ML18152A635
| ML18152A635 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/07/1988 |
| From: | Chandu Patel Office of Nuclear Reactor Regulation |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| TAC-65557, TAC-65558, NUDOCS 8801140162 | |
| Download: ML18152A635 (15) | |
Text
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Docket Nos. 50-280 and 50-281 Mr. W. L. Stewart e
Vice President - Nuclear Operations Virginia Electric and Power Company Post Office Box 26666 Richmond,.Virginia 23261
Dear Mr. Stewart:
January 7, 198~
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATED TO INSERVICE TESTING PROGRAMS FOR SURRY POWER STATION, UNITS 1 AND 2 (TAC NOS. 65557 AND 65558)
By letter dated April 16, 1987, Virginia Electric and Power Company (VEPCO) submitted the revised Inservice Testing Programs for both Surry units.
As a result of our preliminary review of these programs, we have developed a set of questions and comments.
We would like to meet with VEPCO's representatives, preferably at the plant site, to resolve our concerns.
The enclosed list of questions will be used as the agenda for the discussion.
Formal reply to these questions prior to the meeting is not necessary. However, draft responses should be prepared prior to the meeting and made available during the discussion.
A meeting schedule will be established after you have had a reasonable time to prepare responses to these questions.
The reporting and/or recordkeeping requirements of this letter affect fewer than 10 respondents; therefore, 0MB clearance is not required under P.L.96-511.
Sincerely, Original signed by
--~~----~
(~801140162 880107 I
-ADOCK 05000280.
Chandu P. Patel, Project Manager Pro,iect Directorate II-2 p
Enclosure:
As stated cc: See next page
'. J Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation DISTRIBUTION Docket.File*
NRC & Local PDRs PD22 Reading OGG-Bethesda E. Jordan S. Varga G. Lainas D. Miller C. Patel L~~2 D
er o I 71ss lJ. Partlow ACRS (10)
Gray File-rJf PM:PD22 CPatel:bd 01/07/88 o[;fZD.
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Mr. W. L. Stewart Virginia Electric and Power Company cc:
Mr. Michael W. Maupin Hunton and Williams Post Office Box 1535 Richmond, Virgiria 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 W. 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., Conmissioner Department of Health 109 Governor Street Richmond, Virginia 23219 e
Surry Power Station Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219
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SURRY POWER STATION, UNITS 1 AND 2 PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS
- 1.
VALVE TESTING PROGRAM A.
General Questions and Comments ENCLOSURE
- 1.
Provide a list of all valves that are Appendix J, type C, leak rate tested but not included in the IST program and categorized A or A/C.
- 2.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10CFR50, Appendix J. Relief from paragraphs IWV-3421 through 3425 for containment isolation valves presents no safety problem since the inter.t 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 from IWV-3421 through 3425 for any valves that are Appendix J tested to fulfill Section XI requirements.
- 3.
The NRC staff has identjfied rapid-acting power operated valves as those which stroke in 2 seconds or 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 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.
- 4.
10CFR50.55a(g)(5)(ii) states that, "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 of the Surry IST program 1
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appears to conflict with this requirement, Valve testing in the IST program shall conform to the Code requirements unless specific relief is granted.
- 5.
Provide the limiting values of full-stroke time for all power operated valves in the !ST program for our review.
What are the bases used to assign the limiting values of full-stroke time for these valves?
- 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 v
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 !ST program conform to this staff position?
- 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 yerify 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).
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A differe~t 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 valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.
- 8.
The following specific system questions and comments pertain to the valves, pumps, and drawings of Unit 1.
Unless otherwise noted, the questions and comments also apply to Unit 2.
B.
Main Steam System
- 1.
for which Code requirement is Relief Request 1 requesting relief?
- 2.
Review the valve categorization and type for valves TV-MS-lOlA, TV-MS-101B, 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?
- 3.
Provide a detailed technical justification for not full-stroke exercising valves RV-MS-101A, RV-MS-101B, and RV-MS-101C if they have the capability of being remotely operated.
- 4.
How are valves PCV-MS-102A and PCV-MS-102B stroke timed quarterly?
- 5.
Provide a detailed technical justification for not stroke timing and fail-safe testing valve HCV-MS-104.
- 6.
Do valves TV-MS-109 and TV-MS-110 have a required fail-safe position?
- 7.
How are valves 1-MS-176, 1-MS-178, and 1-MS-182 individually verified to full-stroke exercise open and closed quarterly?
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- 8.
What is the safety position(s) of valves NRV-MS-102A, NRV-MS-102B, and NRV-MS-102C and how is the position(s) verified?
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.
P&ID 11448-FM-68A location 1-FW-148 E-7 1-FW-149 E-7 l-FW-163 F-7 1-FW-164 F-7 1-FW-178 G-7 1-FW-179 G-7
- 2.
How are valves 1-FW-144, l-FW-159, and 1-FW-174 verified to full-stroke open?
- 3.
Are each of the following valves disassembled for full-stroke exercising every refueling outage?
l-FW-10 1-FW-43
. 1-FW-12 1-FW-72 1-FW-41 l-FW-74 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?
- 2.
Does the emergency makeup system for the auxiliary feedwater system perform any safety function?
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- 1.
~E. Circulating and Service Wa~ System What safety function(s) do the following valves perform?
MOV-CW-106A MOV-CW-lOOA MOV-CW-1068 MOV-CW-100B MOV-CW-106C MOV-CW-lOOC MO\\/-CW-106D MOV-CW-100D
- 2.
Review the safety function(s) of valves 1-SW-130, 2-SW-130, l-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.
F.
Component Cooling Water System
- 1.
How are valves 1-CC-176 and 1-CC-177 verified to full-stroke exercise?
- 2.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-CC-lOSA TV-CC-llOA TV-CC-1058 TV-CC-110B TV-CC-lOSC TV-CC-llOC TV-CC-107
- 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 1-2, G-1, C-3, and D-1) to determine if they should be included in the 1ST program and tested to Section XI requirements.
- 4.
Review the safety function(s) of valves HCV-CC-100 and the component cooling water surge tank vacuum breaker (P&ID 11448-FM-720, locations A-1 and B-1) to determine if they should be included in the 1ST program and tested to Section XI requirements.
- 5.
How are valves l-CC-557 and 1-CC-563 verified to full-stroke open?
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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.
- 2.
Provide a detailed technical justification for not fail-safe *testing valves TV-IA-101A, TV-IA-101B, and TV-IA-100 quarterly.
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 TV-SS-100B TV-SS-102B TV-SS-104B TV-SS-101A TV-SS-103A TV-SS-106A I. Vents and Drains System TV-SS-101B TV-SS-103B TV-SS-106B
- 1.
Provide a detailed technical justification for not fail-safe testing the following valves quarterly.
TV-DA-lOOA TV-DG-108A TV-DA-100B TV-DG-108B TV-DA-103A TV-VG-109A TV-DA-103B TV-VG-109B 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.
l-RS-11 l-CS-24 l-RS-17 l-CS-105 6
l-CS-13 l-CS-127
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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-1008 TV-LM-lOOC TV-LM-1000 TV-LM-lOOE TV-LM-lOOF TV-LM-lOOG TV-LM-lOOH TV-CV-150A TV-CV-1508 TV-CV-150C TV-CV-1500 L.
Reactor Coolant S~stem
- 1.
Provide a more detailed technical justification for not leak testing valves HCV-1556A, HCV-1556B, and HCV-1556C in accordance with
- IWV-3426 and 3427 (see Relief Request 30).
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- 2.
Provide a detailed technical justification for not full-stroke exercising, not fail-safe testing, and not remote position indication verifying the following valves quarterly (every 2 years for position verification).
How are these valves stroke timed?
SOV-RC-lOOA-1 SOV-RC-lOOA-2 SOV-RC-1008-1 SOV-RC-1008-2 SOV-RC-lOlA SOV-RC-1018 S0V-RC-101C SOV-RC-1010
- 3.
Review the safety function(s) of the following valves to determine if their categorization should be changed.
SV-1551A SV-1551B SV-1551C MOV-1535 MOV-1536 PCV-1456 PCV-1455C
- 4.
Provide a detailed technical justification for not fail-safe testing valve TV-1519A quarterly.
- 5.
Provide a more detailed technical justification for not full-stroke exercising valve 1-PG-65 quarterly and during cold shutdown.
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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.
- 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?
N.
Chemical and Volume Control System
- 1.
How are valves 1-CH-76 and l-CH-92 verified to full-stroke open during quarterly exercising?
- 2.
What are the consequences of valve failure during quarterly exercising of valves LCV-11158 and LCV-11150?
- 3.
~eview 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 IST program and tested to Section XI requirements.
- 4.
Provide a detailed technical justification for not fail-safe testing valve TV-1204 quarterly.
- 5.
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.
P&ID 11448-FM-88B location MOV-1287A B-6 MOV-12878 E-6 MOV-1287C G-6 MOV-1286A B-6 MOV-1286B F-6 MOV-1286C G-6 8
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- 6.
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.
P&ID 11448-FM-BBB location MOV-1267A D-7 MOV-1267B D-7 MOV-1269A F-7 MOV-1269B F-7 MOV-1270A H-7 MOV-1270B H-7
- 7.
Review the safety function(s) of valves MOV-1350 and 1-CH-227 (P&ID 11448-FM-BBB, locations H-6 and 1-6) to determine if they should be included in the 1ST program and tested to Section XI requirements.
- 8.
Provide a detailed technical justification for not fail-safe testing valves HCV-1200A, HCV-1200B, and HCV-1200C quarterly.
- 9.
Provide a more detailed technica1 justification for not full-stroke exercising valve 1-CH-309 quarterly.
- 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.
- 2.
How is reverse flow closure verified for valves 1-SI-50 and l-SI-58?
- 3.
Provide a more detailed technical justification for not full-stroke exercising valves MOV-1869A, MOV-1869B, and MOV-1842 during cold shutdown.
- 4.
How are valves 1-SI-25 and 1-SI-410 verified to full-stroke open and closed during cold shutdown?
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- 5.
Review the safety function(s) of the following valves to determine if their categorization should be changed.
MOV-1890A MOV-1869A MOV-18908 MOV-18698 MOV-1890C MOV-1842
- 6.
Provide a detailed technical justification for not fail-safe testing valves TV-SI-100, TV-SI-102A, and TV-SI-1028 quarterly.
- 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 l-SI-130 l-SI-109 l-SI-145 l-SI-128 l-SI-147
- 8.
What are the consequences of valve failure during quarterly exercising of valves MOV-1865A, MOV-18658, and MOV 1856C?
- 9.
Provide a more detailed technical justification for not full-stroke exercising the following valves quarterly and during cold shutdown.
How is reverse fl ow closure verified for each of these valves?
l-SI-88 l-SI-91 l-SI-94 1-SI-238 1-SI-239 l-SI-240
- 10.
How is reverse flow closure verified for each of valves l-SI-79, 1-SI-82, and l-SI-85?
- 11.
Review the safety function(s) of valves l-SI-235, l-SI-236, and l-SI-237 to determine if their categorization should be changed.
- 12.
What is the accuracy of flow instruments FT-1932, FT-1933, FT-1960, FT-1961, FT-1962, and FT-1963?
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- 13.
If the opera~ity of valves HCV-1853A, HCV-l~B, HCV-1853C, and HCV-1936 {P&ID 11448-FM-89B, locations D-4, D-7, G-5, and H-5) is necessary to fulfill the requirements of Branch Technical Position RSB 5-1, these valves must be included in the IST program and tested to the Code requirements.
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-101 TV-GW-105 TV-GW-lllA TV-GW-111B TV-GW-102 TV-GW-106 TV-GW-103 TV-GW-107 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 TV-BD-100B TV-BD-lOOE TV-BD-lOOC TV-BD-lOOF R.
Radiation Monitoring-Containment Particulate System
- 1.
Provide a detailed technical justification for not fail-safe testing valves TV-RM-lOOA, TV-RM-100B, and TV-RM-lOOC quarterly.
S.
Fuel Oil System
- 1.
Review the safety-related function(s) of 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.
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- 2.
Provide a detailed technical justification for not stroke timing the following valves quarterly.
SOV-EE-100 SOV-EE-103 SOV-EE-101 SOV-EE-104 T.
Containment Purge System SOV-EE-102 SOV-EE-105
- 1.
Provide a technical justification for not verifying valve remote position indication for valve MOV-VS-101 to the Section XI requirements.
U.
Diesel Air Starting System.
- 1.
Provide a more detailed technical justification for not individually exercising valv~s SOV-EG-lOOA, SOV-EG-1008, S0V-EG-300A, and SOV-EG-3008 to the Section XI requirements.
- 2.
Review the safety f~nction(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 IST program and tested to Section XI requirements.
- 2.
PUMP TESTING PROGRAM
- 1.
Relief Request l proposes to utilize ASME Publication 78-WA/NE-5 for pump vibration velocity acceptance criteria.
An acceptable alternative pump vibration velocity acceptance criteria is that of ANSI/ASME OM-6, draft 10.
Provide a copy of 78-WA/NE-5 for our review.
- 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?
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- 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)?
- 4.
Provide the technical justification that demonstrates that flow measurement is not necessary for evaluation of pump performance for auxiliary feedwater pumps 1-FW-P-3A, 1-FW-P-3B, and 1-FW-P-2 (see Relief Request 6).
- 5.
Provide a more specific technical justification for not testing residual heat removal pumps quarterly.
- 6.
IWP-4400 states that rotative shaft speed need not be measured for pumps qirectly 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).
- 7.
Observation of lubricant level or pressure applies only to those pumps that have a lubrication system with level or pressure indication. Therefore, relief from the Code requirement need not be requested for pumps meeting these conditions (see Relief Requests 13 and 14).
- 8.
Provide the specific technical justification that demonstrates that the proposed alternate testing for component cooling water pumps meets the Code requirement for measurement of pump flow (see Relief Request 15}.
- 9.
Provide a more specific technical justification for not measuring vibration for the boric acid transfer and fuel transfer pumps quarterly (see Relief Request 9 and 12}.