ML18004B664

Forwards Addl Info Re Inservice Pump & Valve Testing Program,Supplementing Rev 3 to Program Submitted on 860916, Per NRC Request.Valves 1AF-16 & 1AF-31 Will Be Tested on Cold Shutdown Frequency

ML18004B664
Person / Time
Site:	Harris
Issue date:	12/31/1986
From:	Cutter A CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NLS-86-482, NUDOCS 8701070588
Download: ML18004B664 (18)

Text

ACCESSION NBR:

FACIL: 5'0-400 AUTH. MANE CUTTER> A. B.

REC IP. NANE DENTONi H. R.

REQU ORY INFORMATION DISTRIBU SYSTEN (RIDS)

Z 8701070588 DOC. DATE: 86/12/31 NOTARIZED:

NO DOCKET ¹ Shearon Hav ris Nucleav Power Plant.

Unit 1.

Cav olina 05000400 AUTHOR AFFILIATION Carolina Po~er 8r Light Co.

RECIPIENT AFFILIATION Office of Nucleav Reactor Regulationi Direc tov'post 851125

SUBJECT:

Fov~ards addi info v e inservice pump Zc valve testing program> supplementing Rev 3 to pv ogram submitted on 860916>

pev NRC v equest. Valves 1AF-16 5 1AF-31 vill be tested on cold shutdown fv equencg.

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Carolina Power 8 Light Company l3EC S 1 1986 SERIAL: NLS-86-082 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-53 IN-SERVICE PUMP AND VALVETESTING PROGRAM

Dear Mr. Denton:

Carolina Power R Light Company hereby submits information concerning the In-Service Pump and Valve Testing (IST) Program.

This information is being submitted as a result of discussions with the NRC Staff. The attached responses supplement our IST Program (Revision 3) as submitted on September 16, 1986.

Yours very tr ABC/SDC/ccj (5103SDC)

Attachment cc:

Mr. B. C. Buckley (NRC)

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

Dr. J. Nelson Grace (NRC-RII)

Mr. C. Ransom (EGRG)

. B. Cutter Vice Pr sident Nuclear Engineering R Licensing 870107058C~

05000400 8 8b'1'231 PDR ADO "

PDR P

411 Fayetteville Street

~ P. O. Box 1551

~ Raleigh, N. C. 27602

ATTACHMENT TO NLS-86-482 (1293NEL/ccrc)

SHEARON HARRIS NUCLEAR POMER PLANT PUMP AND VALVE IN-SERVICE TESTING PROGRAM

RESPONSE

TO RE VEST FOR ADDITIONAL INFORMATION 1.

Ques tion The licensee has not provided a good technical basis for not full-stroke exercising auxiliary feedwater valves 1AF-16 and 31 during each cold shutdown.

This information should be provided in Relief Request RV-1 or these valves should be full-stroke exercised on a cold shutdown frequency.

~Res ones The valves 1AF-16 and 1AF-31 will be tested on a cold shutdown frequ'ency.

2.

Question If auxiliary feedwater valves 1AF-19, 34, 49, 50, 51,

129, 130, and 131 have a

~re uired fail-safe position, then they perfora an active safety-related function and they must be exercised and have their full-stroke times measured to verify that they can perform that function and to detect degradation that might lead to valve failure.

If shutting off the auxiliary feedwater pumps has the same effect as removing power to these valves and results in the valves going to their fail-safe position, then that is considered a fail-safe test as required by the code and no relief is necessary from the fail-safe testing requirement.

However, these valves perform an active safety function and are not exempt from the Section XI testing that is designed to detect valve degradation.

(1293NEL/ccrc)

R~es onse In order to avoid the thermal shock problem of testing these valves on a quarterly time frame, the valves 1AF-19, 34, 49,'0, 51,

129, 130, and 131 will be tested on a cold shutdown frequency.

3.

Question The NRC staff position is that two series check valves cannot be verified in the closed position together as a pair, the valve or valves for which credit is taken for reverse flow closure must be individually verified capable of performing that safety function.

This applies to the following auxiliary feedwater valves:

IAF-54 1AF-73 lAF-92 1AF-117 1AF-136 lAF-142 1AF-148

~Res onse The valves 1AF-54, 73, 92,

117, 136,

142, and 148 will be verified to be in the closed position by acoustic detection.

The valves will be leak tested in pairs using installed temperature elements.

4.

Question Has a testing method been decided upon for auxiliary feedwater valves 1AF-65, 84, and 103 (refer to Relief Request RV-5)?

~Res onse The method of testing 1AF-65, 84, and 103 is to disassemble one valve at each refueling.

(1293NEL/ccrc)

"1 1

5.

Question Provide a more detailed technical justification for not exercising auxiliary feedwater valves 1AF-117,

136, 142, and 148 at a cold shutdown frequency.

The provided justifications are more inconvenience than valid justifications such as thermal shock to the feedwater piping and nozzles.

Most other facilities with similar design exercise these valves at cold shutdowns.

(Refer to Relief Request RV-7.)

~Res onse The valves 1AP-117,

136, 142, and 148 will be tested when going to a cold shutdown.

6.

Question Condensate valves 1CE-36 and 46 should be full-stroke exercised on a cold shutdown frequency according to the NRC staff positions on cold shutdown testing unless a more detailed technical justification is provided.

Also, if there are any deviations from the code other than going from the quarterly to the cold shutdown frequency, a cold shutdown justification should not be used.

There is both a cold shutdown justification and a relief request for these valves; these should be combined into a single relief request.

~Res onse See response to Question 7.

7.

Question The basis for relief in condensate Relief Request RV-2 for valve 1CE-56 does not provide an adequate technical justification for not full-stroke exercising this valve on a cold shutdown frequency (refer to Item 5 above).

(1293NEL/ccj)

I t

p 1'

~Res onse (to Questions 6 snd 7)

The valves 1CE-36, 46, and 56 are of the same material,

type, and manufacturer.

These valves will be tested by disassembly.

One valve will be disassembled at each refueling.

The relief requests will be combined and adjusted to reflect this test method.

8.

Question The basis for relief in containment spray Relief Request RV-2 for valves 1CT-102 and 105 does not provide an adequate technical justification for not exercising these valves during cold shutdown.

~Res onse The valves ICT-102 and 105 will be tested at cold shutdown.

9.

Question Containment spray system Relief Request RV-3 is not required because the spray additive tank vacuum breakers are spring-loaded check valves that are performing a relief valve function and are being tested as relief valves in accordance with the requirements of Section XI, IWV-3510.

An explanatory note that identifies the valve type and the testing performed would be sufficient.

~Res onse The vacuum breakers do perform a relief function.

One valve will be tested as a relief valve per IWV-3510 using the manufacturer's recommended test procedure at each refueling.

(1293NEL/cc))

10.

Question The proposed testing for valves 1IA-784, 785,

786, 787,

788, and 789 in instrument air Relief Request RV-2 is not acceptable.

Refer to the staff position in Item 3 above.

~Res onse We will disassemble one valve on the accumulator side and one valve on the instrument air side at each refueling.

11.

guestion No technical justification was provided as a basis for not exercising valves 1CS-341,

382, 423,

470, and 472 (CVCS Relief Request RV-I) during cold shutdowns when the RCS is vented or open to the atmosphere.

Unless a justification is provided and found acceptable, these valves should be exercised during those cold shutdowns.

~Res onse The valves 1CS-341,

382, 423,

470, and 472 will be tested at cold shutdown when the RCS is open, vented, and drained to the top of the vessel flange.

12.

Question Provide a more detailed technical justification for not exercising valves 1CS-165,

166, 291, and 292 during cold shutdowns (refer to CVCS Relief Request RV-3).

What is the flow rate of RWST water that would result and for how long would it be maintained while testing these valves?

What boric acid concentration could result in damage to the reactor coolant pump seals?

Could any significant seal wear occur given the boric acid concentration and the limited time that this higher concentration would be experienced during valve testing?

How would boric acid cause increased seal wear if it remains in solution during valve testing?

(1293NEL/ccj)

R~es onse The valves 1CS-165,

166, 231, and 292 will be tested at cold shutdown.

e 13.

guest1on Provide a more detailed technical justification for not exercising valve 1CS-279 during cold shutdowns (refer to CVCS Relief Request RV-5).

~Res onse The valve 1CS-279 will be tested when borating on the way to cold shutdown.

14.

guesefon Provide a more detailed technical justification for not exercising valve 1CS-294 during cold shutdowns (refer to CVCS Relief Request RV-6).

~Res onse The valve 1CS-294 will be tested during cold shutdown.

15.

Question The proposed testing for valves 1CC-118 and 119 in component cooling water Relief Request RV-I is not acceptable.

Refer to the staff position in Item 3 above.

~Res onse We plan to either install a test tap between the valves or remove the internals of one of the valves.

(1293NEL/ccj)

16.

Question The requests for relief from measuring emergency service water pump bearing temperature and vibration do not identify any alternate means of determining pump mechanical condition for these pumps.

Past experience by other utilities has show that measuring vibration on the upper motor bearing (which is normally a thrust bearing that wholly or partially supports the pump shaft and impeller) will provide information that can be used to determine pump and shaft bearing condition.

This or some other appropriate alternate method should be employed to monitor the emergency service water pumps at Shearon Harris.

~Res onse ESW pump flow and psid will be plotted on pump curve to check for degradation of the pump.

Vibration measurements will also be taken.

17.

Question Pump Relief Request PR-5 states that the emergency service water intake screen wash pump flow rate will vary constantly during pump operation and that it is not possible to establish a repeatable set of pump test conditions.

If pump flow varies widely, how is pump differential pressure to be used to evaluate pump performance?

What acceptable,

alert, and required action ranges do you use for pump differential pressure?

Review the safety-related function of this pump.

~Res onse ESW intake screen wash pump psid and ultrasonic measured flow will be plotted on pump curve to check for degradation of the pump.

Vibration movement will also be taken.

(1293NEL/cc))

18.

Question Provide the justification for not testing the boric acid transfer pumps when borating the reactor coolant system when entering cold shutdowns.

Provide a more detailed justification why vibration measurements cannot be taken on the motor casing of the boric acid transfer pumps; other utilities measure vibration on similar pumps.

~Res onse Vibration measurements will be taken on the boric acid transfer pumps.

Flow will be measured through the emergency boration path when borating on the way to cold shutdown.

19.

Question Does the manual exercising procedure identified for valves 1CB-3, 1CB-7, and 1CM-7 in containment HVAC Relief Request RV-1 employ a method to quantitatively measure the torque required to open the valves as required by Section XI, IWV-3522(b)'t If the torque is

measured, the method used should be identified in the relief request.

If torque is not measured, a quantitative test should be developed to detect valve degradation.

~Res onse Ve willverify reverse flow closure on valves ICB-3 and 7 and 1CM-7 e

by visual inspection.

The torque required to open the valves will be measured by a spring scale.

These valves will be inspected at refueling.

20.

Question In reference to Cold Shutdown Test CS-1 for the safety injection

system, why can't the charging pumps be used to verify forward flow operability of check valves 1SI-81, 82, 83,

134, 135,

136, 137, 346, 347,

356, 357, and 358?

(1293NEL/ccj)

~Res onse Testing these valves with high head safety injection will cause pressurizer level control problems along with borating the RCS possibly leading to a reactor scram.

21.

Question In reference to Cold Shutdown Test RV-2 for the component cooling water system, why must all the reactor coolant pumps be secured to test valves 1CC-207,

208, 249,

251, 297, and 299?

~Res onse Stroking these valves to the RCP thermal barriers and bearing oil coolers will not contribute to pump degradation due to the short time flow will be stopped.

The relief request will be revised to read exercise and time at cold shutdown when the RCS temperature is less than or equal to 200 degrees.

It is our intent to perform this test when the RCPs can be stopped.

22.

Question In reference to Cold Shutdown Test RV-4 for the auxiliary feedwater

system, why can't the steam generators be drained during short duration cold shutdowns to allow testing of valves 1AF-54, 73, and 92?

~Res onse The valves lAF-54, 73, and 92 will be forward flow tested on the way to cold shutdown when the auxiliary feedwater system is in operation. (1293NEL/ccj)