ITEM 1 On page 84 ofthe valve table (forUnit3), check valve 3-0875C, has been designated Category C but because it is a pressure isolation valve it should be designated A/C.
(See also Table 3.4-1 of Technical Specifications).
I<'PL RESPONSE The IST Program (Rev. 1) has been revised to reflect this designation.
Attachment 1 to L-95-277 Page 5 ITEM2 The licensee should verifywhy check valves, 3-0875D, 3-0875E, and 3-0875F (P&ID5613-M-3064-1), have not been classified as pressure isolation valves while the other branching check valves have been so classified.
FPI RESPONSE AtTurkey Point, only the "Event V"pressure isolation valves are specifically called out in Technical Specifications with specific leakage limits assigned.
Check valves 3-0875D, 3-0875E, and 3-0875F are not listed in the Technical Specification and as such have no specific leakage limitassigned.
The IST Program categorizes these valves as Category C and as recommended in Generic Letter 89-04, Position 4, periodic closure testing ofthese valves is performed on a refueling frequency basis.
RECOMMENDED ACTIONITEMS SECTION 5.2 In Pump ReliefRequest PR-4 for all pumps in the IST Program, the licensee should ensure that the calculation of pump differential pressure is proceduralized properly to account for liquid in the pressure sensing gage lines so that the accuracy ofthe final value meets Code requirements.
FPI RESPONSE The Code requirement for pressure measurement states that ifthe presence or absence ofliquid in a gage line could produce a difference ofmore than 0.25% in the indicated value ofthe measured pressure, means shall be provided to assure or determine the presence or absence ofliquid as required forthe static correction used. For gauges which were not vented and did not meet the above Code requirement, the introduced error in conjunction with the specific range and accuracy ofthe gauges utilized were verified to exceed the Code required accuracy for calculation ofdifferential pressure.
This calculation verified that the square root ofthe sum ofthe squares (SRSS) ofthe errors ofthe gauges utilized, including a term to account for the error associated with the presence or absence of liquid, was less than the SRSS ofsix percent ofthe associated suction and discharge pressures.
The reliefrequest has been clarified to state this fact and more specifically delineate to which pumps it applies.
RECOMMENDED ACTIONITEMS SECTION 5.3 In any future revision ofPump Relief Request PR-2 for the Residual Heat Removal Pumps, the licensee should also indicate that vibration is being measured quarterly.
0
t Attachment 1 to L-95-277 Page 6 FPL RESPONSE Pump ReliefRequest PR-2 included in the IST Program (Rev. 1) has been updated as requested.
RECOMMENDEDACTIONITEMS SECTION 5.4 (1)
In Valve ReliefRequest VR-2 for check valves in the Safety Injection System which are pressure isolation valves (PIVs), in which the licensee wants to perform a seat leakage test verification ofvalve closure in accordance withthe fiequencies specified in Technical Specification 4.4.6.2.2, the licensee could convert this request into a deferral justification and include valves:
3-0873C and 4-0873C 3-0875A thru C and 4-0875A thru C FPL RESPONSE Valve ReliefRequest VR-2 has been withdrawn in revision 1 ofthe IST Program with the request converted into a refueling outage justification in accordance with the guidelines provided in Section 4.1.4 ofNVREG 1482.
Valves 3/4-0873C has been included in this refueling outage justification.
A deferral already exists for 3/4-0875A thru C (CS J-SI-7).
RECOMMENDEDACTIONITEMS SECTION 5.4 (2)
The licensee should also verifywhether:
Cold Leg Injection check valves 3-0876A thru C should be included in the request.
FPL RESPONSE Valves 3/4-0876A, B, and C are not required to be added to this new justification as closure testing ofthese valves is already covered under cold shutdown justifications CSJ-SI-5 and CS J-SI-6.
Attachment 1 to L-95-277 Page 7 RECOMMENDEDACTIONITEMS SECTION 5.4 (3)
The licensee should also verifywhether:
Valves 3-0876 D&Eand 4-0876 D8cE on the Alternate Low Head Safety Injection lines Rom the Residual Heat Removal (RHR) heat exchangers perform a safety function in the open position and whether an exercise closed test is also required. The licensee should also review whether these valves are active, rather than passive.
FPL RESPONSE Review of the Turkey Point UPSAR Chapter 6 and the design basis document indicate that the residual heat removal system was designed to perform its function following a single active failure under General Design Criterion 41. The capability ofthe system to operate followingselected passive failures wa's imposed by the AtomicEnergy Commission after a staffmeeting in 1967. This capability, although available, is beyond the original design ofthe system. Based on the preceding it has been determined that these valves do not perform a safety function in the open direction. In regards to their classification as active or passive, these valves were initiallyclassified as passive as they are normally closed, periodically verified closed'by seat leakage testing and required to be retested following opening under the requirements ofTechnical Specification 4.4.6.2.2. However, in order to provide consistency in the Program, this classification willbe revised to active and an exercise closure test specified. Current testing of these valves willbe unaffected by this change as a refueling outage justification will also be added specifying that testing will conform to the requirements of plant Technical Specifications.
RECOMMENDEDACTIONITEMS SECTION 5.4 (4)
The licensee should also verifywhether:
I'he pressure differential requirements ofOM-10, paragraph 4.2.2.3 for seat leakage testing are met by the Technical Specification required testing forPIVs. Ifthe licensee determines that the proposed leak rate testing in the Technical Specifications is not adequate to meet the Code requirements for leak rate testing (i.e. OM-10 paragraph 4.2.2.3), a reliefrequest should be prepared and submitted for review.
FPL RESPONSE Testing requirements implemented for the pressure isolation valves has been verified to meet the requirements ofOM-10, paragraph 4.2.2.3.
Ll
i Attachment 1 to L-95-277 Page 8 RECOMMENDED ACTIONITEMS E ON 5.5 (1)
The licensee has submitted 32 Cold Shutdown Justifications (CSJ) which document the impracticality oftesting valves quarterly, during operation, as required by OMa-1988, Part 10.
The following deferrals require further action by the licensee:
In CS J-RH-1 for the Residual Heat Removal (RHR) pumps'ischarge check valves 3-0753 A&Band 4-0753 A&B,the licensee has provided no information as to why the valves cannot be verified closed quarterly, because there appear to be available test connections and, as discussed in GL 89-04 Position 3 (Ref. 7), verification ofclosure may be achieved by a leak test, even ifno leakage limits apply. The licensee should revise and resubmit this deferral to discuss any impracticality ofverifying closure ofthese valves quarterly.
FPL RESPONSE This Cold Shutdown Justification for these valves contained in revision 1 ofthe IST Program has been revised to provide discussion ofthe impracticality ofperforming closure testing quarterly.
RECOMMENDED ACTIONITEMS SECTION 5.5 (2)
In CSJ-SI-1, forthe SIS Pump Discharge Unit Cross-Tie, normally open motor operated gate valves MOV-0878 A&B, it is not apparent fi'om the Turkey Point UFSAR, Appendix A, paragraph on "Sharing ofthe High Head Safety Injection Pumps" under what circumstances these normally open valves would be required to close, nor whether these valves would be required to reopen followingclosure. The possibility ofentering an LCO is not sufIicient basis for not performing the required testing, unless the testing renders systems inoperable for an extended period oftime. The licensee should full-stroke exercise these valves quarterly within the Technical Specification time of72 hours, or provide justification that it is impractical to perform the testing during power operation. The licensee should also verify whether a safety function to open (or reopen following closure) exists and revise the Program accordingly.
FPL RESPONSE The Cold Shutdown Justification for these valves has been rewritten to clarifythe situation for which these valves are required to close and further discuss the impracticality ofquarterly exercising. In regards to the valve having a safety function to open, no accident scenario could be identified which required these valves to open or reopen followingclosure.
i Attachment 1 to L-95-277 Page 9 RECOMMENDED ACTIONITEMS SECTION 5.5 (3)
In CSJ-SI-2, for the SI and CS Minimum Flow Line Isolation Valves, normally open motor operated globe valves, MOV-3-0856 A&B, and MOV-4-0856 A&B,the licensee has only specified an exercise closed test in the Valve Program Tables. It appears that these valves have a safety function in the open position as well. The licensee should review the safety function of these valves and revise the program accordingly.
FPL RESPONSE During normal operation, these valves are maintained open to provide a flowpath for the minimum flowrecirculation lines associated with the containment spray pumps and associated safety injection pumps. Review ofthe system operating procedures and emergency operating procedures indicate that these valves are required to close during a design basis accident as part ofthe realignment ofthe safety injection system for long term recirculation, Once closed, these valves remain closed for the remainder ofthe accident scenario and therefore have no safety function to reopen followingclosure.
RECOMMENDED ACTIONITEMS SECTION 5.5 (4)
In CSJ-SI-3 for the locked open RWST Outlet Isolation Valves, motor operated gate valves MOV-3-0864 A&Band MOV-4-0864 A&B,the licensee should also verifywhether a safety function to open (or reopen following closure) exists and revise the Program accordingly.
FPL RESPONSE During normal operation, these valves are maintained open to provide suction for the containment spray pumps, low head safety injection pumps and associated high head safety injection pumps.
Review ofthe system operating procedures and emergency operating procedures indicate that these valves are required to close during a design basis accident as part ofthe realignment ofthe safety injection system for long term recirculation. Once closed, these valves remain closed for the remainder ofthe accident scenario and therefore, in regards to accident mitigation, these valves have no safety function to reopen followingclosure. These valves are also closed following emptying of the contents ofthe associated refueling water storage tank into the reactor cavity in preparation for refueling. Upon completion of refueling, these valves are reopened to return the contents of the refueling cavity back to the refueling water storage tank, however these operations are not required to bring the unit to the cold shutdown condition nor do they maintain the unit in the cold shutdown condition.
i Attachment 1 to L-95-277 Page 10 RECOMMENDED ACTIONITEMS SECTION 5.5 (5)
In CSJ-SI-S, CSJ-SI-6, and CSJ-SI-7, for SIS check valves which are pressure isolation valves, the licensee refers in the Valve Program Tables to an "other reliefrequest" regarding exercising to the closed position. It is not evident what the reference is for the "other relief request" concerning closure testing. Since these are pressure isolation valves, it appears that these valves should be included in Valve ReliefRequest VR-2. The licensee should refer to the evaluation for VR-2.
FPL RESPONSE As discussed previously, VR-2 has been withdrawn in revision 1 ofthe IST Program. In the Valve Program Tables, the frequency specified for the closure testing ofthe valves discussed in these cold shutdown justifications has been revised &om &equency category 7 ("other (See applicable Request for Relief)") to frequency category 2 ("Cold Shutdown as defined by Tech. Specs.").
In CS J-AF-1 for the normally closed, AuxiliaryFeedwater Steam Supply Non-return check valves on the inlet to the AFWsteam-driven pump turbines, Flow diagrams (5613(4)-M-3075-
- 1) and (5610(4)-M-3075-1) indicate that these valves can be full-stroke exercised open during the Turbine Driven AuxiliaryFeedwater Pump quarterly test and therefore, testing quarterly appears practical. However, verifying closure does require isolation to make use ofthe test connections around these check valves. There are 3 (100~/o) steam driven pumps for both Units.
Only one auxiliary feedwater pump is needed per Unit. Taking one out ofservice leaves two to serve both Units. The possibility of entering an LCO is not a suf6cient basis for not performing the required testing unless testing renders the system inoperable for an extended period oftime. The licensee should exercise these valves closed quarterly or revise the deferral to demonstrate that quarterly testing is impractical.
FPL RESPONSE The deferral included in revision 1 of the IST Program has been enhanced to demonstrate the impracticality oftesting these valves quarterly.
RECOMMENDEDACTIONITEMS SECTION 5.6 (1)
t Attachment 1 to L-95-277 Page 11 impracticality oftesting valves quarterly, during operation, as required by OMa-1988, Part 10. The following deferrals require further action by the licensee:
In ROJ-SA-1 forthe normally closed Service Aircontainment isolation valves 3-40-0205 (4 0205), the licensee has not provided justification as to why a reverse seat leakage test could not be performed during cold shutdowns. In its submittal ofthe Inservice Testing Program for the St. Lucie Unit 2 plant, Revision 2, September 15, 1992, the licensee indicated that analogous valve V-181270 in the Service AirSystem is full-stroke exercised to the closed position during those cold shutdowns in which the Section ofthe Service Airsystem inside containment is in service. Therefore, the licensee should full-stroke exercise the subject valves f3-40-0205 (4 0205)) to the closed position during those cold shutdowns when the Service Airsystem header inside containment is in service or revise this justification to justify deferring full-stroke exercising the subject valves to the closed position during refueling outages.
FPL RESPONSE The Refueling Outage Justification for the Service Aircheck valves has been updated in revision 1 ofthe IST Program to meet all ofthe requirements specified in NUREG-1482, Section 4.1.4.
RECOMMENDED ACTIONITEMS SECTION 5.6 (2) f'n the foHowing ROJs there is no seat leakage testing for containment isolation function every 2 years under Appendix J prescribed in the Valve Program Tables. The licensee should verify whether seat leakage testing under Appendix J is being performed:
- In ROJ-CV-2 forthe normally open Charging Header containment isolation check valves 3-0312C (4-0312C), and
- in ROJ-CV-4 for the normally open RCP Seal Water containment isolation check valves 3-0298A thru 3-0298C (4-0298A thru 4-0298C).
FPL RESPONSE Revision 1 ofthe IST Program has been updated to reflect that these valves are seat leakage tested in accordance with the requirements of 10 CFR 50, Appendix J.
C
t Attachment 1 to L-95-27,7 Page 12 NRC RECOMMENDED ACTIONS SECTION 5.6 (3)
In the followingROJs, the proposed alternative provides part-stroke exercising to the open position during cold shutdowns and full-stroke exercising to the open position during refueling outages in accordance with OMa-1988 Part 10 paragraph 4.3.2.2(d), provided that the full-stroke exercising open test is conducted at the maximum required accident Qowrate. It appears that the licensee is proposing to perform a reduced pressure flowtest as a means offull-stroke exercising the valves open. It is not evident how a reduced pressure Qow test alone willverify that the valves are full-stroke exercised open.
The licensee should indicate whether the full-stroke open test is conducted at the maximum required accident Qowrate as discussed in Generic Letter 89-04, Position 1. Ifa reduced Qowrate is used, a positive means for verifying the valves open to the full-stroke position is required.
Such means must meet all the six criteria identified in Position 1.
Draft NUREG-1482, Section 4.1.2, further discusses the use of nonintrusive techniques as a means for verifyingvalve position and the acceptability ofsample testing.
The licensee should revise the followingjustifications to clarify the testing method, since they currently do not appear to comply with Generic Letter 89-04, Position 1:
- In ROJ-SI-5 for the normally closed SIS Cold Leg Injection check valves 3-0875A thru 3-0875C (4-0875A thru 4-0875C), and
- InROJ-SI-6 forthe normaHy closed SIS Accumulator Discharge check valves 3-0875D-F (4-0875D-F).
FPL RESPONSE The above referenced refueling outage justifications have been enhanced in revision 1 ofthe IST Program to address all six ofthe criteria identified in Generic Letter 89-04, Position 1.
ATTACHMENT2 TO I 95-277 TURKEYPOINT UNITS 3 AND4 INSERVICE TESTING PROGRAM, REVISION 1