ML18004A386

Responds to NRC 860610 Request for Addl Info Re Pump & Valve Testing Program.One Oversize Drawing Encl

ML18004A386
Person / Time
Site:	Harris
Issue date:	07/31/1986
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML18004A387	List: ML18004A386 ML18004A388
References
NLS-86-262, NUDOCS 8608050260
Download: ML18004A386 (43)

Text

REQULAT INFORNATION DISTRIBUTION "STEN (R IDS)

ACCESSION NBR: $ 608050260 DOC. DATE: 86/07/31 NOTARIZED: NO DOCKET I FACIL: 50-400 Shearon Harris Nuclear Power Plant> Unit 1> Carolina 05000400 AUTH. NANE AUTHOR AFFILIATION ZlNNERNA'N> S. R. Carolina Power Zc Light Co.

REC IP. NAl'lE 'ECIPIENT AFFILIATION DENTQN> H. R. Of fice of Nuclear Reac toT Regulation> Direc tor (post 851125 SUB JECT: Responds to NRC 860610 request for addi in fo re pump i% valve testing program. One oversize dratoing encl.

DISTRIBUTION CODE: 8001D COPIES RECEIVED: LTR ENCL SI ZE:

TITLE: Licensing Submittal: PSAR/FSAR Amdts Ec Related CorT espondence NOTES: Application for permit rene'!al filed. 05000400 RECIPIENT Co< IES RECIPIENT COPIES ID CODE/NAl'lE LTTR ENCL ID CODE/NANE LTTR ENCL P(JR-A EB 1 P4JR-A EICSB 2 2 PNR-A FOB 1 PMR-A PD2 LA PAR-A PD2 PD BUCKLEY> 8 01 2 2 PNR-A PSB 1 PWR-A RSB INTERNAL. ADl'l/LFl'lB 0 ELD/HDS1 1 0 IE FILE 1 IE/DEPER/EPB 3h 1 IE/DGAVT/GAB 21 1 1 NRR BMR ADTS 0 NRR PMR-8 ADTS 0 NRR QE> l'i. L 1 1 NRR/DHFT/NTB 1 "L 1 RQN2 3 3 I /MIB 1 0 EXTERNAL: BNL(AMDTS QNl Y) Dl'lB/DSS (ANDTS)

LPDR 03 NRC PDR 02.

NSIC 05 PNL QRUEL> R TOTAL NUNBER OF COPIES REQUIRED: LTTR 30 ENCL 25

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SKK Carolina Power 8 Light Company JUL S ~ ~9S6 SERIAL: NLS-86-262 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO. 1 - DOCKET NO.50-000 PUMP, AND VALVE TESTING PROGRAM ADDITIONALINFORMATION

Dear Mr. Denton:

Enclosed is CPotrL's response to your staff's request for the subject additional information. The additional information is presented in an NRC question/CPdcL response form and follows the structure of the requests in the June 10, 1986 letter from B. C.

Buckley to E. E. Utley. Many of the responses indicate that program changes addressing the questions have already been incorporated in a draft revision of the program. The revised program will be made available to you when it is finalized.

If you have any questions, please contact Mr. James D. Kloosterman at (919) 836-8055.

Yours very truly, f 8608050260 860731 PDR ADOCIro 05000400 I A PDR S.. Zi merman ager Nuclear icensing Section SDC/vaw (0011SDC)

Enclosures cc: Mr. B. C. Buckley (NRC)

Mr. G. F. Maxwell (NRC-SHNPP)

Dr. J. Nelson Grace (NRC-RII)

Mr. C. Ransom (EGRG)

Wake County Public Library Po QA.

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e 1g t General uestions and Co nts (Cont'd) Maximum stroke times are being developed based on actual observed stroke times obtained during pre-operational testing, manufacturers data, and technical specifications. Technical Specification values are used only as an absolute "not to exceed" value. Where actual stroke times are much less than Technical Specification values, the limiting value of maximum stroke time will be determined from actual observed values, but at no time will maximum stroke times exceed Technical Specification values. A plant criteria has been developed for determining values of maximum stroke times from the pre-operational measured values as follows: Stroke time greater than 10 seconds 2 X baseline A) B) Stroke time greater than 2 seconds - 3 X baseline but equal to or less than 10 seconds C) Stroke time equal to or less than 2 seconds 3 seconds Valves that perform a containment isolation function should be included in the IST Program and be categorized "A" or "A/C", as appropriate. Are all valves that perform a containment isolation function in the IST Program? The Program Plan has been revised to include all containment Isolation valves as Category "A" or "A/C". Valves considered containment isolation valves are all those valves in 'SHNPP FSAR Table 6.2.0-1 for Appendix J, Type C, local leak-rate testing. If the Appendix 3, Type C, tested valve list changes, the Program Plan will automatically be changed to agree with Table 6.2.0-1.

5. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50 Appendix 3, however, the licensee must comply with the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs of Section XI, IWV-3026 and 3027.

The program has been revised to include all valves in the Appendix 3, Type C, test as Category A and substitutes the Appendix 3, Type C, test for Articles ""'" program IWV3020 "through IWV-3025. Leakage rate analysis and corrective actions as required by IWV-3026 and 3027 will be performed.

6. Valves that serve both a pressure boundary isolation function and a containment isolation function must be leak tested to both the Appendix 3 and the Section XI requirements. Is this the case at SHNPP?

The Program Plan has been revised to state that valves that perform both a containment isolation function and a pressure isolation function will be tested to the requirements of both Appendix 3 and Section XI.

7. 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 analyses through the valve would be an adequate demonstration of the full-stroke requirements. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some (0862NE L/vaw )

General uestions and Co nts (Cont'd) 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. Does the SHNPP IST Program conform to this staff position. The Program Plan considers any test that uses a flow rate less than the design flow rate as being a partial-flow test. (0862NEL/vaw ) B. MAIN STEAM SYSTEM

1. How are valves 1MS-71 and 73 verified to full-stroke open quarterly?

Valves 1MS-71 and 73 are in the main steam line to the auxiliary feedwater pump turbine. Forward flow operability is verified during quarterly pump testing. Upstream and downstream measurements (PT 0308 B, C and PT 0030) will indicate excessive pressure drop if valves do not fully open during turbine operation. In addition, a relief request has been prepared to disassemble and visually inspect these valves in lieu of verification of reverse flow closure. One valve will be disassembled and visually inspected in lieu of verification of reverse flow closure. A valve will be disassembled and visually inspected at refueling. The alternate valve will be disassembled and visually inspected at the next refueling and valve inspections alternated during subsequent refuelings. Failure of a valve to pass inspection will initiate disassembly and inspection of the alternate valve. (0862NEL/vaw ) C. FEEDWATER

1. What is the safety-related function of the following valves?

IFW-133 IFW-100 IFW-159 IFW-307 IFW-191 IFW-198 IFW-217 IFW-313 IFW-209 IF W-256 IFW-277 IFW-319 IFW 133~ 100~ 191~ 198~ 209~ 256 These feedwater flow control valves do not fall strictly within the criteria used for inclusion in the IST Program. However, because of the importance of the valves in providing redundancy to the system isolation valves (IFW-159, 217, 277, 60, 81, 102) in certain scenarios (see FSAR Section 10.0.7.2), these valves will be included in the program. IFW-I59, 217, 277 These are feedwater isolation valves which close in 5 seconds, or less, on an isolation signal. These valves are equipped with 90-percent (open) partial-stroke exercisers for testing during full flow operation. IFW-307, 313, 319 These are feedwater isolation bypass line valves. These valves are safety related and, therefore, close on an isolation signal. (0862NEL/vaw ) D. AUXILIARY<PEEDWATER SYSTEM

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?

IAF-50 1AF-136 IAF-16 1AF-68 ICE-36 1AF-73 lAF-102 1AF-31 1AF-87 ICE-06 IAF-92 lAF-108 lAF-117 1AF-106 ICE-56 To verify forward flow operability of the series check valves in the auxiliary feedwater discharge lines, it is necessary to establish full flow through the valves into the Steam Generators. It has been determined that a potential for thermal shock induced cracking of the feedwater nozzles exists if cold condensate water is injected into the hot Steam Generators during normal operation. In addition, to test auxiliary feedwater during normal operation would require starting the auxiliary feedwater system and securing the normal feedwater flow. The switch over from normal to auxiliary feedwater flow would have an adverse effect on Steam Generator water level control and could result in a forced plant shutdown. 1AF-16, 31, 50, 73, 92 Motor driven auxiliary feedwater pump discharge line to Steam Generator series check valves can only be forward flow operability tested by injecting full flow into the Steam Generators. The motor driven auxiliary feedwater pumps are in operation at cold shutdown during water chemistry adjustment prior to initiating normal feedwater flow. At this time, there is enough Steam Generator capacity to perform a full forward flow operability verification. In addition, the Program Plan has been revised to perform quarterly partial-flow testing of the motor-operated pumps using the small diameter pump recirculation line and full flow pump operability testing at long duration cold shutdowns. For cold shutdowns of seven days or longer, the Steam Generators are drained down for wet lay-up. During refilling of the Steam Generators, there is sufficient time to perform full Section XI testing of the pumps. For short duration cold shutdowns, there will be insufficient capacity to operate the pumps long enough to fully comply with Section XI, but testing will be performed as much as possible without impacting plant startup. 1 AF-117, 136, 102, 108 Steam driven auxiliary feedwater pump discharge line to Steam Generator series check valves can only be forward flow operability tested by injecting full flow into the Steam Generators. The only source of steam to the steam driven turbine is from the Main Steam System. To operate the turbine requires that the Steam Generators be producing sufficient steam to drive the turbine. Control of Steam Generator water level when producing steam is much more critical than during the refilling process, where the motor-operated pumps are tested. To perform flow testing during steam production would have a significant impact on Steam Generator water level control on all three Steam Generators, would require a significant amount of start-up time and could result in a forced plant shutdown. The Program Plan has been revised to perform full forward flow operability testing of these valves and full steam driven pump testing when the impact on plant operations will be minimized (i!e, in conjunction with refueling). These valves are considered to be in the low (0862NEL/vaw ) ~ ~ RP%L failure rate category, and as such, the optimum test frequency is in the range of 3 to 27 months. Refueling intervals of 12 to 20 months are within this range and delay of testing to refueling should not have a significant impact on the test program. 1AF-68, 87, 106 Steam Generator auxiliary feedwater inlet check valves are full forward flow operability tested during normal operation. These lines are in service during normal feedwater flow with approximately 18 percent of feedwater flow through them into the Steam Generators. Verification of full flow is performed by subtracting the flow measured at flow element FT-2003 from that measured at FT-2005. 1CE-36, 06, 56 Condensate inlet to the auxiliary feedwater pump check valves can only be full forward flow operability verified during auxiliary feedwater pump operation. 'The Program Plan has been revised to delay testing to cold shutdown when the pumps are in operation. In addition, a relief request has been prepared to perform disassembly and visual inspection on one check valve at refueling in lieu of verification of reverse flow closure. Failure of the valve to pass visual inspection will initiate disassembly and inspection of the other two valves. lAF-50, 73, 92, 117, 136, 102, 108 A relief request has been prepared for these series check valves to not perform individual valve verification of reverse flow closure. Each flow path from the auxiliary feedwater pumps to the feedwater lines includes two check valves in series. Each two check valve set functions as a single unit to prevent reverse flow from the feedwater lines back through the pumps. Reverse flow is prevented as long as either check valve is closed. Each line is continuously monitored by alarmed temperature sensors. Thus, if both valves fail to close an over temperature alarm will occur. The lack of an alarm verifies that at least one of the series valves is closed and that their design function is being accomplished. If an overtemperature alarm indicated failure to close, the appropriate valves will be identified an 'orrective action initiated. (0862NEL/vaw ) 0 ~ ~ Y' E; p1 4 E. SERVICE WATER SYSTEM

1. How is it verified that valves 1SW-101, 103, 152, 150, 163, and 165 back seat to block flow in the reverse direction during quarterly valve testing?

1SW-101, 103, 152, 150, 163, 165 The Program Plan has been revised to remove verification of reverse flow closure. These are small (I-I/2") check valves from the service water headers to the inlet of the charging pump oil coolers. They have been installed to prevent cross-flow between the operating and non-operating 30-inch Service Water headers. Because of their relative small size, cross-flow between the headers through these lines would not be large enough to cause significant reduction in Service Water System operating capacity. As such, reverse flow closure is considered to be desirable, but not essential, for safety-related system operation.

2. Provide the technical justification for not exercising valves 1SW-231, 200,.and 202, and not back seat testing valve ISW-233 during cold shutdowns (relates to Relief Request No. R-26).

1SW-231, 200, 202 These valves have been added to the Program Plan and are fully Section XI tested quarterly. 1SW-233 This is a simple check valve located in the safety-related portion of the nonsafety-related Normal Service Water System which supplies the nonsafety-related containment fan cooler line. Its only safety-related function is as a leak-tight containment isolation barrier in the closed position. The only way to verify closure is by leak testing which is beyond the scope of normal cold shutdown testing. The valve is not equipped with a position indicator and the required test taps used for seat leak testing are located inside the containment which has restricted access during normal operations and cold shutdown. It has been determined that optimum test interval is in the range of 3 months to 27 months and refueling intervals occur every 12 to 20 months which is in the optimum range for operability testing. The code requires quarterly testing, but allows extension to cold shutdown if it is impractical during normal operations. Since cold shutdowns can occur at intervals up to refueling outages, changing the test interval from quarterly to refueling does not differ significantly from that Code allowed change from quarterly to cold shutdown testing.

3. Provide the technical justification for, not exercising valve 1SW-50 during cold shutdowns (Relates to Relief Request No. R-21).

1SW-50 The Normal Service Water to Emergency Service Water headers cross-tie check valve has been removed from the Program Plan. It is upstream of the motor operated isolation valves (ISW-39, 00) and is in the non-classed portion of the non-safety-related Service Water System. The motor operated valves close on the system isolation signal and are included in the test program. Since system isolation occurs at the motor operated valves, this check valve performs no safety-related function and has been removed from the program. (0862NE L/vaw ) CONTAINMENTSPRAY SYSTEM How is the valve position indication verified for ICT-102 and 105 which are located inside valve encapsulation chambers? ICT-102, 105 The valve encapsulation chambers are equipped with removable access plates which will be removed and position indication verification performed as specified in the Code. How are check valves ICT-62 and 65 full-stroke exercised quarterly? Could exercising these valves with flow possibly contaminate RWST water with chemicals? ICT-62,65 These check valves in the lines from the containment spray additive tank to the eductors are tested quarterly during containment spray pump testing. A test line, with installed flow element, from the RWST has been included to provide a source of clean water for testing of these valves and the eductors without injecting NaOH into the system or RWST. How are valves ICT-53 and 91 verified to full-stroke exercise when tested during refueling outages? Provide a more detailed technical justification for not exercising these valves during cold shutdowns. ICT-53, 91 These inside containment simple check valves are safety related in both the forward flow (for containment spray initiation) and the reverse direction (for containment isolation). Reverse flow closure can only be verified (see response to ISW-233, Question No. E-2) at refueling during valve leakage testing. There are no test lines installed and any water pumped through the system to verify forward flow 'operability would result in injecting large quantities of water into the containment which would cause extensive damage to safety-related equipment located inside the containment structure. Using air as a test medium is not practical since large segments of the system would have to be drained and high pressure air pumped into the system through a small diameter test connection, the amount of air that could be injected using this method would be insufficient to verify full stroke opening of the valve. Also, injection of high pressure air into the containment could result in an overpressurization of the containment structure. A'relief request has been prepared to perform disassembly and visual inspection of one valve at refueling. Valve inspections will alternate for subsequent refuelings. Failure of the inspected valve to exhibit full stroke open capability will initiate inspection of the other valve. Can valves ICT-11 and 12 be full-stroke exercised quarterly without the possibility of contaminating the RWST water with unwanted chemicals? ICT-I I, 12 A test line has been installed to the RWST to perform quarterly testing without injecting chemicals into the system during test or contaminating the RWST. (0862NE L/vaw ) ~~ ,1 ,f Containment S ra S st

5. Do the vacuum breakers (location A-7 and A-3) on the Containment Spray Additive Tank perform any safety-related function?

Vacuum Breakers The vacuum breakers performed a safety-related function and will be tested in accordance with Section IWV-3620.

6. Is design accident flow established through valves 1CT-27 and 72 during quarterly testing to verify a full-stroke exercise of the valves?

1CT-27, 72 Verification of forward flow operability is done quarterly with pump testing by pumping through the 6-inch test line back to the RWST. The safety-related system design flow rate is 2275 GPM. The plant test procedure requires verification of a recirculation flow of 2025 GPM and a flow of 250 GPM through the minimum flow line. 10-(0862NEL/vaw ) G. POST ACCIDENT SAMPLING SYSTEM

l. Is operability of the post-accident sampling system a safety-related function at SHNPP? If so, all valves that are required to change position in order for the system to perform its function should be included in the IST Program and be tested in accordance with the Code.

Operation of the post-accident sampling system is not a safety-related function at SHNPP. Only the containment isolation valves perform a safety-related function and are included in the Program Plan. ll (0862NEL/vaw ) H. RADIATIONMONITOR SYSTEM

1. What is the safety-related function of valves 1SP-16, 28, 916, and 918?

1SP-16, 28, 916, 918 The system has been modified to remove the sample return block valves. The present design consists of four containment isolation valves (1SP-12, 915, 917,901) and two block valves in each of the radiation monitor inlet and outlet lines (1SP-16, 916, 918, 939. Valve numbers 1SP-16, 916, 918 were reassigned from the deleted sample return block valves to the radiation monitor inlet and outlet line block valves.) 1SP-12, 915, 917, 901 Containment isolation valves are quarterly operability tested and seat leak tested at refueling. 1SP-16, 916, 918, 939 Radiation monitor inlet line block valves (1SP-16, 916) and outlet block valves (1SP-918, 939) are quarterly operability tested. (0862NEL/vaw ) I. DIESEL GENERATOR SYSTEM

1. Review the safety-related function of the following valves to determine if they should be included in the IST Progiam and be tested in accordance with the Code.

VALVE PAID LOCATION VALVE PAID LOCATION IEA-4 S-0633 C-2 ISW-757 S-0633 C-8 IEA-19 S-0633 D-2 IS V/-776 S-0633 C-18 IEA-35 S-0633 C-12 IEA-30 S-0633SOI B-6 IEA-50 S-0633 D-12 IEA-45 S-0633SOI A-17 , IEA-14 S-0633SOI A-6 IEA-46 S-0633SOI A-17 IEA-15 S-0633SOI A-6 IEA-60 S-0633SOI B-17 IEA-29 S-0633SOI B-6 IEA-61 S-0633SOI B-17 I EA-4, 19, 35, 50 D. G. Air Compressor to Air Receiver check valves have been added to the program for quarterly verification of reverse flow closure. I EA-14, 15, 29, 30, 45, 46, 60, 61 These valves are located on the diesel generator skid mounted package and are outside the scope of Section XI testing. They are adequately tested during diesel generator testing. ISV/-757, 776 These valves are isolated by locked manual valves and perform no safety-related function. (0862NEL/vaw )

3. DEMINERALIZEDWATER SYSTEM

1. For all of the valves covered by Relief Request No. R-33, provide a more detailed technical justification for not exercising the valves quarterly and the justification for not exercising them during cold shutdowns. What are the estimated radiation fields in the vicinities of these valves and what dose rates would be received by the operators while performing the required testing?

1DW-65; ISA-82; IFP-357, 309; 1RC-160; 1SI-182, 290, 233 These are all inside containment simple check valves whose safety-related function is to provide a leak-tight containment isolation boundary. Response is basically the same as for ISW-233 (Question No. E-2). (0862NE L/vaw ) K. INSTRUMENT AIR SYSTEM

1. Provide a more detailed technical justification for not exercising valves IIA-216 and 220 during cold shutdowns.

1IA-216 The Program Plan has been revised to perform testing at cold shutdown. 1IA-200 Valve is an inside containment simple check valve whose only safety-related function is provide a leak-tight containment isolation function. Response is basically the same as for 1SW-233 (Question No. E-2). (0862NE L/vaw ) r 1 ft Il L. REACTOR COOLANT SYSTEM I. There is an apparent conflict between the alternate test paragraph in Relief Request No. R-17 and the basis for relief. The basis states that the pressurizer PORVs cannot be exercised during cold shutdowns and the alternate test states that they will be exercised during cold shutdowns. The staff position is that the PORVs should be exercised on a cold shutdown frequency. 1RC-110, 116, 113 These are the Pressurizer Power-Operated Relief Valves. Valves IRC-110 and 116 are part of the pressurizer overpressure protection system which is provided to prevent a RCS overpressure condition when solid conditions exists in the pressurizer. Plant Technical Specifications (3.0.9.0) require that in mode 0 the RCS be depressurized and vented, or that the two power-operated relief valves, with proper setpoints, be operable. Since exercising the valves open will not disable the valves ability to relieve an overpressure condition, valve exercising will be performed at cold shutdown when the pressurizer is not in a solid condition. '. 'Provide a more detailed technical justification for not exercising 1RC-900, 901, 902, 903, 900, and 905 quarterly. 1RC-900, 901, 902, 903, 900, 905 These are the Reactor Vessel head and Pressurizer vent line block valves." The Program Plan has been revised to perform quarterly testing of these valves. 16-(0862NE L/vaw ) M. CHEMICAL AND VOLUME CONTROL SYSTEM

1. Provide a more detailed technical justification for not exercising the following valves during cold shutdowns (Refer to Relief Request Nos. R-0 and R-18). Provide the reasons that reactor coolant pumps cannot be stopped during cold shutdown to allow for valve testing.

ICS-301 ICS-070 ICS-300 ICS-382 ICS-071 ICS-385 ICS-023 ICS-072 ICS-026 ICS-301, 382, 023, 070, 072 Exercising these valves during normal operation or at cold shutdown results in a loss of normal seal water to the RCS pump seals. If seal water is stopped, reactor coolant normally contains a high particulate matter concentrate which is carried with the reactor coolant inleakage and contaminates the seals. Westinghouse has studied this problem and recommends (see Westinghouse document NSD TB-7515, 1978) that seal water flow be maintained at cold shutdown as well as during normal operation. ICS-300, 385, 026, 071, 077 These valves are inside containment simple check valves whose only safety-related function is to provide a leak-tight containment isolation boundary. Response is basically the same as for ISW-233 (Question No. E-2).

2. Could exercising valve ICS-I, 2, 11, 238 and 092 quarterly during power operations result in loss of pressurizer level control or result in thermal shock to the regenerative heat exchanger?

ICS-I, 2 These RCS normal letdown to CVCS block valves have been removed from the Program Plan. Isolation of normal letdown is not a safety-related function. Downstream valves ICS-7, 8, 9, 11 are automatically actuated containment isolation valves and are in the test program. Since the valves perform no safety-related function they have been exempted from the program as operating convenience valves. ICS-I I, 238 These valves are in the normal letdown and charging lines to the RCS. Exercising of these valves during normal operation would disrupt normal RCS charging flow which could decrease significantly the capability of the CVCS to provide proper boration ratio. Failure of either valve in the closed position coincident with normal charging flow could result in a high RCS level trip. Because of these reasons and a potential for thermal shock to the regenerative heat exchanger, the Program Plan has been revised to delay valve testing to cold shutdown. (0862NEL/vaw ) %1 Chemical and Volume Con S stem (Cont'd) 1CS-092 This valve is in the normal charging line to the RCS and is exercised quarterly by diverting charging flow through the alternate charging line during testing. In this way there is no potential for loss of pressurizer level control or thermal shock to the regenerative heat exchanger. 30 Is credit taken for the use of auxiliary pressurizer spray to take the reactor from normal operating conditions to cold shutdown as described in Branch Technical Position RSB 5-1? If so, then valves 1CS-087, 088, 091 perform a safety-related function and should be included in the IST Program and be tested in accordance with the Code. 1CS-087, 088, 091 SHNPP does not take credit for the use of the auxiliary pressurizer spray to take the Reactor from normal operating conditions to cold shutdown. The PORVs and control circuitry have been designed for the cold overpressurization condition. The normal spray and pressurizer PORVs provide functional diversity and redundancy for pressure reduction capability in a post-accident condition., Loss of the auxiliary spray valves would provide no compromise to safety-related operation. Do the following valves perform a pressure boundary isolation function to protect the low pressure piping on the suction of the centrifugal charging pumps from being overpressurized? 1CS-097 1CS-088 ICS-500 1CS-091 1CS-088, 091, 097, 500 Only those valves designated as pressure isolation valves in Table 3.0-1 of plant Technical Specification are included in the program as pressure isolation valves. These four valves are not included in Table 3.0-1. Any change to the list of pressure isolation valves in the Technical Specifications will automatically be reflected in the Section XI testing program.

5. Provide a more detailed technical justification for not exercising valves 1CS-165 and 166 during cold shutdown.

1CS-165, 166 also 1CS-291, 292 The Volume Control Tank discharge valves (1CS-165, 166) and the BWST to CVCS Charging Pump inlet header block valves (1CS-291, 292) are interlocked such that both sets of valves cannot be open at the same time. To exercise the valves would result in BWST water being injected into RCS and RCS pump seals by the charging pumps. RCS pump seal flow is required at both normal operation and cold shutdown (see response to 1CS-301, Question No. M-I). Exercising at either time would affect RCS boron concentration and inlet high boron concentrations into the RCS pump seals, which could cause seal damage and shorten service life.

6. Provide the technical justification for not exercising valve 1CS-290 during cold shutdowns. If this valve cannot be full-stroke exercised during cold shutdowns, can it be partial-stroke exercised?

(0862NEL/vaw ) 1' '! ~ 4~ Chemical and Volume Con S stem (Cont'd) ICS-290 To verify forward flow operability would require opening the downstream block valves (1CS-291, 292) to the charging pump header. Exercising of 1CS-291, 292 has been delayed to refueling (see response to ICS-291, Question No. M-5). Since the only way to verify forward flow operability is by passing full flow through this valve it also has been delayed to refueling. Partial-stroke exercising would result in the same seal contamination problems as full-stroke exercising.

7. How is a full-stroke exercise of valves 1CS-178, 192, and 206 verified during quarterly valve testing? Is design accident flow established through these valves quarterly?

1CS-178, 192, 206 These charging pump discharge check valves cannot be verified for full flow operability quarterly. Normal operating charging flow is automatically controlled by downstream flow control valve (1CS-231) in response to RCS operating conditions. To inject full flow into the RCS during normal operation would result in undesirable RCS boron concentrations and system pressure, temperature and level transients. Full-stroke exercising these valves at cold shutdown would result in RCS pressure and level transients due to limitations on letdown capability. Valves will be partial-stroke exercised quarterly and verification of full forward flow operability performed at r efueling.

8. Provide a legible copy of PdclD 2165-S-1306 for our review.

A legible copy of drawing 2165-S-1306 is being forwarded for review.

9. Is any credit taken for boric acid gravity feed path? If so, all appropriate valves should be included in the IST Program and be tested in accordance with the Code.

There is no credit taken for the boric acid gravity feed path. The system design is such that any pressure in the Volume Control Tank will prevent any gravity flow. (0862NE L/vaw ) SAFETY IN3ECTION SYSTEM How is a full-stroke exercise of valves 1SI-81, 82, and 83 verified during testing? Is design accident flow established through these valves? Provide the justification for not partial-stroke exercising these valves during cold shutdowns. 1SI-81, 82, 83 The Program Plan has been revised to verify full forward flow operability at cold shutdown. Full flow will be verified by measuring RHR loop flow. Safety-related system operation requires a flow rate of 7000 GPM and pump operation will verify at least a 7000 GPM flow rate. Provide the technical justification for not exercising valves 1SI-136 and 137 during cold shutdowns. 1SI-136, 137 Program Plan has been revised to verify forward flow operability at cold shutdown. I Do the following valves perform a pressure boundary isolation function to protect-the low pressure piping on the suction of the centrifugal charging pumps from being overpressur ized? ISI-8 1SI-72 1SI-81 ISI-100 1SI-127 1SI-136 ISI-9 1SI-73 1SI-82 1SI-105 1SI-128 1SI-137 1SI-10 ISI-70 1SI-83 1SI-106 1SI-129 1SI-138 None of the listed valves are considered to be pressure isolation valves nor are they included in Table 3A-I of Plant Technical Specifications (see response to ICS-097, Question No. M-0). How are valves ISI-209, 250, 251, 252, 253, and 250 verified to full-stroke exercise open during testing at cold shutdowns? Is design accident flow verified through these valves or is some other method used to ascertain valve disk position during testing? ISI-209, 250, 251, 252, 253, 250 The Accumulator Tanks are isolated from the RCS by these normally closed check valves. Each accumulator is charged with a nitrogen blanket at approximately 650 psig which is insufficient to inject into the RCS during normal operations. To exercise these valves to their full open position at cold shutdown would inject approximately 925 cubic feet of high boron content water into the RCS. Letdown capacity from the RCS is not adequate to allow this volume to be injected into the RCS and doing so could result in a cold overpressurization of the RCS. Dumping the full accumulator inventory into the RCS at refueling could flush large amounts of crud into the RCS and clean-up systems. High particulates in the RCS at refueling reduces visibility for refueling operations and generates large amounts of waste which could lengthen the outage and increase personnel exposure. The Program Plan has been revised to perform a partial-flow operability test at cold shutdown. In addition, one valve will be disassembled and visually inspected at each refueling. Valve inspections will alternate for subsequent refuelings. Failure of a (0862NEL/vaw ) Eafet In'ection S stem (C d) valve to exhibit full-stroke open capability will initiate inspection of the remaining valves.

5. Review the safety-related function of the following valves to determine if they should be included in the IST Program and be tested in accordance with the Code.

VALVE PAID LOCATION 1RC-176 2165-S-1309 A-9 1RC-175 2165-S-1309 B-9 1RC-170 2165-S-1309 B-9 SHNPP does not consider the nitrogen supply to the PORV Accumulators to be safety related and has not included these valves in the Section XI valve test program.

6. How is a full-stroke exercise of valves 1SI-320 and 321 verified during the quarterly testing?

.1SI-320, 321 These are 10-inch check valves in the RHR pump suction line from the RWST and are full forward flow operability verified during quarterly RHR pump testing. The plant test procedure requires a test flow rate of at least the system safety-related design flow rate.

7. How is the valve position indication verified for valves 1SI-300 and 301 which are located inside valve encapsulation chambers?

1SI-300, 301 The valve encapsulation chambers are equipped with removable access plates which will be removed and position indication verification performed as specified in the Code. (0862NEL/vaw ) F O. COMPONENT COOLING WATER SYSTEM I. Provide a more detailed technical justification that demonstrates that testing the following valves in pairs can verify the ability of these valves to perform their safety-related function. The Code requires individual testing because if valves are back seat tested in pairs, one valve in the pair could fail and not be able to perform its safety function and this could go undetected. ICC-118 ICC-215 ICC-226 ICC-237 ICC-306 ICC-119 I CC-216 ICC-227 ICC-238 ICC-307 ICC-118, 119 Only one check valve is required to isolate the non-classed sampling system from the CCW. If either valve closes on, flow reversal, system requirements are satisfied. The second valve has beerr installed as a back-up to the safety-related valve as an operating convenience. Testing the two valves as a unit is equivalent to testing a single check valve in this location. Since only one of the two valves is required to close, and because there are no system provisions for individual valve closure ~ verification, they will be tested as a unit and, if the unit fails to exhibit reverse flow closure, both valves will be disassembled and repaired. ICC-215, 226, 237 These valves have been removed from the program. Downstream check valves ICC-216, 227, and 238 are in the high pressure piping portion of the system and provide protection of the low, pressure piping if an RCS pump thermal barrier leak occurs. Valves 215, 226, and 237 are in the low pressure piping portion of the piping and perform no safety-related function. ICC-216, 227, 238 The Westinghouse RCS Pumps must have cooling water to the bearing oil coolers and thermal barriers at all times when the RCS temperature is above 200'F, and there are no installed taps or position indicators that could be used to verify reverse flow closure. Any possible test involves verification of these and associated upstream nonsafety-related check valves as a single unit. To verify reverse flow closure at cold shutdown would involve draining large segments of the system and providing an alternate source of pressurized water inside the containment which may not be accessible during cold shutdown. Also, this test would involve waste processing of the water removed. for testing and of the water used for testing. This type of testing would involve an excessive amount of time and personnel and could cause delays in plant startup. The Program Plan has been revised to perform disassembly and visual inspection of one valve at refueling. The alternate valves will be done during subsequent refuelings. Failure of a valve to pass visual inspection will result in disassembly and inspection of the other two valves. ICC-306, 307 These 3/0-inch check valves in the CCW line from the Gross Failed Fuel Detector have been removed from the Program Plan as nonsafety related. Valves ICC-300 and 305 on the inlet to the detector close on an isolation signal, so if the detector maintains its integrity, reverse flow is not important. If the detector were to loose integrity, the line is an orificed 3/0-inch line and any leakage from CCW would not / (0862NE L/vow ) I I Com onent Coolin Wate em (Cont'd) be great enough to degrade system safety-related operating capability. Also, there are manual in-line valves that could be used to isolate the detector for long-term operation.

2. Provide a more detailed technical justification for not exercising the valves referenced in Relief Request Nos. R-10, R-13, and R-29 during cold shutdowns. If it is determined that an adequate justification exists for not exercising these valves during cold shutdown, then these valves should be exercised during every cold shutdown where conditions permit.

1CC-207, 208, 209, 251, 297, 299 These are the containment isolation and block valves in the RCP thermal barrier and bearing oil cooler lines. A loss of cooling water for more than a few minutes could result in extensive damage to the reactor coolant pumps. Westinghouse Document 1B5710-100-07A states that cooling water must be provided to the pumps at all times when the RCS. temperature is above 200'F. Because of local temperature variations in the RCS at RCS temperatures near 200'F, at least one RCP may be kept in operation during short duration cold shutdowns where the RCS temperature is'maintained near 200'F. It is felt that under these conditions stopping cooling water to the operating pump could contribute to pump degradation and result in unnecessary pump repairs. The Program Plan has been revised to perform testing at cold shutdown, if all reactor coolant pumps are secured. 1CC-215, 216, 226, 227, 237, 238 See response to O. Component Cooling Water Question No. l. 1CC-211, 250, 298 These are inside containment simple check valves whose only safety-related function is to provide a leak-tight containment isolation barrier. See response to ISW-233 (Question No. E-2). (0862NE L/vaw ) P. RESIDUAL HEAT REMOVAL SYSTEM

1. How are check valves IRH-30 and 70 verified to full-stroke open during quarterly valve testing? Is design accident flow established through these valves or is some other means used to determine valve disk position?

1RH-30, 70 Full forward flow operability of these 10-inch RHR pump discharge check valves is verified during quarterly RHR pump testing with pump test flow through 8-inch pump test line back to the RWST. The plant test procedure requires a test flow rate of at least the system safety-related design flow rate. (0862NE L/vow ) hq, hP' Q. CONTAINMENT HVAC SYSTEM

l. Provide a more detailed technical justification for not exercising valves CB-V1, CB-V2, and CM-Vl quarterly during power operation; also, provide a justification for not exercising these valves during cold shutdowns. The alternate test paragraph for Relief Request No. R-'1 should be expanded to explain how these valves will be exercised.

CB-V 1, V2; CM-V1 These are inside containment simple check valves and do not have position verification capability. To verify forward flow operability'using system fluid would required injecting large quantities of air into the containment and would result in a containment overpressurization condition. The only practical method to verify forward flow operability is by mechanically exercising the valve disk through a complete cycle by hand. Entry into containment during cold shutdown is limited by plant procedures to perform only necessary repair and maintenance work. In cases of short shutdowns caused by problems external to the containment, there may be no entry made into the containment. These valves are not in a harsh environment and* 'enerally have exhibited a low failure rate. It has been determined that the optimum test frequency for low failure rate valves is in the range of 3 to 27 months. Refueling intervals of 12 to 20 months are within this optimum range. Cold shutdowns can occur at intervals up to refueling and changing the test interval from quarterly to refueling does not differ significantly from the Code allowed change, from quarterly to cold shutdown. Reverse flow closure is only necessary to provide a containment isolation leak-tight boundary (see response to IS W-233, Question No. E-2). (0862NE L/vaw ) l ~c I

2. PUMP TESTING PROGRAM

1. TABLE 1 1WP-3100-1 requires that proper pump lubrication level or pressure be observed during pump testing. This test quantity has not been addressed in the SHNPP IST Program. Is this test quantity being observed as required? If there are any exceptions, provide the justifications.

The Program Plan table has been revised to include observation of lubrication level or pressure, except as follows: A) These pumps do not have external lubrication where the level or pressure can be observed. Emergency Service Water Service Water Booster Spent Fuel Pool Cooling B) The pump and motor are an integral unit with no bearings in the pump. Residual Heat Removal Containment Spray Boric Acid Transfer

2. Provide a more detailed technical justification for not measuring pump bearing temperatures. What information or data supports the conclusions drawn in Relief Request No. R-1?

The Program Plan has been revised to exclude bearing temperature measurements for pumps as follows: A) Bearings are in the pump flow path and are exempt by IWP-0310. Emergency Service Water Service Water Booster B) Pump and motor are an integral unit with no bearings in the pump. Containment Spray Residual Heat Removal Boric Acid Transfer C) Quarterly testing for the auxiliary feedwater pump would be performed through a small diameter recirculation line. As a result, operating time is limited to less than required to reach temperature stability. Full-flow testing at refueling test duration is dictated by plant conditions to less than required to achieve bearing temperature stability. (0862NEL/vow ) Pum Testin Pro ram (C ) D) Pump operating time during testing is limited by day tank capacity and is far less than required to reach temperature stability. Diesel Fuel Oil Transfer E) For the remainder of pumps, a new relief request has been prepared as follows: These pumps have no installed instrumentation to measure bearing temperature. Measurement of temperature of the pump bearing housing would not be indicative of actual bearing temperature because of temperature gradients caused by 'operation of space coolers, etc. The once-a-year measurement will not provide significant information about pump condition. The long running time required to achieve temperature stability could result in increased maintenance and repair. Deletion of this measurement will not have significant affect on the pump monitoring program, since other required test parameters are being measured.

3. Pump Note No. 2 indicates that observing diesel generator fuel oil transfer pump refilling the day tank demonstrates proper pump operability. Unless the time to change the day tank level a given amount is measured and that information equated to pump flow rate, this alternate testing method is not adequate since it does not allow for detection of pump degradation.

The Program Plan had been revised to request relief from the Code required flow rate measurement. In lieu of the Code required flow rate measurement, change in tank level and pump operating time will be used to calculate pump flow rate.

0. Is pump vibration measured in units of displacement (mils) or in velocity units (in./sec.)? If measured in units of velocity, provide the allowable ranges for pump vibration for our review.

At the present time, SHNPP plans to measure pump vibration in units of displacement to the requirements of Table IWP-3100-2. If a decision is made in the future to use velocity measurement in lieu of displacement, acceptance, alert and required ranges will be established and forwarded for review. (0862NEL/vow ) ~ I