ML19242C249

Forwards Request for Addl Info to Complete Evaluation of Inservice Testing Program

ML19242C249
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/29/1979
From:	Reid R Office of Nuclear Reactor Regulation
To:	Cavanaugh W ARKANSAS POWER & LIGHT CO.
References
NUDOCS 7908100123
Download: ML19242C249 (7)

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UNITED STATES

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i NUCLEAR REGULATORY COMMISSION y'C

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'j WASHINGTCN, D. C. 20555 3

June 29, 1979

%,.....f Docket tio.: 50-313 Mr. William Cavanaugh, III Vice President, Generatien and Construction Arkansas Power & Light Comoany P. O. Box 551 Little Rock, Arkansas 72203 Cear Mr. Cavanaugh:

We have reviewed your submittals regarding the extent of your compliance with the requirements of 10 CFR 50.55a(g) for Arkansas Nuclear One, Unit No. I and have detemined additional information is needed to complete our evaluation.

Enclosed is listed the infor,ation which is needed. We believe that much of the information needed can be readily provided through discussion with your staff. Therefore, within 10 days on receiot of this let;er, please arrange a conference telephone call with our staff to close 0;;t these remaining items.

Sincerely, b

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n Robert W. Reid, Chief Operating Reactors Branch 44 Division of Operating Reactors Encicsure:

Request for Additional Infor:*a tion cc w/ enclosure: See next page 790810cm e u,. w...

Arkansas Power & Light Company cc:

Phillip K. Lyon, Esq.

House, Holms & Jewell 1550 Tower Building Little Rock, Arkansas 72201 Mr. David C. Trimble Manager, Licensing Arkansas Power & Light Company P. O. Box 551 Little Rock, Arkansas 72203 Mr. James P. O'Hanicn General Manager Arkansas Nuclear One P. O. Box 608 Russellville, Arkansas 72301 Mr. William Johnson U. S. Nuclear Regulatory Commission P. O. Box 2090 Russellville, Arkansas 72801 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Pcwer Generation Division Suite 420, 7735 Old Georgetown Road Bethesda, Maryland 20014 Troy B. Conner, Jr., Esq.

Conner, Moore & Corber 1747 Pennsylvania Avenue, N.W.

Washington, D.C.

20006 Arkansas Polytechnic College Russellville, Arkansas 72801

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REQUEST FCR ADDITIONAL INFORMATION ARKANSAS NUCLEAR ONE, UNIT NO. 1 INSERVIC: TESTING PRCGRAM

SUBJECT:

These questiens are the result from tt.e Srcokhaven National Laboratory review of the Arkansas Nuclear One, Unit 1 (Cocket 50-313) Inservice Test Program Resubmittai (1-019-6) dated January 15, 1979.

REFERENCES:

A.

BNL-NUREG-25495, "Recommendatiens to the Staff en Arkansas Nuclear One, Unit.1 Inservice Testing Program," December 1978.

Note: This is the SNL' report to the NRC that resulted frcm the IST program SER meeting held at the plant en November 15 & 16, 1978.

B.

Arkansas Nuclear One, Unit i Inservice Testing Program Resubmittal (1-091-6), dated January 15, 1979.

C.

Arkansas Nuc: ear Cne, Unit 1, Inservice Testing Program (pum;s and valves) submittal 1005.08, dated June 18, 1977, (20 month period starting April 1978).

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1.0 CF-1 A and CF-13 Reference B (Encicsure 1, Item 3.0) stated that the subject check valves shall be partial-stroke exercised during each refueling cutage.

Reference 3 (Enclosure 1, Item 3) also stated that " Full-strcking of these valves during ccia shutdcwn could delay start-up more than S hctrs and create as much as 23,CC0 gallcas of licuid waste." While this provided a basis for not full strokirg at cold shutdcwn, it did not provide the informatien re-quired in Reference A (Item 2.2.5.1, Evaluatica) 1.e., to provide information that would indicate the degree of part stroking cbtainable and cvide tech-nical justification as to why full stroking is not practical at refuelings or scme time during service life.

Provide infor~ation concerning the degree of part stroking expected during tests; sucn as a percentage of design ficwrate cbtained or scme other measure.

The licensee shcuid also give specific reascns why full stroking these valves cannet be acccmplished at refueling intervals cr at scme time during service life.

(What are the prcblems inv:lved?)

2.0 MU-320 Curing discussicns at the SER meeting (Reference A, Item 2.2.5, Evaluation),

nis check valve was determined te be in the ncrmai make-u path to :he RCS.

The problem with full strckir.g was uncers: cod to be :nat ficws u: :c 250 GPM would be recuired via the make-u; pum:s and wcuid exceed let:cwn Reference E

1. ica, pcssibly leacing to a hign ressurizer ie"el reac cr trip.

Encicsure 3) incicates tha full strcke exer:isine this valve during n:rmal

ar.: 0;eration v.cuid :nertally shcck the H:: nc::le.

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L s J.2. u U It was cur understanding frcm the SER meeting, that ne MU-340 path was the make-up path and that thermal shock of this nozzle was not a problem.

Review the reasons cited above and confirm for the sake of consistency waich cne is to be used as the basis fe:- relief.

3.0 CV-1214, CV-1215, and CV-1221 The explanation given in Reference B (Enclosure 1) appears to be different than th evaluaticn written in Reference A (Item 2.4.3.1, Evaluation).

Reference B states " Failure of valves in closed positicn would require stopping RC pump seal injecticn and the RC pumps.

Reference A indicates the problem could be high level pressurizer trip. This should be clarified for the sake of consis.tency.

_4.0 CV-1050 Reference B (Enclosure 1) shows the_yalve deleted frca the program. Reference A.

(Item 2.2.3 and 2.2.6.2) shcws the valve as beinc in the program as Catecory S.

The valve is a PressunrIsolation candidate and was questiened as to possibly performing a containment isolation function.

The following information is required before we can evaluate whether or not this valve is to remain in the IST program:

Is the valve a containment isolation valve? Cces it receive a C.I. signal?

5.0 CV-1300 and CV-13vi These valves were listed in Reference C is Category 3".

Reference 3 lists these valves as Category A.

Which is correct? If these valves are Category A, satisfy all the requirements of IWV-3420 or request relief from this paragraph.

6.0 CV-1234 Based on discussions at the SER meeting, Reference A (Item 2.4.t.1) states that the valve wculd be exercised at cold shutdcwn.

Reference B (En-closure 2) states that the valve will be exercised every 3 months to Code.

Please confirm which is correct.

7.C CV-1220 Reference A (Item 2.4.5.1) indicates the reason for strcking this valve at' cold shutdcwn was that makeup flow disruption wculd cccur if the valve was ex-ercised quarterly.

Reference B indicates the reascn as being the potential-to overoressurize upstream piping.

This eheuld be clarified.

Which hasis is correcd S.0 CV-laCa Reference A (! tem 2.5.1) states tnat this valve is in :ne ;regram, and satisfies the Code requirement.

Reference 3 'Encicsure 1) states tnat tais valve is deleted from tne program because ic dces no: change ccsi-icn durinc an emergency.

This valve #: in ne Cecay Heat return line fecm the RCS to the' RMR cume and is cicsoc during ncrmal planc cceraticr..

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The folicwing information is required before we can evaluate whether or not this valve is to remain in the I.iT program.

Is the valve a containment isolation valve? Doe _ sit receive a C.I. signal or safety injectica sigral?

9.0 CV-1428 and CV-1429_

Reference A (Item 2.5.1) states these valves are in the program as Category. I.

Reference B (Enclosure 4) states these valves are deleted frcm the program for the folicwing reasons:

"The valves are used to centrol decay heat and LPI ficw. They do not change position upon ES actuation, and physically cannot be locked which precluces classification as Category E."

The folicwing information is requested in order to cceplete the evalua-tien.

What is the position of the valve during normal pcwer. operaticn - par-tially cpen, full open, etc.? Are these valves required to be operator cen-trolled at any time prior to, during or after LPSI chase?

Provide circumstances where operator centrol of these valves is necessary during emergency candition (if applicable).

10.0 CV-la10 Reference A (Item 2.5.2 and 2.5.5.1) states this valve is in the Reference 3 (Enclosure 4) states this valve is deleted frcm program.

the program because it dces not change position during an emergency.

Reference B also notec that the valve is intericcked to tlose or remain closed when RCS pressure is greater than 290 psig.

The folicwing information is required before it can be determined if this valve can be removed frca the IST prcgram.

It this valve a Centainment Isolation valve? Does it receive a C.I. signai?

11.0 CV-1414 and CV-1415 Reference A (Item 2.5.3.1) states these valves are in the program and treated as passive valves, i.e., cpen and their function is to open during Reference 3 (Encicsure 4) states these valves are deleted an emergency.

frca the program.

In Order to complete t% evaluatien, the folicwing'information is re-quired.

Is there pcwer to these valves or are they racked cut?

Describe hcw pcwer is racked cut if acplicable.

Do these valves have positicn indicators and am the read cuts in :ne centrei recm? At wnat frecuency dces the licensee date: nine by visual inspecticn af the ;csiticn lights and/or actual valve position that these valves are aligned ccen?

Is there a check list precedure to acccmolish this periodic cneck?

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l 12.0 CA-61 and CA-62 Reference A (Item 2.5.4.1) based en the SER meeting stated that these valves will be part stroked only every 3 =cnths.

Reference 3 (Enclosure 2) states that the valves will meet the Code.

Are these v.-lves full stroke exercised during these quarterly tests?

13.0 CV-2415 and CV-2419 Reference A (Item 2.8.3.1) states these valves are in the program as Categcry B with relief requested and'a recomendation that relief be granted.

Reference B states these valves are in the program with no category given, j

but a. notation stating "Lccked in Position." This should be clarified.

How are these valves locked in pcsiticn? Please describe physical and/or administrative methods used to lock these valves.

Are these valves setup to receive a safety injection signal?

l These valves should also be code categorized by the licensee.

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14.0 SS-4A an'd 35-43 I

I Reference A states that the licensee at' the SER meeting had requested re-

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lief to exercise these check valves by conducting air ficw tests every 5 years as part of the Reactor. Building spray header ficw tests.

The staff questioned.the proposed air tests as to the possibility that seat leakate

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past a stuck closed check valve cculd lead to the belief that the valve was being part-stroked open. The licensee was asked to review the l

proposed testing < and provide technical information that would support the proposed air flew tests in light of the staff's concern about seat leakage vs. determinaticn of part stroking.

Reference 3 was reviewed and fcund to request relief for partial stroke exercising at refueling cutages.

Also presented was the licensee's y

basis for not testing at cold shutdcwn.

Mcwever, no information was presente?

to satisfy the ccncern that the air ficw test might not be valid to de=cn-i strate check valve part strcking.

,t The licensee is requested to provide a descrip;ien of the testing perfer-ed to strcke these valves, and shcw hcw it will ce determined that seat leakage across a stuck closed valve can be distinguished frcm the air i

ficw thrcugh a part strcked open valve.

L 15.0 C'/-3323 and CV-3821 i

Reference A (!:em 2.10.2) states these valves are in tne crogram as Category E.

Reference 3 (Encicsure 2) states these valves are Categcry E, bu: nas a no a:icn as follows:

"Tc be removed f = ;rogram " Wny are these valves being remeved from tne pr: gram?

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16.0 CV-3640 thru CV-3646, CV-3Sil, CV-3820 Reference A (Item 2.10.3.1) states that the licensee was to establish the basis for the relief recuest and would provide it.

Reference 3 (Enclosure 3) provided the follcwing statement as the basis for exercising at cold shutdown, " Testing these valves during normal operation, would result in inadequate ficw to components at high elevatiens due to reductions in service water flow."

The basis as presented is inadequate and does not present the information necessary to make a prcper evaluation. Provide a basis for each of these valves that is consistent with the requirerents of NRC Staff Guidance for Preparing Pump and Valve,.. Pursuant to 10 CrR 50.55a(g)," dated January 13, 1975,Section II.

You are requested to answer the folicwing:

What is the position (open or closed) of each of these valves a.

during normal plant operatien?

b.

Can these valves be part-stroke or full-stroke exercised quarterly? If no, give reascns sucn as, what equipment is affected by stroking a particular valve, and hcw specifi-cally might this equipment s operaticn be affected? What is t

the possible consequences to plant Operatica such as reactor trip, turbine trip, etc, 'If applicable?

17.0 CA-90A and CA-903 Reference A (Iten 2,8,4,l} indicates that at the SER meeting, relief was requested to only part-stroke exercise these check valves every 3 months.

Reference B '.(Enclosure 21 states that these valves will meet the Code requi rements. Are these valves considered full-stroke exercised during quarterly tests?

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