ML19339H249
| ML19339H249 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/31/1992 |
| From: | Link B WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-87-06, GL-87-6, VPNPD-92-272, NUDOCS 9208040333 | |
| Download: ML19339H249 (4) | |
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>l ll Wisconsin
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POWER COMPAth'
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231 W. Michigon, Po. Box 2046. Mdwoukee. WI 53201 1414) 221 2345 I
I VPNPD-92-272 NRC-92-086 l
- July 31, 1992 U.
S. NUCLEAR REGULATORY COMMISSION f
Document Control Desk Mail Station P1-137 Washington, D.
C. --
20555
. Gentlemen:
i
-DOCKETS 50-266 AND 50-301 RESPONSE TO UNRESOLVED ITEMS INSPECTION REPORT 50-266/92008(DRS);
50-301/92008(DRS)
I POINT BEACH NUCLEAF PLANT, UNITS 1 AND 2
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Your letter dated May 28, 1992,' transmitted Inspection Report 50-266/92008 (DRS) ; 50-301/92008 (DRS), which consisted of a review of.the Point Beach Nuclear Plant program for_in-service testing (IST)_of pumps and valves and our compliance with NRC positions 7
described in Generic Letter (GL).89-04, " Guidance.on Developing Acceptable In-Service Testing Programs."
Your letter requested i
that we respond to' issues identified in the. Inspection Report as unresolved items. -
l Currently our IST Program Document and IST Program Background Document are being revised to reflect recently completed physical
. modifications to our safety injection (SI) and residual heat removal (RHR) systems.
This revision will also address NRC concerns _ described in your Safety Evaluation Report dated April 17,_1992, which evaluated the third 10-year in-service
. testing program for our Point Beach Nuclear Plant.
In response to.the unresolved items transmitted in your May 28, 1992, Inspection Report, we have identified corrective actions which
. involve the revision of applicable sections of our IST Program
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Document and IST Program Background Document.
These changes will be-incorporated into the planned major revisions of the IST Program Document and the IST Program Background Document, which will be completed by December'11, 1992.
Corrective actions in i
L response to the unresolved items are summarized in the following
_ paragraphs.
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f NRC Document Control Desk July 31, 1992 Page 2 Eggponse to Unresolved Item 266/92008-01(2); 301/92008-01(al-This unresolved item refers to our leak rate testing of some Category A and A/C valves on a system basis rather than on an
-individual basis as required by ASME Section XI, IWV-3420, " Valve Leak Rate Test".
In our letter dated July 30, 1992 (NRC-92-085),
we submitted revised Valve Relief Request VRR-23, " Containment Isolation Valves," to address this situation.
Revised Valve Relief Request VRR-23 lists the valves in question and describes an alternate test method that we believe is appropriate.
The alternata test method involves leak rate testing combinations of valves in parallel arrangements and will utilize the most conservative individual valve leak rate limit as the limit for combined leakage from the entire set of valves.
Approval of that relief request will resolve this issue.
Response to Unresolved Item 265/92008-01(b); 301/92008-01(b)
This unresolved item refers to Section 3.8 of our 1ST Program l
Background Document.
Our IST Program Background Document states that all valves that are designated as high-low pressure interface valves (pressure isolation valves) are included in the IST Program as Category A valves.
Contrary to this statement, 7
our IST Program Document complies wi th GL 89-04, Position 4, l
" Pressure Isolation Valves (PIVs)," and includes testing on only those PIVs that are specifically listed in Point Beach Technical Specifications.
PIVs described in our June 12, 1987, response to GL 87-06, " Periodic Verification of Leak Tight Integrity of Pressure Isolation Valves," which are not specifically listed in our Technical Specifications, are not currently included in our IST Program as Category A valves.
To resolve this discrepancy, we will revise Section 3.8 of the IST Program Background Document to clarify that all PIVs listed in Technical Specifications are required to be included in the IST Program as Category A valves; however, other PIVs may not be required to be included in the IST Program as Category i valves.
Additionally, as part of our major revision to the IST Program
-Background Document, we are re-evaluating those valves listed in our Jv ie 12, 1992, response to GL 87-06 which are not currently inc1'.aed in the IST Program as Category A valves to determine if their inclusionin the IST program is warranted.
Should our evaluation determine that additional PIVs need to be added to the IST Program, we will provide you with our schedule for appropriate program additions and associated test procedure implementation.
We will complete these actions by December 11, 1992. -We believe that these actions will adequately resolve this issue.
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NRC Document Control Desk July 31, 1992 Page 4 i
i Section XI, IWV-1100, " Scope."
Consequently, we do not believe that verification of the position indication is required or l
warranted.
t' The second issue involves the SI accumulator vent valves, SI-00834A and B.
IST Test Procedures IT-240 (Unit 1), " Safety Injection Accumulator Valves," and IT-245 (Unit 2), " Safety Injection Accumulator Valves," requires these valves to be fail-safe tested in the closed direction.
However, Procedure PBNP i
4.12.17, "In-Service Testinc " included acceptance criteria for stroke time testing in the vpen direction only.
On July 24, 1992, PBNP 4.12.17 was revised to incorporate acceptance criteria for stroke time tests of.the subject valves in the closed i
direction.
The IST Program Document and IST Program Background Document-Will be revised by December 11, 1992, to incorporate requirements to test the subject valves in the closed direction.
The third issue involves service water (SW) valves associated with component cooling water (CCW) heat exchangers.
The IST i
Program currently includes testing on the CCW heat exchanger SW outlet valves but does not include testing on the CCW heat exchanger SW inlet valves.
We will revise the IST Program documents to incorporate testing on the CCW heat exchanger inlet valves and will issue appropriate test procedures by December 11, 1992.
He believe that these actions wil) iw uately resolve these issues.
If you have any questions or require additic. 1 information regarding this correspondence, please contact us.
Sincerely, f
g l
e Bob Link l
Vice President l
Nuclear Power i
Copies to NRC Regional Administrator, Region III NRC Resident Inspector r
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