ML18152A288
| ML18152A288 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/13/1988 |
| From: | Chandu Patel Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| TAC-65555, TAC-65556, NUDOCS 8805250397 | |
| Download: ML18152A288 (32) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Docket Nos. 50-280 and 50-281 Mc;1,y 1 3 1. 1 9"88 LICENSEE: Virginia Electric and Power Company FACILITY: Surry Power Station, Units 1 and 2
SUBJECT:
SUMMARY
OF THE INSERVICE TESTING (1ST) PROGRAM MEETING HELD ON MARCH 29 AND 30, 1988 AT THE SURRY SITE (TAC NOS. 65555 AND 65556)
An IST review meeting was held on March 29 and 30, 1988 at the Surry Site to resolve questions raised from the preliminary review of the proposed IST Program for the Surry Units. is a copy of the meeting minutes. is a list of attendees.
The following two items clarify the staff's position on open items identified for NRC's action.
- 1.
Accumulator Discharge Check Valves - In Surry's IST Program, Valve Relief Request No. 26, VEPCO asked for relief from quarterly testing and as an alternative test, VEPCO propo5ed to partially stroke the valves each tefueling.
The NRC staff's position is that demonstration of full-stroke capability as required by the Code must be done.
This may be accomplished by exercising the check valves by a measur8d flow rate through the valve.
When this ~ethod is used as a positive means to verify a full-stroke exercise of the valve disk, the measured flow rate must be at least equal to the maximum flow rate identified in any of the plant's safety analyses.
Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differen-tial pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve.
Where a check valve can not be fully-stroked exercised with flow, an alternative would be disassembly and inspection of the valves to verify the full-stroke capability. A sampling technique as described in Item 7 of the General Questions and Comments in the me~ting minutes can be used in selecting valves for disassembly and inspection.
In the final submittal VEPCO must commit to full-stroke exercising by flow testing or disassembly and inspection of the valves.
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May 13, 1988 e
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- } 2.
Auxiliary Feedwater Pumps - VEPCO stated that it will perform testing with existing instrumentation at least as often as required by Section XI, or will perform a more comprehensive full-flow test at a reduced frequency, but not both tests.
The NRC staff's position is that the pump test should be done with the mini-flow lines per the frequency as required by the Code, and a comprehensive full-flow test at a reduced frequency.
Enclosures:
As stated cc:
See next page DISTRIBUTION Docket Fi le NRC & Local PDRs PD22 Reading H. Berkow C. Patel OGC-vJF E. Jordan J. Partlow NRC Participants ACRS (IO)
- See previous concurrence
- LA:PDII-2 DMiller 5/ /88 cpp PM:PDII-2 CPatel :bg 5/13/88 Chandu P. Patel, Project Manager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation
J I
e e 2.
Auxiliary Feedwater Pumps - VEPCO stated that it will perform testing with existing instrumentation at least as often as required by Section XI, or will perform a more comprehensive full-flow test at a reduced frequency, but not both tests.
The NRC staff's position is that the pump test should be done with the mini-flow lines per the frequency as required by the Code, and a comprehensive full-flow test at a reduced frequency.
Please let us know if you have any further questions.
Enclosures:
As stated cc:
See next page DISTRIBUTION Docket File NRC & Local PDRs PD22 Reading H. Berkow C. Patel OGC-WF E. Jordan J. Partlow NRC Participants ACRS (10) uf'1P PM:PDII-2 CPatel:bg 5/ /Z-/88 L~P.
I-2 D
- er 5 11>'88 Chandu P. Patel, Project Manager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation D:PDII-2 HBerkow 5/ /88
Mr. D. S. Cruden Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virginia 23212 Mr. David L. Benson, Manager Surry Power Station Post Office Box 315 Surry, Virginia 23883 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 vi. T. Lough Virginia Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23209 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 James B. Kenley, M.D., Commissioner Department of Health 109 Governor Street Richmond, Virginia 23219 Surry Power Station Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219
'a e ENCLOSURE l SURRY POWER STATION, UNITS 1 AND 2 PUMP AND VALVE INSERVICE TESTING PROGRAM MEETING MINUTES
- 1.
VALVE TESTING PROGRAM A.
General Questions and Comments
- 1.
Provide a list of all valves that are Appendix J, Type C, leak rate tested but not included in the 1ST program and categorized A or A/C.
Response
All valves that are Appendix J, Type C, leak rate tested are included in the IST program.
- 2.
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.
Specific relief must be requested form IWV-3421 through 3425 for any valves that are Appendix J tested to fulfill Section XI requirements.
Response
Leak rate limits are individually assigned to valves that are Appendix J leak rate tested except in two c~ses where a group of valves cannot be tested individually.
- 3.
The NRC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds of less.
Relief may be obtained from the trending requirements of Section XI, Paragraph IWV-3417(a),.
however, in order to obtain this Code relief the staff does require 1
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that the licensee assign a maximum limiting stroke time of 2 seconds to these valves and comply with the requirements of IWV~3417(b) when the 2 second limit is exceeded.
The last paragraph on page 4-32 appears to be in conflict with this position.
Response
Rapid acting power operated valves, which normally stroke in two seconds or less, will be assigned maximum limiting stroke l
times of two seconds and identified as rapid acting valves in the IST program.
Corrective action requirements of IWV-3417(b) will be initiated for these valves if the two second time limit is exceeded.
- 4.
10 CFR 50.55a(g)(5)(ii) states that, 11 If a revised inservice inspection program for a facility conflicts with the technical specification for the facility, the licensee shall apply to the Commission for amendment of the technical specifications to conform the technical specification to the revised program."
The second paragraph of section 4.4.1, page 4-32 appears to conflict with this law.
The valves in the IST program shall conform to the Code requirements.
Response
Paragraph two in section 4.4.1 of the Surry IST program will be clarified on the relationship of Section XI limits versus Technical Specification limits.
- 5.
Provide the limiting values of full-stroke time for all power operated valves in the IST program for our review.
What are the bases used to assign the limiting valvues of full-stroke time for these valves?
Response
The maximum values of full-stroke time for power operated 2
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valves will be evaluated to determine reasonable values which should be used.
These values should be based upon actual stroke times for each valve not to exceed FSAR or Technical Specification limits.
- 6.
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 requirement.
Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some 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 Surry IST program conform to this staff position?
Response
Virginia Electric understands the staff position on full-stroke exercising check valves with flow.
- 7.
The NRC staff has concluded that check valve sample disassembly/inspection using a manual full-stroke of the disk is an acceptable alternative method to verify the full-stroke capability of check valves.
The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number, and materials of construction) and must have the same service conditions. Additionally, at each disassembly the licensee must verify that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).
A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entire group has been tested.
If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the 3
valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.
Response
Valve disassembly and inspection has been discussed with the licensee.
The licensee understands the staff position on grouping, frequency of testing, and disassembly/inspection of check valves.
B.
Main Steam System
- 1.
For which Code requirement is Relief Request 1 requesting relief?
Response
Relief request 1 will remain in the 1ST program.
This addresses only lift pressure setpoint testing versus all other testing in PCT-25.3-1976.
- 2.
Review the valve categorization and type for valves TV-MS-lOlA, TV-MS-1018, and TV-MS-101C.
Is the technical specification testing identified for these valves in the alternate testing for Relief Request 2 more limiting than the Code required testing?
Response
The staff agrees that TV-MS-lOlA, B, and Care Category B valves.
The Technical Specification testing identified for these valves is acceptable.
Additional Comment:
Section XI allows testing at a cold shutdown frequency if quarterly testing at power is not practical.
A technical justification must be submitted (and approved) as a cold 4
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shutdown justification.
However, a relief request is not required.
- 3.
Provide a detailed technical justification for not full-stroke exercising valves RV-MS-lOlA, RV-MS-1018, and RV-MS-lOlC if they have the capability of being remotely operated.
Response
RV-MS-101A, B, and Care Category B valves and must be tested quarterly in accordance with Section XI unless a cold shutdown justification is provided or relief requested.
These valves will be categorized 118 11 The valve table will be changed accordingly as to the actuator type, valve type, and relief request reference.
- 4.
How are valves PCV-MS-102A and PCV-MS-1028 stroke timed quarterly?
Response
Valves PCV-MS-102A and B have position indication and individual control switches.
- 5.
Provide a detailed technical justification for not stroke timing and fail-safe testing valve HCV-MS-104.
Response
HCV-MS-104 must be fail-safe tested and stroke timed unless adequate technical justification is provided in a relief request to allow deviation from Section XI requirements.
- 6.
Do valves TV-MS-109 and TV-MS-110 have a required fail-safe position?
5
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Response
TV-MS-109 and 110 have a required fail-safe position.
Additional Comment:
Fail-safe testing identified in the Surry 1ST program is performed in both directions using the alternate motive power (air, nitrogen, etc.). The utility will re-evaluate their fail-safe testing definition and change the testing identified on the valve table.
- 7.
How are valves 1-MS-176, 1-MS-178, and 1-MS-182 individually verified to full-stroke exercise open and closed quarterly?
Response
Each parallel leg is tested individually when the pump is running on the recirculation line (less than full-rated flow).
The utility will re-evaluate their testing method to determine if this is a full-stroke exercise of these valves.
- 8.
What are the safety-related position(s) of valves NRV-MS-102A, NRV-MS-102B, and NRV-MS-102C and how are the position(s) verified?
Response
The safety positions of NRV-102A, B, and Care shut.
Position is verified by running the valve stem down on the disk when the valve is in the shut position.
C.
Feedwater System
- 1.
Review the safety function(s) of the following valves to determine if they should be included in the 1ST program and tested to Section XI requirements:
6
.)
Response
Valve 1-FW-148 1-FW-149 1-FW-163 1-FW-164 1-FW-178 1-FW-179 P&ID and Coordinates 11448-FM-68A E-7 11448-FM-68A E-7 11448-FM-68A F-7 11448-FM-68A F-7 11448-FM-68A G-7 11448-FM-68A G-7 Valves 1-FW-148, 163, and 178 will be added to the Surry IST program and a relief request will be submitted for modified testing. Valves 1-FW-149, 164, and 179 will be evaluated to determine if they have a safety function.
THIS IS AN OPEN ITEM FOR THE LICENSEE.
- 2.
How are valves 1-FW-144, 1-FW-159, and 1-FW-174 verified to full-stroke open?
Response
The licensee will evaluate the acceptance criteria of current testing to determine if it satisfies the requirements of a full '"'stroke.
- 3.
Is each of valves 1-FW-10, 1-FW-12, 1-FW-41, 1-FW-43, 1-FW-72, and 1-FW-74 disassembled for full-stroke exercising every refueling?
Response
The licensee will evaluate the necessity of double check valves from a safety standpoint.
Also, an evaluation will be done on grouping these valves for disassembly and inspection.
D.
Auxiliary Feedwater Cross Connect System
- 1.
How are valves 1-FW-272, 1-FW-273, 1-FW-309, and 1-FW-310 verified to full-stroke exercise during cold shutdown?
7
.)
Response
The licensee will evaluate the acceptance criteria of current testing to determine if it satisfies the requirements of a full-stroke.
- 2.
Does the emergency makeup system for auxiliary feedwater perform any safety function?
Response
The emergency makeup system pumps, 1-FW-P-4A and 48, perform no safety function as stated by the licensee. Therefore, these pumps and their associated valves need not be included in the IST program.
E.
Circulating and Service Water System
- 1.
What safety function(s) do the following valves perform?
MOV-CW-106A MOV-CW-lOOA
Response
MOV-CW-106B MPV-CW-100B MOV-CW-106C MOV-CW-lOOC MOV-CW-1060 MOV-CW-1000 These valves perform a safety function in the closed position to conserve water in the ultimate heat sink.
- 2.
Review the safety function(s) of valves 1-SW-130, 1-SW-268 and the check valve downstream of valve 1-SW-109 (P&ID 11448-FM-71B, locations B-6, B-6, F-8, and G-8) to determine if they should be included in the IST program and tested to Section XI requirements.
Response
Valves 1-SW-262 (the check valve downstream of valve 1-SW-109),
8
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.)
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e 268, and 130 will be included in the IST program and tested quarterly to Section XI requirements.
F.
Component Cooling Water System
- 1.
How are valves l-CC-176 and 1-CC-177 verified to full-stroke exercise?
Response
The licensee.will evaluate the acceptance criteria of the current testing to determine if it satisfies the requirements of a full stroke.
- 2.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-CC-105A TV-CC-110A
Response
TV-CC-1058 TV-CC-1108 TV-CC-105C TV-CC-110C TV-CC-107 The licensee is performing fail-safe testing.
The valve table will be changed to reflect this.
- 3.
Review the safety function(s) of valves HCV-CC-lOlA, HCV-CC-1018, HCV-CC-102A, and HCV-CC-1028 (P&ID 11448-FM-728, locations I-2, G-1, C-3, and D-1) to determine if they should be included in the IST program and tested to Section XI requirements.
Response
HCV-CC-lOlA, B, 102A, and B do not have a required safety function and will not be included in the IST program.
- 4.
Review the safety function(s) of valves HCV-CC-100 and the component cooling water surge tank vacuum breaker (P&ID 11448-FM-72D, 9
locations A-1 and B-1) to determine if they should be included in the IST program and tested to Section XI requirements.
Response
HCV-CC-100 does have a safety function in the closed position to isolate the tank if gaseous activity gets too high.
The vaccuum breaker has a safety function to protect the tank.
The licensee will evaluate the testing to be performed.
- 5.
How are valves 1-CC-557 and l-CC-563 verified to full-stroke open?
Response
The licensee will evaluate the acceptance criteria of the current testing to determine if it satisfies the requirements for a full-stroke test.
G.
Compressed and Containment Instrument Air Systems
- 1.
Provide a more detailed technical justification for not full-stroke exercising valves 1-IA-938 and 1-IA-939 quarterly and during cold shutdown.
Response
The licensee will provide additional justification for not full-stroke exercising these valves quarterly and/or during cold shutdowns.
- 2.
Provide a detailed technical justification for not fail-safe testing valves TV-IA-lOlA, TV-IA-1018, and TV-IA-100 quarterly.
Response
Fail-safe testing is being performed.
The valve table will be changed to reflect this.
10
H.
Sampling System
- 1.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-SS-lOOA TV-SS-102A TV-SS-104A
Response
TV-SS-100B TV-SS-1028 TV-SS-104B TV-SS-lOlA TV-SS-103A TV-SS-106A TV-SS-1018 TV-SS-103B TV-SS-106B Fail-safe testing is being performed.
The valve table will be changed to reflect this.
I.
Vents and Drains System
- 1.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-DA-lOOA TV-DG-108A
Response
TV-DA-1008 TV-DG-1088 TV-DA-103A TV-VG-109A TV-DA-1038 TV-VG-1098 Fail-safe testing is being performed.
The valve table will be changed to reflect this.
J.
Containment and Recirculation Spray Systems
- 1.
Provide a more detailed technical justification for not full-stroke exercising the following valves quarterly and during cold shutdown.
1-RS-11 1-CS-24
Response
1-RS-17 1-CS-105 l-CS-13 1-CS-127 The licensee will further evaluate the frequency and test 11
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method for testing of valves 1-RS-11, 17, CS-13, and 24 to determine if these valves can be manually exercised in accordance with the Code at a cold shutdown frequency.
The licensee will provide a separate relief request with a more detailed technical justification for not testing valves 1-CS-105 and 127 to Code requirements.
K.
Containment Vacuum and Leakage Monitoring System
- 1.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-LM-lOOA TV-LM-lOOE TV-CV-150A
Response
TV-LM-1008 TV-LM-lOOF TV-CV-1508 TV-LM-lOOC TV-LM-lOOG TV-CV-150C TV-LM-100D TV-LM-lOOH TV-CV-150D Fail-safe testing is being performed.
The valve table will be changed to reflect this.
L.
- 1.
Provide a more detailed technical justification for not leak testing valves HCV-1556A, HCV-15568, and HCV-1556C in accordance with IWV-3426 and 3427 (see Relief Request 30).
Response
These are not Event-V boundary isolation valves.
These valves are tested according to Technical Specifications, but not individually.
No further action is required at this time.
- 2.
Provide a detailed technical justification for not full-stroke exercising, fail-safe testing, and verifying the remote position 12
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indication of the following valves quarterly (every 2 years for position verification).
How are these valves stroke timed?
SOV-RC-lOOA-1 SOV-RC-lOlA-1
Response
SOV-RC-lOOA-2 SOV-RC-lOlA-2 SOV-RC-1008-1 SOV-RC-1018-1 SOV-RC-1008-2 SOV-RC-1018-2 Fail-safe testing and valve position verification are being performed.
The valve table will be amended to indicate this.
The licensee will provide a more detailed technical justification for not full-stroke exercising these valves.
- 3.
Review the safety function(s) of the following valves to determine if their categorization should be changed.
SV-1551A MOV-1536
Response
SV-15518 PCV-1456 SV-1551C PCV-1455C MOV-1535 The classification of valves SV-1551A, 8, and C will be changed to Category C and valves PCV-1456, and 1455C to Category 8/C.
Valves PCV-1456 and 1455C will be tested on the approach to each cold shutdown and testing may not be deferred.
The technical justification will be changed to provide more detail on the testing to be performed.
The classification of MOV-1535 and 1536 will be changed to Category B.
The valve table will be amended for these valves to properly show the testing required and the valve categories.
- 4.
Provide a detailed technical justification for not fail-safe testing valve TV-1519A quarterly.
Response
Fail-safe testing is being performed.
The valve table will be changed to reflect this.
13
)
- 5.
Provide a more detailed technical justification for not full-stroke exercising valve 1-PG-65 quarterly and during cold shutdown.
Response
Additional information will be provided in an amended relief request for not full-stroke exercising valve 1-PG-65 quarterly and during cold shutdowns.
M.
Residual Heat Removal System
- 1.
Provide a more detailed technical justification for not full-stroke exercising valves 1-RH-5 and 1-RH-11 quarterly.
Response
The licensee will provide additional technical justification for not full-stroke exercising valves 1-RH-5 and 11 quarterly (i.e., interlocks, possible inter-system LOCAs).
- 2.
Do valves FCV-1605 and HCV-1758 (P&ID 11448-FM-87A, locations B-5 and G-4) have a required fail-safe position?
Response
Valves FCV-1605 and HCV-1758 do have a required fail-safe position.
They will be added to the !ST program as Category B valves.
A cold shutdown justification will be provided as there is no remote position indication.
N.
Chemical and Volume Control System
- 1.
How are valves 1-CH-76 and 1-CH-92 verified to full-stroke open during quarterly exercising?
14
)
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e
Response
The utility will evaluate the acceptance criteria of the current testing to determine if it satisfies the requirements of a full-stroke.
- 2.
What are the consequences of valve failure during quarterly exercising of valves LCV-1115B and LCV-1115D?
Response
Quarterly testing of valves LCV-1115B and Dis now being done and poses no problems when done during plant operation.
- 3.
Review the safety function(s) of valves 1-CH-256, 1-CH-265, and 1-CH-274 (P&ID 11448-FM-88B, locations D-6, F-6, and G-1) to determine if they should be included in the 1ST program and tested to Section XI requirements.
Response
These valves will be added to the !ST program as Category C valves and tested to the open position quarterly.
The licensee will evaluate the methods to be used to verify a full-stroke of these valves.
- 4.
Provide a detailed technical justification for not fail-safe testing valve TV-1204 quarterly.
Response
Fail-safe testing is being performed.
The valve table will be changed to reflect this.
- 5.
Review the safety function(s) of the following valves to determine 15
if they should be included in the IST program and tested to Section XI requirements:
Response
Valve MOV-1287A MOV-1287B MOV-1287C MOV-1286A MOV-1286B MOV-1286C Coordinates and P&ID 11448-FM-888 B-6 11448-FM-888 E-6 11448-FM-888 G-6 11448-FM-888 B-6 11448-FM-88B F-6 11448-FM-888 G-6 These valves are maintenance convenience valves and need not be included in the IST program.
- 6.
Review the safety function(s) of the following valves to determine if they should be included in the IST program and tested to Section XI requirements.
Response
Valve MOV-1267A MOV-12678 MOV-1269A MOV-12698 MOV-1270A MOV-12708 Coordinates and P&ID 11448-FM-888 D-7 11448-FM-888 D-7 11448-FM-888 F-7 11448-FM-888 F-7 11448-FM-888 H-7 11448-FM-888 H-7 These valves are Category B, maintenance convenience, valves and need not be included in the IST program.
- 7.
Review the safety function(s) of valves MOV-1350 and 1-CH-227 (P&ID 11448-FM-888, locations H-6 and I-6) to determine if they should be included in the IST program and tested to Section XI requirements.
Response
These valves will be added to the IST program as Category Band 16
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C valves respectively and tested at a cold shutdown frequency.
A cold shutdown justification will be provided.
- 8.
Provide a detailed technical justification for not fail-safe testing valves HCV-1200A, HCV-12008, and HCV-1200C quarterly.
Response
These valves are fail-safe tested quarterly and the valve table will be changed to reflect this.
- 9.
Provide a more detailed technical justification for not full-stroke exercising valve 1-CH-309 quarterly.
Response
The licensee will provide a more detailed technical justification for not full-stroke exercising valve l-CH-309 quarterly and during cold shutdowns.
- 0.
Safety Injection System
- 1.
Provide a more detailed technical justification for not full-stroke exercising valves 1-SI-56 and 1-SI-47 quarterly.
Response
The licensee will disassemble and inspect valves 1-SI-56 and 47 on a sampling basis each refueling. Additional justification will be provided in the relief request for not full-stroke exercising these valves with flow.
- 2.
How is reverse flow closure verified for valves 1-SI-50 and 1-SI-58?
17
Response
The licensee will add quarterly reverse flow closure verification of check valves 1-SI-50 and 58 to the IST program.
- 3.
Provide a more detailed technical justification for not full-stroke exercising valves MOV-1869A, MOV-1869B, and MOV-1842 during cold shutdown.
Response
The licensee will provide a more detailed technical justification for not testing these valves during cold shutdowns.
- 4.
How are valves l-SI-25 and 1-SI-410 verified to full-stroke open and closed during cold shutdown?
Response
The licensee will further evaluate the full-stroke capability (open and closed) of these valves.
THIS IS AN OPEN ITEM FOR THE LICENSEE.
- 5.
Review the safety function(s) of the following valves to determine if their categorization should be changed.
MOV-1890A MOV-1869A
Response
MOV-1890B MOV-1869B MOV-1890C MOV-1842 These valves will be categorized as active (versus passive) valves.
The IST program will be amended accordingly.
- 6.
Provide a detailed technical justification for not fail-safe testing valves TV-SI-100, TV-SI-102A, and TV-SI-102B quarterly.
18
Response
Fail-safe testing of these valves is being performed quarterly.
The valve table will be changed to reflect this.
- 7.
Provide a more detailed technical justification for not full-stroke exercising the following valves quarterly.
What alternative methods have been considered to full-stroke exercise these valves?
l-SI-107 1-SI-130
Response
.1-Sl-109 1-SI-145 1-SI-128 1-SI-147 These valves will be further evaluated as to the testing required and the testing to ~e done.
The licensee feels their FSAR adequately addresses testing requirements for these check valves (i.e., part-stroking) and the full-stroke requirements of Section XI do not apply.
The NRC staff position is that demonstration of full-stroke capability as required by Section XI must be done.
THIS IS AN OPEN ITEM FOR THE LICENSEE to further evaluate the testing of these valves.
THIS IS ALSO AN OPEN ITEM FOR THE NRC.
- 8.
What are the consequences of valve failure during quarterly exercising of valves MOV-1865A, MOV-1865B, and MOV-1865C?
Response
The licensee will continue the testing of these valves quarterly during operation.
- 9.
Provide a more detailed technical justification for not full-stroke 19
exercising the following valves quarterly and during cold shutdown.
How are each of these valves individually closure verified?
1-SI-88 1-SI-238
Response
l-SI-91 1-SI-239 1-SI-94 1-SI-240 The licensee will evaluate the acceptance criteria of the current testing to determine if it satisfies the requirements of a full-stroke.
- 10.
How is reverse flow closure verified for each of valves l-SI-79, 1-SI-82, and 1-SI-85?
Response
Drain lines have been added upstream of these valves to allow verification of valve closure.
- 11.
Review the safety function(s) of valves 1-SI-235, 1-SI-236, and 1-SI-237 to determine if their categorization should be changed.
Response
The categorization of these valves will be changed to A/C; These valves will be added to Relief Request number 30.
- 12.
What is the accuracy of flow instruments FT-1932, FT-1933, FT-1960, FT-1961, FT-1962, and FT-1963?
Response
The accuracy of these flow instruments is +2% over a range of 0-600 gpm.
- 13.
If the operability of valves HCV-1853A, HCV-1853B, HCV-1853C, and HCV-1936 (P&ID 11448-FM-89B, locations D-4, D-7, G-5, and H-5) is 20
e necessary to fulfill the requirements of Branch Technical Position RSB 5-1, these valves must be included in the !ST program and tested to the Code requirements.
Response
The licensee will further evaluate the safety function of these valves to determine the testing required.
THIS IS AN OPEN ITEM FOR THE LICENSEE.
P.
Containment Hydrogen Analyzer System
- 1.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-GW-100 TV-GW-104 TV-GW-lllA
Response
TV-GW-101 TV-GW-105 TV-GW-111B TV-GW-102 TV-GW-106 TV-GW-103 TV-GW-107 Fail-safe testing of these valves is being performed.
The valve table will be changed to relect this.
Q.
Steam Generator Blowdown System
- 1.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-BD-lOOA TV-BD-100D
Response
TV-BD-100B TV-BD-lOOE TV-BD-lOOC TV-BD-lOOF Fail-safe testing of these valves is being performed at a cold shutdown frequency.
The valve table will be changed to reflect this.
21
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R.
Radiation Monitoring-Containment Particulate System
- 1.
Provide a detailed technical justification for not fail-safe testing valves TV-RM-lOOA, TV-RM-1008, and TV-RM-lOOC quarterly.
Response
Fail-safe testing of these valves is being performed.
The valve table will be changed to reflect this.
S.
Fuel Oil System
- 1.
Review the safety function(s) of the CS-60A valves (six check valves at the outlet of the ready and standby pumps) to determine if they should be included in the IST program and tested to Section XI requirements.
Response
These valves will be added to the !ST program as Category C valves and tested quarterly.
However, as flowrate cannot be determined, a full-stroke of these valves cannot be verified.
- 2.
Provide a detailed technical justification for not stroke timing the following valves quarterly.
SOV-EE-100 SOV-EE-103
Response
SOV-EE-101 SOV~EE-104 SOV-EE-102 SOV-EE-105 These valves have no individual control switches.
They are controlled by the system.
The licensee will provide a more detailed technical justification for not testing these valves to Code requirements.
22
T.
Containment Purge System
- 1.
Provide a technical justification for not verifying valve remote position indication for valve MOV-VS-101 to the Section XI requirements.
Response
Remote position indication is being verified for this valve.
The valve table will be changed to reflect this.
U.
Diesel Air Starting System.
- 1.
Provide a more detailed technical justification for not individually exercising valves SOV-EG-lOOA, SOV-EG-100B, SOV-EG-300A and SOV-EG-300B to the Section XI requirements.
Response
Relief Request 37 will be amended to propose an alternate test in place of stroke-timing these solenoid valves.
The failure of these valves to open promptly will give a diesel engine trouble alarm.
Further investigation would identify problems with the operability of these valves.
- 2.
Review the safety function(s) of valves 1-EG-40, 1-EG-42, 3-EG-40, and 3-EG-42 to determine if they should be included in the !ST program and tested to Section XI requirements.
Response
These valves will be included in the 1ST program as Category C valves.
Closure capability will be verified at least quarterly.
23
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- 2.
PUMP TESTING PROGRAM
- 1.
Relief Request 1 proposes to utilize ASME Publication 78-WA/NE-5 for pump vibration acceptance criteria.
An acceptable alternative criteria is that of ANSI/ASME OM-6, draft 10.
Provide a copy of 78-WA/NE-5 for our review.
Response
The licensee will base their alternative pump vibration velocity acceptance criteria on ANSI/ASME OM-6, Draft 10.
- 2.
Relief Requests 2, 3, 4, 6, 9, 11, and, 12 reference instrumentation installation at some unspecified date.
When and what specific instrumentation will be installed to permit measurement of Code required parameters?
Response
The licensee will amend.Relief Request 11 with a more detailed technical justification for not testing the emergency service water pumps to Section XI requirements.
The following instrumentation will be installed during the 1989/1990 refueling outages for Units 1 and 2 to facilitate measurement of Code required parameters:
PUMPS CH-P-lA,18, and lC SI-P-lA, and 18 RS-P-2A, and 28 CH-P-2A, and 28 EE-P-lA,18,lC, and 10 24 RELIEF REQUEST 2
3 4
9 12 INSTRUMENTATION Inlet pressure, fl owrate Inlet pressure Inlet pressure Inlet pressure, flowrate, vibration Inlet pressure, discharge pressure, vibration
Flowrate instrumentation installation is still being evaluated for the diesel fuel oil transfer pumps (EE-P-1A,1B,1C, and lD).
- 3.
What alternative testing methods have been considered to detect hydraulic degradation for recirculation spray pumps 1-RS-P-lA and 1-RS-P-lB (see Relief Request 5)?
Response
The licensee will be making system modifications to hydraulically test pumps 1-RS-P-lA and 18 during the 1988 refueling outages for Units 1 and 2.
A relief request will be submitted to request that testing be allowed on a refueling outage basis.
- 4.
Provide the technical justification which demonstrates that flow measurement is not necessary for evaluation of pump performance for auxiliary feedwater pumps 1-FW-P-3A, l-FW-P-3B, and l-FW-P-2 (see Relief Request 6).
Response
The licensee will perform testing with existing instrumentation at least as often as required by Section XI, or will perform more comprehensive full-flow testing at a reduced frequency.
Whether testing is done by using the mini-flow lines, or, by full-flow to a steam generator with a waiver of current frequency requirements is an OPEN ITEM FOR THE NRC.
- 5.
Provide a more specific technical justification for not testing the residual heat removal pumps quarterly.
Response
The licensee will provide a more detailed technical 25
justification for cold shutdown testing of the residual heat removal pumps.
- 6.
IWP-4400 states that rotative shaft speed need not be measured for pumps directly coupled to motor drives of either the synchronous or the induction type.
Therefore, relief from the Code requirement need not be requested for pumps meeting these conditions (see Relief Request O).
Response
Relief Request O will be removed from the IST program.
- 7.
Observation of lubricant level or pressure applies only to those pumps that have a lubrication system with level or pressure indication (see Relief Requests 13 and 14).
Response
Relief Requests 13 and 14 will be deleted from the IST program.
- 8.
Provide the specific technical justification that demonstrates that the alternate testing for component cooling water pumps meets the Code requirement for measurement of pump flow (see Relief Request 15).
Response
Relief Request 15 will be deleted from the IST program.
Component cooling water pumps will be tested quarterly in accordance with Code requirements.
- 9.
Provide a more specific technical justification for not measuring vibration for the boric acid transfer and fuel oil transfer pumps quarterly (see Relief Request 9 and 12).
26
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L
Response
System modifications will be performed on the boric acid transfer pumps during the 1989/1990 refueling outages for Units 1 and 2 to allow measurement of vibration.
The licensee will begin quarterly vibration testing of the fuel oil transfer pumps.
27
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- 1 ENCLOSURE 2 e
SURRY POWER STATION, UNITS 1 AND 2
!ST PROGRAM WORKING MEETING March 29 and 30, 1988 NAME REPRESENTING Thomas Shaub Virginia Power David Sommers Virginia Power John P. Maciejewski Virginia Power David J. Fortin Virginia Power R. H. Blount Virginia Power John W. Kin Virginia Power Alex McNei 11 Virginia Power Cuonh Duonh Virginia Power Chandu Patel NRC/NRR Thomas Mclellan NRC/EMEB George A. Hallstrom NRC/Region II Gerry L. Jones DOE/Idaho Operations John F. Hosler EPRI Herb Rockhold INEL/EG&G Idaho Brad Stockton INEL/EG&G Idaho Office