ML19263E267
| ML19263E267 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/27/1979 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| NUDOCS 7906050450 | |
| Download: ML19263E267 (8) | |
Text
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UNITED STATES e[..
,7[*g NUCLEAR REGULATORY COMMISSION
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WASHINGTON, 0. C. 20555 o
'N.'....J' April 27, 1979 Docket No. 50-155 Mr. David Bixel Nuclear Licensing Administrator Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201
Dear Mr. Bixel:
We have completed a preliminary review of your February 1,1979 transmittal of the Big Rock Point Plant Description of Inservice Test Program for Pumps and Valves and Requests for Relief from Specific ASME Code Requirements." We find that additional information is required to continue our review.
Enclosed are the questions and comments that need to be resolved. Past experience with the same review at other plants shows that the most efficient and effective way of resolving the remaining questions is through a meeting at the plant with the NRC reviewers, the plant operating personnel, and the responsible Inservice Testing Engineer. A written response is not required at this time, but please be prepared to discuss the enclosed questions at a meeting at Big Rock Point.
It is our understanding that the dates of May 16 and 17,1979 are tentatively acceptable to your staff for the meeting. The dates for the meeting were selected so an additional working day is avail-able if the discussions need to be continued.
The following reviewers will represent the NRC at the plant' visit:
John Fehringer, EGG Herb Rockhold, EGG Alan Wang, NRC Vic Nerses, NRC 2300 191 79060504%
f Mr. David Bixel April 27,1979 If you have any questions concerning the enclosure or the proposed meeting, please contact Stanley Nowicki.
Sincerely, b
4 Dennis L. Ziemann, Chief Operating Reactors Branch #2 Division of Operating Reactors
Enclosure:
Inservice festing Program Questions and Coments cc w/ enclosure:
See next page 2300 192
Mr. David Bixel April 27,1979 CC Mr. Paul A. Perry, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon, Esquire Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Hunton & Williams George C. Freeman, Jr., Esquire P. O. Box 1535 Richmond, Virginia 23212 Peter W. Steketee, Esquire 505 Peoples Building Grand Rapids, Michigan 49503 Charlevoix Public Library 107 Clinton Street Charlevoix, Michigan 49720 2300 193
INSERVICE TESTING PROGRAM QUESTIONS AND COMME!4TS BIG ROCK POINT PLANT 50-155 1.
General A-Of these pumos and valves for which relief from the Code is required, the following information should be included.
1.
Identification of the conconent for which relief is recuested:
a.
Name and number as given in FSAR b.
Function c.
ASME Section III Code Class o.
For valve testing, also specify the AS!iE Section XI valve Category as defined in IWV-2000 e.
The PSID which contains the valve or pump f.
The location of the component on the P&ID by the use of coordinates.
2.
Specific identification of tne ASME Code requirenent that has been determined to be impractical for each component.
3.
Information to support the determination that the requirement in (2) is impractical; i.e., state and explain the basis for requisting relief.
4 Specification of the inservice testing that will be performed in lieu of the ASME Code Section XI requirements, if any. What type of Appendix J testing, if any?
5.
The schedule for implementation of the procedure (s) in (4).
B.
Although it is prudent to maintain occupation radiition exposure for inspection personnel as low as practicable, the request for relief from code requirements cannot be granted solely on the basis of high radiation levels.
A balanced judgment between the hardships and comoensating increase in the level of safety must be explicitly justified. Therefore, detailed information regarding the radiation levels at the required tett location, along with estimatec yearly man-rem exposures associated with the testing, should be provided. Alternative testing techniques that have been considered should be discussed.
If these alterrative techniques have been determined to be impractical, the basis for this determination should be provided.
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. C.
The inservice testing program should clearly identify which valves are applicable to each of the categories listed above, and relief requests should provide the infor=ation requested so that these requests may be granted where justified.
II.
Comments and Questions - Pumps A.
Core Soray (CS) System 1.
Are the CS pumps driven by fixed or variable speed motors?
2.
How is inlet pressure measured or calculated?
3.
What are the specific reasons used to support the determination that these pumps cannot be tested during cold shutdowns?
S.
Fire and Post Incident Cooling System (M-123) 1.
What is the safety related function of the fire jockey pump?
III. Co ments and Ouestions - Valves A.
General 1.
Provide a list of all valves that require a check of valve position indicators per IWV-3300.
2.
Provide a list of all power operated valves, and stroke time limits required by IWV-3410(C)(1).
3.
Steam and Condensate System (M-106) 1.
Review the safety related function of containment isolation valves CV-4016 and CV-4090 to determine is they should be included in the IST program c.nd categorized A.
2.
The NRC staff considers the following containment isolation v31ves CV-4107, MO-7067, CV-0 04, and the turbine stop valve safety related, and therefore they should be included in the IST program and categorized A.
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- C.
Reactor Cleanuo, Thutdown, and Poison Systems (M-107) 1.
What specific technical basis was used to support the determination that valves M0-7052, 7053, 7062, and 7063 cannot be exerci:ed at cold shutdowns?
2.
What are the specific technical reascns used to support l
the detemination that valve CV-4020 cannot be exercised l
at cold shutdowns?
3.
What is the safety related function of the liquid poison supply check valve (location B-17)? How is this valve full j
stroke exercised? Why can't this valve be exercised during
{
cold shutdowns?
l 0.
Nuclear Steam Succly System (M-121) 1.
What is the specific technical basis used to succort the detemination that valve CV-4050 cannot be exercised during I
cold shutdowns?
2.
Provide more specific information on how the liquid poison supply to reactor vessel check valve (location L-12), and liquid poison suoply to reactor vessel recirculation pump suction check valve (location M-8), are full stroke exercised?
3.
What is the technicai basis used to support the deteminatica 7
that valve MO-7050 cannot be exercised during cold shutdowns?
4 What technical basis was used to make the detemination that valve M0-7065 cannot be exercised during power operation or during cold shutdowns?
5.
Provide more specific information concerning how the feedwater check and its associated stop check are leak tested and why i
these valves cannot be exercised during cold shutdowns?
l 6.
Are valves M0-N001, fiOO2 and N006 required to change position on a safety signal to perfom their safety function?
E.
Control Rod Drive System (M-122) 1.
What is the technical basis for not full stroke exercising
' valves CVNC-09 and 10 each cold shutdewn?
2.
What is the safety related function of valves CVNC-Il and 12?
2300 196
. F.
.Fj e and Post Incident Coclino System (M-123) 1.
Provide more specific technical information about why the CS pump discharge and tank inlet checks cannot be exercised during power opera. tion or cold shutdowns?
2.
Provide more detailed infomation on how CS primary ar.ri back-up check valves (location D-8) are full stroke exercised quarterly?
3.
What is the specific technical basis for not exercising CS primary check valves (location 0-10) during cold shutdowns?
4.
What specific technical basis was used to support the determination that valves M0-7064 and 7068 cannot be exercised during cold shutdowns?
5.
Why is valve M0-7068 disabled clcsed?
6.
The NRC staff censiders the following valves safety related, and therefore they should be included in the IST program and cat:rgorized as follows:
Cateoory E VPI-4 L.0. (location 0-16)
VPI-6 L.C. (location 0-12)
VPI-7 L.C. (location P-12)
VPI-8 L.O. (location P-12)
VFP-30 L.0. (location N-6)
VFP-29 L.0. (location 0.6)
VPI-9 L.C. (location P-13)
VPI-l L.0. (location 0-10)
VPI-2 L.0. (location 0-11)
VPI-3 L.0. (location 0-15)
VFP-5 L.0. (location G-15)
VFP-6 L.0. (location F-15)
VFP-13 L.0. (location H-17)
VFP-14 L.O. (location G-20) i VFP-15 I. 0. (location G-19)
~
VFP-16 L.O. (location B-21)
VFP-17 L.0. (location B-24)
VFP-18 L.O. (location C-21)
VFP-19 L.0. (location H-20)
VFP-34 L.O. (location C-21) 2300 197 VFP-35 L.0. (location G-19)
Catecory B M0-7069(lyationN-8)
. Category C VFP-304 (location G-15)
VF0-309 (location F-15) 7.
What is the safety related function of the fire system accumulator?
l G.
Reactor Deoressurizing System (M-A203) 1.
What is the specific technical basis used to support the determination that valves SV-4984, 4985, 4986, and 4937 cannot be full stroke exercised?
i H.
Radwaste System (M-108) (M-107) 1.
The relief request concerned with Technical Specification 3.7.3 is not required. Both the old and the proposed Technical Specifications are in accordance with the recuire-ments of Section XI.
I.
Make-uo and Condensate Deminerali:ation (M-110) l 1.
The NRC staff considers containment isolation valves CV-4105 (location J-22) and check valve (location J-24) safety related, and therefore they should be included in the IST program and categorized A.
J.
Reactor Buildina Heating, Ventilatinc, and Coolino (M-125) 1.
Which of the reactor building ventilation line containment isolation valves receive a safety signal?
2.
Are there any cooling and heating water automatic isolation valves outside the containment sphere?
K.
Service and Instrument Air (M-133) 1.
Is service air or instrument air required inside the ccntainment sphere post accident to perform a safety function?
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