ML18141A764
| ML18141A764 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/22/1984 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18141A765 | List: |
| References | |
| NUDOCS 8407120440 | |
| Download: ML18141A764 (10) | |
Text
r.
Docket Nos.
50-280 and 50-281 Mr. W. L. Stewart e
JU\\\\I 2 2 1984 Vice President - Nuclear Operations Virginia Electric and Power Company P. 0. Box 26666 Richmond, Virginia 23261
Dear Mr. Stewart:
DISTRIBUTION:
Docket File L PDR DEisenhut EJordan DNeighbors ACRS, 10 NRC PDR ORB#l reading OELD JNGrace CParrish JPage We are reviewing your submittals dated September 21, 1982 and December 27, 1982, related to pump and valve inservice testing for Surry Power Station, Unit Nos.
1 and 2.
We request that you review the enclosed list of questions and plan for us to meet with you at the Surry site to discuss your IST program further.
The enclosure will serve as an agenda for the meeting.
After about four weeks, we will arrange for the visit with you.
Enclosure:
As stated cc w/enclosure:
See next P?ge
-8407120440 840622 PDR ADOCK 05000280 p
fDR ORB#l:OL~
CParrish/dn 6/ '}\\!84 OR~
DN~],'~~ors 6/l\\'184 Sincerely, Steven A. Varga, Chief Operating Reactors Branch #1 Division of Licensing
~~~ W. L. Stewart e Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box, 1535 Richmond, Virginia 23213 Mr. J. L. Wilson, Manager Post Office Box 315 Surry, Virginia 23883 Donald J. Burke, Resident Inspector Surry Power Station U.S. Nuclear Regulatory Commission Post Office Box 166, Route 1 Surry, Virginia 23883 Mr. Sherlock Holmes, Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 W. T. Lough Virginia Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23209 Regional Radiation Representative EPA Region III Curtis Building - 6th Floor 6th and Walnut Streets Philadelphia, Pennsylvania 19106 Mr. J. H. Ferguson Executive Vice President - Power Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261 James P. O'Reilly Regional Administrator - Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 e
Surry Power Station Units 1 and 2
- 1.
VALVE TESTING PROGRAM A.
General Questions and Comments
- 1.
In order for relief to be granted from the requirements of Section XI, IWV-3417, for rapid actuating power operated valves, the licensee should specifically identify the applicable valves and identify in the IST program the maximum allowable stroke time for these valves.
- 2.
The 1980 Edition of the Code defines passive valves as valves which are not required to change position to accomplish a specific function.
The licensee can identify any valve that does not hav~ to change position to fulfill its function(s) important to safety as a passive valve and is not required to exercise that valve.
However, any valve that has a function important to safety which is not specifically identified as being a passive valve in the IST program, must be exercised in accordance with the requirements of Section XI unless a specific relief is requested by the utility and approved by the NRC.
- 4.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50, Appendix J.
Relief from Paragraphs IWV-3421 through -3425 for containment isolation valves presents no safety problem since the intent of IWV-3421 through -3425 is met by Appendix J requirements, however, the licensee shall comply with Paragraphs IWV-3426 and -3427 unless specific relief is requested from these paragraphs.
- 4.
Are all valves that are Appendix J type C leak-rate tested included in the Surry IST programs and categorized A or A/C?
- 5.
Are all valves that perform both a containment isolation and a pressure isolation function leak-rate tested to both the Appendix J and the Section XI requirements?
e
- 6.
Provide a listing apd/or identify in the Surry !ST program resubmittal valves that are leak rate tested to verify their pressure boundary isolation function.
Also, identify the valves that perform both a pressure boundary isolation function and a containment isolation function.
- 7.
The current NRC position is that the emergency diesel generator air start system performs a function important to safety and the appropriate system valves should be included.in the !ST program and tested in accordance with the Code.
- 8.
Provide the current revision of the following Surry, Unit 1, system'P&IDs for our review.
Systems Compres~ed Air and Containment Inst. Air Boron Recovery System Sampling System Vents and Drains Containment and Recirculation Spray System Reactor Coolant System Gaseous Waste Disposal Reactor Cavity Purification Radiation Monitor-Containment Particulate Fuel Oil Lines Containment Purge Containment Fire Protection (Shows Valves 1-FP-151 and 152) Drawing No.
11448-FM-?SC
-?SE
-7SG
-?SJ 11448-FM-79A
-798 11448-FM-828 11448-FM-83A 11448-FM-84A 11448-FM-86A
-868 11448-FM-90A 11448-FM-llSA 11448-SPS-14A 11448-FB-48 11448-FB-GA
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Also provide the P&IDs for any other systems, such as the emergency diesel generator air start system, that may be included in the Surry !ST programs.
- 8.
- 1.
Provide the justification for the deletion of the decay heat release non-return valves (NRV-MS-102A, 8, and C) from the Surry
!ST program.
- 2.
Review the function important to safety of the main steam PORVs (RV-MS-lOlA, 8, and C) to determine if they should be categorized 118 11 rather than 11C11
- C.
Auxiliary Steam and Air* Removal
- 1.
Provide the justification for the deletion of the air removal divert to atmosphere valve (TV-SV-103) from the program.
- 2.
Should check valve 1-VP-12 be categorized AC-passive?
D.
- 1.
Should valves 1-SW-206 and 208 be categorized A-passive?
- 2.
Are valves MOV-SW-103A, 8, C, and D exercised quar~erly instead of at the cold shutdown frequency indicated in the !ST program?
Component Cooling Water
- 1.
Are check valves 1-CC-242, 233, and 224 leak rate tested in accordance with the requirements of Appendix J?
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- 2.
Provide the justification for the deletion of relief valves RV-CC-112A, 8, and C from the IST program.
F.
Vents and Ora ins G.
- 1.
Should valves 1-VA-1 and 6 be categorized A-passive in the IST program?
Containment and Recirculation Spray System
- 1.
Provide the justification for the deletion of valves MOV-CS-IOOA and B from the IST program.
- 2.
Are valves 1-CS-105 and 127 leak rate tested in accordance with the requirements of Appendix J?
- 3.
Provide the justification for the deletion of valve MOV-RH-100 from the IST program.
H.
Containment Vacuum and Leakage Monitoring I.
- 1.
Should valves HCV-CV-100 and 1-CV-2 be categorized A-passive?
- 2.
Provide the justification for the deletion of valves TV-LM-lOlA and B from the !ST program.
- 3.
Provide the justification for the deletion of valves l-GW-166, 175, 174, and 183 from the !ST program.
- 1.
Should valves HCV-1556A, 8, and C be categorized A-passive?
- 2.
Are the Unit 2 reactor vessel head vent valves S0V-RC-200A-1 and 2, and SOV-RC-2008-1 and 2 leak rate tested?
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- 3.
The NRC has adopted the position that since the pressurizer power-operated relief valves have shown a high probability of sticking open and are not needed for overpressure protection during power operation, routine exercising during power operation is "not practical" and, therefore, not required by IWV-3412(a).
Therefore, the PORVs should be exercised at a cold shutdown frequency.
- 4.
Provide a copy of Surry, Unit 1 Technical Specifications 3.1.C and 4.3 for our information.
J.
- 1.
Should valve MOV-RH-100 be categorized A-passive in the IST program?
- 2.
Provide a more detailed technical justification for not exercising valves MOV-1720-A and B quarterly.
- K.
Chemical and Volume Control
- 1.
Provide the justification for deleting valve MOV-12898 from the IST program.
- 2.
Is the stroke time measured for valve FCV-1160?
- 3.
Provide a more specific technical justification for not exercising valve MOV-1373 quarterly.
L.
Safety Injection
- 1.
Are valves 1-SI-235, 236, and 237 leak rate tested to technical specification and Section XI requirements as indicated in note 30?
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M.
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- 2.
Are valves MOV-2864A and 8 (Unit 2) leak rate tested in accordance with the requirements of Appendix J?
- 3.
Are the following Unit 2 valves leak rate tested to verify reverse flow closure for performing their pressure boundary isolation function?
2-SI-107 2-SI-88 2-SI-241 2-S"I-109 2-SI-91 2-SI-242 2-SI-128 2-SI-94 2-SI-243 2-SI-130 2-SI-238 2-SI-79 2-SI-145 2-SI-239 2-SI-82 2-SI-147 2:-SI-240 2-SI-85 Fuel Oil Lines
- 1.
Are stroke times measured for valves SOV-EE-100, 101, and 103?
N.
Containment Purge
- 1.
Are valves MOV-VS-lOOA, 8, C, and 0, and MOV-VS-102 exercised and the stroke times measured quarterly in accordance with the requirements of Section XI?
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- 2. _PUMP TESTING PROGRAM
- 1.
The current NRC position is that utilizing pump vibration velocity measurements, instead of vibration displacement, is an acceptable alternative method to assess pump condition if a listin~ of allowable ranges is established by the licensee and approved by the NRC.
The table in Relief Request 1 (Table 2, ASME Publication 78-WA/NE-5) has vibration velocity values that are unrealistically high and exceed the values that are currently acceptable to the NRC.
The current NRC position is that the maximum acceptable range value be less than or equal to 0.314 inches per second and the maximum value for the required action range threshold be less than 0.628 inches per second.
- 2.
The current NRC position is.that the lack of installed instrumentation is not an acceptable long term technical Justification to be used as a basis for relief from making Code required measurements on pumps that perform a function important to safety.
Unless the licensee can demonstrate that a valid alternate method is used to obtain the data required to assess pump condition and determine pump degradation, or it can demonstrate that the Code required measurements are impractical or not applicable, the licensee should make the necessary system and/or component modifications to allow measurement of the required parameters.
The following pump program relief requests are affected by this staff position:
2 3
4 6
9 10 11
- 3.
10 CFR 50.55a(g)(6)(ii) states that the Commission may require the licensee to follow an augmented inservice inspection program for systems and components which it deems necessary.
The staff has identified the emergency diesel generator fuel oil transfer system and air start system as systems whose functions are important to safety and is requiring that the appropriate system pumps and valves be e
included in the !ST program and be tested in accordance with the requirements of Section XI.
This staff position affects pump program Relief Request 12.
- 4.
The licensee has listed "lubrication level or pressure" as a code requirement for which relief is requested in the following Unit 2 relief requests.
This parameter has been addressed by notes at the bottom of the pump inservice test table and is not addressed in the relief requests.
3 4
7 9
10 11
- 5.
- Is pump flow rate measured during the quarterly testing of the component cooling water pumps (1-CC-P-lA and 18)?
If it is not, provide a relief request with the specific technical justification for not performing these measurements as required by the Code.
8 -