ML18003B349
| ML18003B349 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/10/1986 |
| From: | Buckley B Office of Nuclear Reactor Regulation |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8606200031 | |
| Download: ML18003B349 (13) | |
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June 10, 1886 Docket No. 50-400 Mr. E. E. Utley, Senior Executive Vice President Power Supply and Engineering and Construction Carolina Power and Light Company Post Office Box 1551 Raleigh, North Carolina 27602
Dear Mr. Utley:
DISTRIBUTION 8 fly NRC PDR D. Miller Local PDR
- ACRS (10)
PAD¹2 Rdg Tech Branch T. Novak Gray File OELD E. Jordan B. Grimes J. Partlow N. Thompson, DHFT
Subject:
Request for Additional Information - Shearon Harris Unit I, Pump and Valve Testing Program The enclosed questions and comments have resulted from the review of the Carolina Power and Light Company's inservice testing (IST) program for Shearon Harris.
We request that you respond to the enclosed questions in a timely manner in order that we can proceed with our review.
The reporting and/or recordkeeping requirements of this letter affect fewer than 10 respondents; therefore OMB clearance is not required under P.L.96-511.
Sincerely,
Enclosure:
As stated
/s/
Bart C. Buckley, Senior Project Manager PWR Project Directorate ¹2 Division of PWR Licensing-A Office of Nuclear Reactor Regulation cc:
See next page A'
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,'606200031 860hiO PDR
- DOCK 05000400 A
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Mr. E.
E. Utley Carolina Power 5 Light Company Shearon Harris CC:
Thomas A. Baxter, Esq.
Shaw, Pittman, Potts
& Trowbridge 1800 M Street, NW Washington, DC 20036 Richard E. Jones, Esq.
Vice President and Senior Counsel Carolina Power 8 Light Company 411 Fayetteville Street Mall Raleigh, North Carolina 27602 Mr. H. A. Cole Special Deputy Attorney General State of North Carolina Post Office.Box 629 Raleigh, North Carolina 27602 Resident Inspector /Harri s NPS c/o U.S. Nuclea~ Regulatory Commission Route 1,
Box 315B New Hill, North Carolina 27562 Charles D. Barham, Jr.,
Esq.
Vice President 5 Senior Counsel Carolina Power 5 Light Company Post Office Box 1551 Raleigh, North Carolina 27602 Mr. John Runkle, Executive Coordinator Conservation Council of North Carolina 307 Granvi'ile Road Chapel Hill, North Carolina 27514
.Mr. Wells Eddleman 812 Yancey Street Durham, North Carolina 27701 Dr. Linda Little Governor's Waste Management Board 513 Albemarle Building 325 North Salisbury Street
- Raleigh, North Carolina 27611 Mr. Travis Payne, Esq.
723 W. Johnson Street Post Office Box 12643
- Raleigh, North Carolina 27605 Mr. Daniel F.
Read CHANGE Post Office Box 2151
- Raleigh, North Carolina 27602 Bradley W. Jones, Esq.
U.S. Nuclear Regulatory Comm.
Region II 101 Marietta Street Atlanta, Georgia 30303 Richard D. Wilson, M. D.
725 Hunter Street Apex, North Carolina 27502 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Mat ietta Street Suite 2900 Atlanta, Georgia 30303 Mr. Robert P. Gruber Executive Director Public Staff - NCUC Post Office Box 991
- Raleigh, North Carolina 27602
ENCLOSURE SHEARON HARRIS NUCLEAR POWER PLANT PUMP AND VALVE INSERVICE TESTING PROGRAM UESTIONS AND COMMENTS l.
VALVE TESTING PROGRAM A.
General uestions and Comnents l.
Provide a l1st1ng of the lim1ting values of full-stroke t1me for all power operated valves 1n the Shearon Harr1s IST program for our review.
2.
Are the correct1ve action requirements of Section XI, IWV-3417(a) and (b) followed for all power operated valves at Shearon Harris?
The NRC staff will grant relief (1f properly requested) from the trending requ1rements of Sect1on XI, IWV-3417(a) for solenoid and other rap1d acllig valves.
In order to obta1n th1s rel1ef the l1censee must ass1gn a maximum 11mit1ng stroke t1me of 2 seconds to these valves and comply w1th the requirements of IWV-3417(b) when the 2 second 11mit is exceeded.
3.
Measurement and analys1s of valve stroke times must conform to the requirements of Sect1on XI 1n addit1on to the plant Technical Spec1ficat1ons (See Table 5.1.6-TS).
The purpose of the Section XI stroke time measurement requ1rements 1s to allow detect1on of valve degradation pr1or to a valve fail1ng to the po1nt that 1t is unable to perform its safety related funct1on.
There 1s not necessar1ly any correlat1on between the Sect1on XI stroke t1me limits and the Techn1cal Specification l1m1ts.
As an example,
)ust because a system is r~quired by Technical Specif1cations to perform 1ts funct1on within 120 seconds, 1t would not be appropr 1ate to assign a 11mit1ng value of stroke t1me of 120 seconds to system valves that normally stroke 1n 5 seconds.
On th1s basis, Technical Specificat1ons may or may sot be appropriate*1n determ1n1ng the 11m1t1ng value of stroke t1mes for valves; where they are not appropr1ate, other reasonable 11mits based on valve construction and operat1ng characterist1cs should be used.
4.
Valves that perform a containment 1solation function should be 1ncluded 1n the IST program and be categor1zed "A" or "A/C" as appropriate.
Are all valves that perform a containment 1solation funct1on at Shearon Harr1s 1ncluded in the IST program?
5.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolat1on valves are determined by 10 CFR 50 Append1x 3, however, the 11censee must comply w1th the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs of Sect1on XI, IWV-3426 and 3427.
6.
Valves that serve both.a pressure boundary isolation funct1on and a
containment 1solat1on funct1on must be leak tested to both the Append1x 3 and the Sect1on XI requirements.
Is this the case at Shearon Harris?
7.
When flow through a check valve 1s used to 1ndicate a full-stroke exercise of the valve disk, the NRC staff pos1tion 1s that verification of the max1mum flow rate 1dent1fied in any of the plant's safety analyses through the valve would be an adequate demonstration of the full-stroke requ1rements.
Any flow rate less than this w1ll be cons1dered partial-stroke exerc1s1ng unless 1t can be shown (by some means such as measurement of the different1al pressure across the valve), that the check valve's d1sk position at the lower flow rate would perm1t max1mum requ1red flow through the valve.
Ooes the Shearon Harris IST program conform to th1s staff pos1t1on?
B.
Main Steam S stem l.
How are valves 1HS-71 and 73 verif1ed to full-stroke open quarterly?
1.
What is the safety related function of the following valves?
1F W-140 1F W-198 1FH-256 1F W-159 1F W-217 1FW-277 1FW-307 1FH-313 1F H-319 D.
Auxiliar Feedwater S stem 1.
Is full auxiliary feedwater flow established into the steam generators during quarterly testing?
If not, how is a full-stroke exercise verified for the following system check valves?
If full flow is established during testing, 'does this create any thermal shock problems with the auxiliary feedwater nozzles or spray rings?
Would establishing full flow disturb steam generator water level control?
lAF-54 lAF-73 1AF-92 1AF -136 1 AF-142 1AF-148 1AF-16 lAF-31 1AF -117 1AF-68 1AF-87 1AF-106 1CE-36 1CE-46 1CE-56 E.
Service Mater S stem 1.
How is it verified that valves 1SH-141,
- 143, 152,
- 154, 163, and 165 back seat to block flow in the reverse direction during quarterly valve testing?
2.
Provide the technical )ustlfication for not exercising valves 1SW-231, 240 and 242, and not back seat testing valve 1SW-233 during cold shutdowns (Relates to relief request R-26).
3.
Prov1de the technical )ustification for not exerc1slng valve lSW-50 during cold shutdowns (Relates
'to relief request R-21).
F.
Containment S ra S stem l.
How 1s the valve pos1t1on 1ndicat1on ver1fied for lCT-102 and 105 wh1ch are located 1ns1de valve encapsulat1on chambers?
2.
How are check valves lCT-62 and 65 full-stroke exercised quarterly?
Could exerc1sing these valves w1th flow poss1bly contam1nate RWST water with chem1cals?
3.
How are valves lCT-53 and 9l verif1ed to full-stroke exerc1se when tested dur1ng refueling outages7 Provide a more deta1led techn1cal
)ustification for not exerc1s1ng these valves dur1ng cold shutdowns.
4.
Can valves lCT-ll and 12 be full-stroke exerc1sed quarterly w1thout the possib111ty of contam1nat1ng the RWST water w1th unwanted chemi ca 1 s?
5.
Oo the vacuum breakers (locat1ons A-7 and A-8) on the containment spray add1t1ve tank perform any safety related funct1on7 6.
Is des1gn accident flow establ1shed through valves 1CT-27 and 72
=dur ing quarterly test1ng to ver 1fy a full-stroke exerc1se of the valves?
G.
Post Acc1dent Sam 11n S stem l.
Is operab1lity of the post-acc1dent sampl1ng system a safety related funct1on at Shearon Harris Nuclear Power Plant?
If so, all valves
that are required to change position 1n order for the system to perform 1ts function should be included 1n the IST program and be tested in accordance'1th the Code.
H.
Rad1ation Monitor S stem What 1s the safety related funct1on of valves lSP-l6, 28, 916, and 918?
I.
01esel Generator S stems l.
Rev1ew the safety related function of the follow1ng valves to determine 1f they should be 1ncluded 1n the IST program and be tested 1n accordance with the Code.
Valve PAID Location Valve PE ID Location 1EA-4 l E A-l9 lEA-35 lEA-50 1 EA-14 1EA-15 lEA-29 S-0633 C-2 S-0633 D-2 S-0633 C-12 S-0633 D-12 S-0633SOl A-6 S-0633S01 A-6 S-0633S01 B-6 l SW-757 1 SW-776 lEA-30 lEA-45 lEA-46 lEA-60 lEA-61 S-0633 C-8 S-0633 C-18 S-0633S01 B-6 S-0633SOl A-17 S-0633S01 A-17 S-0633SOl B-17 S-0633S01 B-17 3.
Demineralized Water S stem 1.
For all of the valves covered by relief request R-33, provide a more deta1led technical )ustification for not exercis1ng the valves quarterly and the )ustification for not exerc1s1ng them during cold shutdowns.
What are the est1mated rad1at1on fields 1n the v1c1n1t1es of these valves and what dose rates would be rece1ved by the operators while performing the required test1ng?
K.
Instrument Air S stem 1.
Provide a more detailed techn1cal )ustification for not exercising valves lIA-216 and 220 during cold shutdowns.
L.
Reactor Coolant S stem 1.
There is an apparent conflict between the alternate test paragraph 1n relief request R-17 and the basis for re11ef.
The basis states that the pressurizer PORVs cannot be exercised during cold shutdowns and the alternate test states that they will be exerc1sed dur 1ng cold shutdowns.
The staff pos1t1on 1s that the PORVs should be exerc1sed on a cold"shutdown frequency.
~2.
Prov1de a more detailed technical Justification for not exerc1s1ng 1RC-900,
- 901, 902,
- 903, 904, and 905 quarterly.
M.
Chemical and Volume Control S stem 1.
Prov1de a more deta1led techn1cal )ustificat1on for not exerc1sing the following valves during cold shutdowns (Refer to re11ef requests R-4 and R-18).
Prov1de the reasons that reactor coolant pumps cannot be stopped dur1ng cold shutdowns to allow for valve test1ng.
1CS-341 1CS-382 1CS-423 1CS-470 1CS-471 1CS-472 1CS-344 1CS-385 1CS-426 2.
Could exerc1s1ng valve 1CS-1, 2, ll, 238 and 492 quarterly during power operat1ons result in loss of pressur1zer level control or. result in thermal shock to the regenerat1ve heat exchanger?
3.
Is cred1t taken for the use of aux111ary pressur1zer spray to take the reactor from normal operat1ng cond1tions to cold shutdown as described
'. ~-:.-.ch Techn1cal Pos1tion RSB.5-1?
If so, then valves lCS-487,
- 48o, and 491 perform a safety related funct1on and should be included in the IST program and be tested 1n accordance with the Code.
4.
Do the following valves perform a pressure boundary 1solat1on funct1on to Drotect the low pressure p1p1ng on the suct1on of the centr1fugal charging pumps from be1ng overpressurized?
1 CS-497 1 CS-500 1 CS-488 1 CS-491 5.
Prov1de a more deta1led technical )ustification for not exercising valves lCS-165 and l66 during cold shutdowns.
6.
Provide the techn1cal Justification for not exerc1sing valve lCS-294
".-'""cold shutdowns.
If this valve cannot be full-stroke exerc1sed during cold shutdowns, can it be partial-stroke exercised?
7.
iiow 'is a full-stroke exerc1se of valves lCS-178,
- 192, and 206 verif1ed during quarterly valve testing?
Is design acc1dent flow established through these valves quarterly' 8.
Provide a legible copy of PAID 2l65-S-1306 for our rev1ew.
9.
Is any credit taken for the bor1c acid grav1ty feed path?
If so, all appropriate valves should be 1ncluded 1n the IST program and be tested 1n accordance w1th the Code.
N.
Safet In ect1on S stem l.
How 1s a full-stroke exerc1se of valves lSI-Bl, 82.
and 83 ver1f1ed dur1ng test1ng?
Is design acc1dent'flow establ1shed through these valves?
Prov1de the Justification for not part1al-stroke exercising these valves dur1ng cold shutdowns.
2.
Provhde the technical ]ust1f1cathon for not exerc1slng valves 1SI-136 and 137 during cold shutdowns.
3.
Do the follow1ng valves perform a pressure boundary 1solat1on funct1on to protect the low pressure p1p)ng on the suct1on of the centrifugal charg)ng pumps from be1ng overpressur1zed?
1SI-8 1SI-9 1SI-72 1SI-73 1SI-81 1SI-82 1SI-104 1SI-105 1SI -127 1SI-136 1SI-128 1SI-137 1SI-10 1SI-74 1SI-83 1SI-106 1SI-129 1S1-138 4.
How are valves 1SI'-249,
- 250, 251,
- 252, 253, and 254 ver1f1ed to full-stroke exerc)se open during testing at cold shutdowns?
Is des1gn acc1dent flow ver1f1ed through these valves or
$ s some other method used to ascertain valve drisk pos1t1on dur1ng test1ng?
5.
Rev>ew the safety related function of the follow>ng valves to determ1ne 1f they should be included 1n the IST program and be tested
$ n accordance with the Code.
Valve PAID Locat1on 1RC-176 1RC-175 1RC-174 2165-S-1309 A-9 2165-S-1309 B-9 2165-S-1309 B-9 6.
How 1s a full-stroke exercise of valves lSI-320 and 321 ver1f1ed dur1ng the quarterly testing?
7.
How 1s the valve posit1on 1nd)cat1on ver1f>ed for valves lSI-300 and 301 which are located inside valve encapsulat1on chambers?
0.
Component Cool1n Water S stem l.
Provide a more detailed techn1cal )ustification that demonstrates that
'esting the following valves 1n pa1rs can verify the ab111ty of these valves to perform the1r safety related funct1on.
The Code requires 1ndividual test1ng because 1f valves are back seat tested 1n pa1rs,
-ne v"',ve 1n the pa1r could fail and not be able to perform its safety funct1on and this could go undetected.
l CC-1 l 8 lCC-1 l 9 1 CC-215 lCC-216 1CC-226 lCC-227 lCC-237 lCC-238 l CC-306 lCC-307 2.
Prov1de a more deta1led techn1cal Justification for not exerc1s1ng the valves referenced in relief requests R-lD, R-l3, and R-29 dur1ng cold shutdowns.
If it 1s determined that an adequate )ustification ex1sts for not exercising these valves dur1ng each cold shutdown, then these va'rves should be exerc1sed dur1ng every cold shutdown where cond1t1ons permi t.
P.
Res1dual Heat Removal S stem l.
How are check valves lRH-34 and 70 verified to full-stroke open dur1ng quarterly valve testings Is des1gn acc1dent flow established through these valves or 1s some other means used to determ1ne valves disk pos1ti on7 g.
Conta1nment HVAC S stem l.
Prov1de a more deta1led techn1cal ]ustificat1on for not exercising valves CB-Vl, CB-V2, and CH-Vl quarterly duding power operat1on;
- also,
>1 prov1de a )ustification for not exercis1ng these valves dur1ng cold shutdowns.
The alternate test paragraph for rel1ef request R-l should be expanded to explain how these valves will be exercised.
2.
PUHP Tf.STING PROGRAN l.
Table IWP-3100-l requires that proper pump lubr1cant level or pressure be observed during pump test1ng.
This test quant1ty has not been addressed in the Shearon Harr1s IST program.
Is th1s test quant1ty be1ng observed as requ1red?
If there are any except1ons, provide the
]usti fi cat ions.
2.
Provide a more deta1led technical Justification for not measuring pump bearing temperatures.
What 1nformation or data supports the conclus1ons drawn.1n rel1ef request R-1?
3.
Pump note No.
2 1nd1cates that observ1ng the diesel generator fuel o11 transfer pump ref1111ng the day tank demonstrates proper pump operab111ty.
Unless the time to change the day tank level a.g1ven amount 1s measured and that informat1on 1s equated to pump flow rate, th1s alternate test1ng method 1s not adequate s1nce 1t does not allow for the detect1on of pump degradat1on.
4.
Is pump v1brat1on measured 1n un1ts of d1splacement (mils) or in velocity un1ts
( in./sec)?
If measured in un1ts of veloc1ty, provide the allowable ranges for pump vibrat1on for our rev1ew.
10