ML19339B869
| ML19339B869 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/29/1980 |
| From: | Trimble D ARKANSAS POWER & LIGHT CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| 2-100-18, NUDOCS 8011100326 | |
| Download: ML19339B869 (9) | |
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w nECE!vf 0 0tSTRIBUT!0N LC.WICES t'h!T ARKANSAS POWER & LIGHT COMPANY POST OFRCE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501) 371-4000 030 l'(f' 10 il 9 I4 October 29, 1980
~_ 3 2-100-18 3
l Directur of Nuclear Reactor Regulation ATTN:
Mr. Robert A. Clark, Chief Operating Reactors Branch #3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555 1
Subject:
Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6 In-Service Testing Program (File:
2-3065)
Gentlemen:
By letter dated February 21, 1980, NRC staff concerns, questions, and comments regarding the In-Service Testing (IST) program for Arkansas Nuclear One - Unit 2 were provided to AP&L.
On March 11, 1980, a meeting was held between AP&L staff and NRC staff and consultants to discuss the information contained in your February 21, 1980, letter.
After reviewing the February 21, 1980, letter and fotes from the meet-ing, AP&L hereby provides, as an attachment to this '9tter, responses to the NRC concerns and questions regarding the ANO-2 IST program.
Very truly yours, M C Tik David C. Trimble Manager, Licensing DCT: MAS: skm Q
Attachment 8011100 32c dio evereo oeomn ome -u
i l
General Comments 1.
The turbine driven emergency feed pump shall be included in the IST program and tested according to the requirements of Section XI, ex-cept during cold shutdown periods when no steam is available to drive the turbine.
2.
All category A and B valves will be stroked and stroke time measure-ments will be taken.
The Code requires comparison with the previous stroke time.
Relief has been requested to allow comparison with the original stroke time.
This is to allow detection of a gradual in-crease in stroke time.
3.
All valves which are in-line for a safety system flow path are category E valves.
4.
At ANO-2 all fail-safe valves are air-operated.
These valves will be tested to their failed pos! tion on a quarterly schedule unless specific relief is requested.
5.
Our position on in-service testing of relief valves is that the ASME Code addresses only those valves which must function in order to safely shut down or to mitigate the consequences of an accident. This position is supported by the clasification of Article IWV-1100 found la the Winter 1977 Addenda.
Only pressurizer and main steam safety valves are in this category.
No other relief valves are to be in-cluded in the IST program A.
Chilled Water (P&ID 2222) 1.
2CV3850, 2CV3851 and 2CV3852 cannot be exercised during power opera-tion as this would result in a loss of cooling water to control rod drives.
These valves will be exercised, according to the Code, during cold shutdowns.
No provisions exist to verify 2AC-49 closed except during a local leak rate test.
This valve will be verified closed at each refueling.
B.
Containment Spray (P&ID 2236) 1.
2BS-5A and 2BS-5B cannot be full stroke exercised during any mode of operation as this would result in spraying down the containment causing damage to safety-related equipment.
To test with air would require draining the spray header riser pipes which would generate 2000 gallons of waste water.
These valves will be partial-stroked during refueling outages by raising the water level in the riser pipes.
The degree of stroke cannot be determined.
These valves are category C instead of A/C.
On the above basis, we hereby request relief from the Code requirement to full-stroke these valves.
2.
2CV5612, 2CV5613, 2CV5647, 2CV5648, 2CV5649 and 2CV5650 are not con-tainment isolation valves and will remain as category B valves.
2BS-4A and 2BS-4B are category C/E valves and are full-stroked during our monthly containment spray pump test.
285-6 is a category C/E valve and is full-stroked using the spent fuel purification pumps.
2BS-44A and 285-44B are category E valves.
3.
2BS-1A and 285-18 are category C valves and are partial-stroked during monthly pump tests.
A full-stroke of these valves is possible only during an accident condition.
For this reason, relief from the Code requirement to full-stroke these valves is requested.
2BS-3A and 2BS-3B are category C valves and are full-stroked during monthly pump testing.
2BS-10A and 2BS-10B are category C valves and are full-stroked during the monthly NaOH addition pump test.
2BS-12A and 2BS-128 are category C valves and are tested quarterly with demineralized water.
2BS-17A and 285-17B are not safety-related.
2PSV5678 and 2PSV5688 are not required to operate in order to safely shut down or to mitigate the consequences of an accident and, therefore, are not to be included in the IST program (see General Comment No. 5).
C.
Component Cooling (P&ID 2234) 1.
Exercising 2CV5236, 2CV5254 and 2CV5255 during power operation would result in a loss of reactor coolant pump seal cooling water, which could damage the reactor coolant pump and require a reactor shutdown.
These valves will oe exercised, according to the Code, during cold shutdowns when the reactor coolant pumps are secured.
No provisions exist for verifying 2CCW-38 closed except during leak rate testing.
This valve will be checked shut during the refueling outage leak test.
D.
Main Steam (P&ID 2202) 1.
2SV0317 is not safety-related and will not be included in the IST program.
2.
The trip throttle valve and the governor valve on the emergency feed pump turbine will be included in the IST program.
Relief is requested from timing the governor valve since it is a modulating valve.
Relief is also requested from stroking the trip throttle valve since it is a passive valve not required to change position during an accident.
s
. E.
Emergency Feedwater (P&ID 2204 sh. 4) 1.
2EFW-4A is categorized C/E and is tested quarterly during power opera-tion.
2EFW-4B is categorized C/E and is tested quarterly during full flow pump recirculation.
Relief is requested from exercising 2EFW-4A and 2EFW-4B during cold shutdown and refueling outages because no steam is available during these periods to run the emergency feed pump turbine.
2.
2EFW-1, 2EFW-16, 2CV0707 and 2CV0706 are not safety-related and will not be included in the IST program.
2EFW-10 is a cat gory E valve locked in a throttled position.
2EFW-2A and 2EFW-2B are category C valves.
Relief from the Code re-quirement to full-stroke these valves is requested because any stroking would result in impure water being introduced into the steam generators and would require an extended outage for cleaning to prevent possible degradation of steam generator internals.
F.
Steam Generator Secondary (P&ID 2206) 1.
2CV1010 and 2CV1060 are partial-stroked during power operation and are full-stroked during cold shutdowns.
Shutting these valves during power operation would cause a loss of ~ steam flow resulting in a low steam generator level causing a reactor trip.
2CV1024 and 2CV1074 cannot be exercised during power operation.
They will be exercised during cold shutdown.
Shutting these valves during power operation would cause a loss of feed flow, resulting in a loss of steam generator level, causing a reactor trip.
2.
2CV1016 is a category B valve.
3.
2EFW-7A, 2EFW-7B, 2EFW-8A, 2EFW-8B, 2EFW-9A and 2EFW-9B are full-stroked quarterly by feeding the steam generator.
2EFW-7A, 2EFW-78, 2EFW-8A and 2EFW-8B are category C/E valves.
4.
The steam generator relief valves are category C.
5.
2CV1001 and 2CV1051 are to be included in the IST program as category B valves.
Relief from stroke testing is requested because these are pas-sive valves not required to actuate during an accident.
i 2MS-40A and 2MS-40B are used for maintenance only.
They are excluded from IST by Article IWV-1300.
2CV-1000 and 2CV1050 are category B valves an'/ will be exercised quar-terly.
1 2MS-39A and 2MS-39B are category-C valves and will be exercised quar-4 terly except. during cold shutdowns when no steam is available.
Since i
these valves open during an accident to supply steam to the EFW tur-bine, verification that the valves shut is not necessary.
Motor i
operated valves provide isolation if needed.
i G.
Service Water (P&ID 2210 sh. 2) 1.
2CV1480 and 2CV1481 cannot be tested during power operation because of the possibility of' unit shutdown due to a loss of service water flow.
2.
2CV1402, 2CV1403, 2CV1407, 2CV1408, 2CV1404, 2CV1405, 2CV1401, 2CV1409, 2CV1445, 2CV1446, 2CV1447, 2CV1448, 2CV1452, 2CV1451 and 2CV1450 are category B valves.
Relief from exercising is requested because these valves are open and remain open during an accident.
i 25W-72 and 25W-73 are category E valves.
2SW-12A and 25W-128'are category C valves.
2ACW-44 and 2CV1460 are not safety related.
G.
(cont.) Service Water (P&ID 2210 sh. 1) 1.
2CV1425 and 2CV1427 cannot be exercised during power operation, shutting these valves would cause a turbine trip resulting in a reactor shutdown.
These valves will be exercised, according to the Code, during cold shut-downs.
2.
Relief from timing 2CV1506 and 2CV1509 is requested because these are modulating valves and timing them is not practical.
i 3.
25W-2A, 2SW-2B and 2SW-2C are category C valves.
2CV1418, 2CV1419, 2CV1420 and 2CV1421 are not safety-related and will not be included in the IST program.
G.
(cont.) Service Water (P&ID 2210 sh. 3) 1.
2CV1541, 2CV1542, 2CV1543 and 2CV1560 cannot be exercised during por;r operation.
Exercising these valves would result in a loss of cooling tower makeup water causing a turbine trip and a loss of condenser
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vacuum.
I 2.
25W-45A, 25W-458 and 2ACW-9 are not safety-related and will not be in-cluded in the IST program.
3.
2CV1510, 2CV1511, 2CV1513 and 2CV1519 are category B valves.
These valves'are open and remain open during an accident.
H.
Fire Water (P&ID 2219) 1.
-There' are-no provisions for checking 2FS-37 shut except during a leak rateLtest.
This_ valve will be checked shut during refueling outage i
leak. rate tests.
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I.
Reactor Coolant (P&ID 2230) 1.
2CV4697 and 2CV4698 are category B valves and are exercised during each refueling outage.. Exercising these valves during power opera-tion or cold shutdown would vent radioactive gas and contaminated i
water into the containment building.
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2.
There are no provisions for checking 2CVC-78 shut except during leak rate testing.
This valve will be checked shut during refuel-ing outage leak rate tests.
3.
2SI-27A, 2SI-278, 2SI-28A and 2SI-28B are not and cannot be tested
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during power operation because of the adverse effects of thermal 4
shock to the injection nozzles.
J.
Chemical and Volume Control (P&ID 2231) 1.
2CV4846 and 2CV4847 cannot be exercised'during power operation be-cause this would cause reactor coolant pump seal damage, requiring a reactor shutdnwn.
Shutting 2CV4873 during power operation would isolate suction to the charging pumps from the Volume Control Tank with possible damage to the charging pumps and would result in loss of pressur-izer level.
2CV4950 cannot be exercised during power operation because this would allow the charging pumps to take suction from.the Refueling Water Tank, causing over-boration of the reactor coolant system-resulting in a reactor shutdawn.
2.
2CVC-70 is a category C valve.
Exercising during power operation is not practical for the. same reason as for 2CV4950.
This valve will be exercised, according to the Code, during cold shutdowns.
2CVC-22A, 2CVC-22B and 2CVC-22C are category C valves and are ex-ercised quarterly.
4 251-24 is not safety-related.
2CVC-28A is not safety-related.
2CVC-28B and 2CVC-28C are full-stroked during cold shutdown by shutting thefupstream M0V's'one at a time.
Exercising these~ valves during power operation would cause thermal shock to the respective -
injection nozzles.
2CV4840, 2CV4824, 2CV4831 and 2CV4827 do not receive containment 1
isolation signals and are not used to mitigate the consequences of an accident.
Therefore, they are not included in the IST program.
3.
2CVC-41A and 2CVC-418 are category C valves tested quarterly.
t.
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2CVC-49 and 2CVC-58 are category C valves.
These valves cannot be exercised during power operation because this would cause over-boration of the reactor coolant system causing a reactor shutdown.
i These valves will be tested, according to the Code, during cold shutdowns.
2CV4920, 2CV4921 and 2CV4916 cannot be exercised quarterly for the same reason as 2CVC-49 and 2CVC-58.
4 2PSV4913, 2PSV4923, 2PSV4932, 2PSV4924, 2PSV4929 and 2PSV4914 are
^
not required to operate in order to safely shut down or to mitigate the consequences of an accident and, therefore, are not included in the IST program.
i 2CVC-53A and 2CVC-53B are category E valves.
2CVC-4926, 2CVC-4927 and 2CVC-4930 are not safety-related.
i K.
Safety ~ Injection (P&ID 2232) 1.
2CV5082 and 2SI-17 are category A valves.
't 2.
Seat leakage past 2CV5038, 2CV5084 or 2CV5086 is inconsequential for fulfillment of their function.
The function of these valves is to protect the LPSI pumps from cavitation after a large break LOCA.
These are category B valves.
Exercising tnese valves during power operation could over pressurize piping downstream of 2CV5086.
These valves will be tested, according to the Code, during cold shutdowns.
3.
2SI-15A, 2SI-158, 2SI-15C and 2SI-15D are category A/C valves. These valves cannot be full-stroked during power operation because the LPSI pumps will not overcome reactor coolant system pressure.
2SI-16A, 2SI-16B, 2SI-16C and 251-160 are partial-stroked during re-fueling outages.
These valves cannot be exercised during power oper-ation because the Safety Injection Tank (SIT) pressure is less.than RCS pressure.
These valves cannot be exercised during cold shutdown because injecting the SIT could cause damage to reactor vessel inter-nal structures and would generate large amounts of liquid radioactive waste.
Also, there is not sufficient volume to accommodate the dis-J charge of the SIT's into the RCS.
Based on the above, we request re-lief from the Code requirement to full-stroke these valves.
4.
2SI-13A, 2SI-13B, 2SI-13C, 25I-130, 2SI-14A, 251-14B, 2SI-14C and-2SI-14D are category A/C valves.
Leak rate testing is not required since there are pressure detectors monitored in the control room located-on the low pressure sides of 2SI-15A, 2SI-15B, 2SI-15C and 2SI-15D.
i 2SI-13A, 251-13B, 2SI-13C and 2SI-130 cannot be exercised during power operation as the discharge head of the HPSI pumps is less than RCS pressure. -These valves cannot be exercised during cold shutdown as'the large flow rates of'the HPSI pumps could cause over pressurization of the RCS.
2SI-14A, 2SI-14B, 2SI-14C and 2SI-140 cannot be exercised during power operation because the discharge head of the LPSI pumps will not over-come RCS pressure.
2CV5091, 2CV5093, 2CV5024, 2CV5004, 2CV5064 and 2CV5044 are not safety-related and will not be included in the IST program.
2CV5003, 2CV5023, 2CV5043 and 2CV5063 are category E valves.
Power is removed and the handwheels are physically locked.
2PSV5007, 2PSV5027, 2PSV5047 and 2PSV5067 are not required to operate in order to safely shut down or to mitigate the consequence's of an accident and, therefore, are not included in the IST program.
l 2SI-22A and 2SI-228 are category C valves and are exercised quarterly.
I 2SI-12, 2SI-7A and 2SI-7B are category C. valves.
Relief from exer-cising is requested on the same basis as for the 2SI-13's.
{
2SI-23A, 25I-238 and 2SI-23C are category C valves and are exercised quarterly.
5.
2SI-19 is located at F-C.
6.
2CV5015, 2CV5016, 2CV5017, 2CV5035, 2CV5036, 2CV5037, 2CV5055, 2CV5056, 2CV5057, 2CV5075, 2CV5076, 2CV5077, 2CV5101.and 2CV5102 are category B vales.
2CV5086 is addressed in the response to Question 2.
7.
2SI-26A and 2SI-26B are category A/C valves.
Relief from exercising and leak testing is requested on the same basis as for the 2SI-13's.
8.
2SI-3A and 25I-3B are category C/E valves and are exercised at cold shutdown for the same reason as for the 2SI-15's.
2SI-10A, 2SI-10B and 2SI-10C are category C/E.
Relief from exercising is requested on the same basis as for the 2SI-13's.
L.
Service Air System (P&ID 2218 sh. 1) l 1.
2SA-68 is category A/E.
2.
2SA-69 is not included in the IST program.
This is a closed system.
Service Air (P&ID 2118 sh. 3)
I' 1.
2IA-15 is not in the program.
This is a closed system.
2.
2IA-14 is category A/E.
M.
Sampling System- (P&ID 2237) 1.
2SV5878 and 2SV5871 are category A valves.
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,1 N.
Hydrogen and Nitrogen Addition System '(P&ID 2239) 2N -1 and 2N -18 are not in the program. This is a closed system.
1.
2 2
. 0.
Heating, Ventilating and Air Conditioning (P&ID 2269) 1.
2HPA-58'and 2HPA-59 are category A/C.
2.
The only means of verifying that 2HPA-58 and 2HPA-59 are shut,is during leak rate testing.
These valves will be verified shut during refueling outages.
3.
25W-40, 25W-41 and 2SW-42 are not safety-related.
25W-48, 25W-49, 25W-50 and 25W-51 are category E valves.
2CV8284, 2CV8289, 2CV8286 and 2CV8291 cannot be exercised during power operation because of the NRC directive to keep these valves shut above the cold shutdown mode of operation.
P.
Plant Heating System (P&ID 2220) 1.
2PH-22 and 2PH-45 are category A/E valves.
2PH-23 and 2PH-44.are not safety-related.
Q.
Fuel Pool System (P&ID 2235) 1.
2FP-34 2FP-35, 2FP-36 and 2CV5432 are category A/E valves.
~
2.
25W-57 provides for emergency makeup to the fuel pool.
It is a cate-gory E valve.
i