ML20073C548
| ML20073C548 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 03/31/1983 |
| From: | Tucker H DUKE POWER CO. |
| To: | Adensam E, Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20073C549 | List: |
| References | |
| NUDOCS 8304130220 | |
| Download: ML20073C548 (12) | |
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DuxE POWER GOMPANY P.O. HOX 331f50 CIIAHLOTTE, N.o. 2fl242 II AL 11. TUCKEH TELEPHONE (704) 373-45 M vum recasarer nennam emosn:mmg March 31, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission-Washington, D. C.
20555 Attention:
Ms. E. G. Adensam, Chief Licensing Branch No. 4 Re: McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 IWP/IWV Pump and Valve Inservice Testing Programs
Dear Mr. Denton:
My letter of August 17, 1982 submitted Revision 3 of the McGuire Nuclear Station (Unit 1) pump and valve inservice testing program. EC&G Idaho, Inc., which has
,_,,been performing a review of the McGuire Unit 1 program under contract to the NRC, generated a list of questions and comments concerning this resubmittal for which responses are required in order that they can complete the draft safety evaluation report for Unit 1.
Please find attached (Attachment 1) this listing with Duke Power Company'r responses.
Also, pursuant to 10 CFR 50.55a(g), enclosed for NRC staff use and review are ten copics of Revision 4 (dated March 31, 1983) to the Unit 1 program. This revision reflects the above nentioned responses as well as additional miscellaneous changes and corrections. Also incorporated into the revision are valves required to be tested by the addition of the Standby Shutdown Facility, and a redefining of cold shutdown testing to prevent a limited shutdown from incurring increased downtime for testing not otherwise required. Note that where responses to EG6G's questions and comments led to revisions in the program, the affected page(s) were indicated after our response.
Additionally, pursuant to 10 CFR 50.55a(g), enclosed for NRC staff use and review are 10 copies of the McGuire Nuclear Station Unit 2 pump and valve inservice testing program (original issue). Because of the similarities of the two units, the Unit 1 and 2 programs are essentially identical, although certain differences exist 'such as those associated with the deletion of the Boron Injection Tank System on _ Unit 2 and systems shared by both units being covered under the Unit 1 program only. This Unit 2 program reflects the results of EG6G's review of the Unit 1 program, including the questions and comments referred to above, and other aspects of Revision 4.
Note that the Unit 1 program has been reprinted in its entirety to facilitate its incorporation into a single multi-unit manual. Both units' programs (with enclosed 8304130220 830331 k (i i
PDR ADOCK 05000369 P
PDR gp a
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~q Harold R. Denton March 31, 1983 Page 2 separation tabs) should be inserted into your Unit 1 binder, removing the earlier version (Revision 3) Unit 1 program, and replacing the binder's inserts with the new " Unit I and 2" inserts (also enclosed).
Duke Power Company intends to implement the Unit 1 program as revised and the Unit 2 program on an interim basis pending approval by the NRC.
By copy of this letter, one copy of each of the above documents is also being provided to NRC-Region II.
Very truly yours,
/h_
C' Hal B. Tucker, Vice President Nuclear Production PBN:jfw Attachment Enclosures cc:
(w/ attachment-enclosures)
Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street NW, Suite 2900 Atlanta, Georgia 30303 Mr. Herb Rockhold Idaho National Engineering Lab.
EG6G, Inc.
1520 Sawtelle Street Idaho Falls, Idaho 83401 Mr. W. T. Orders Senior Resident Inspector-NRC McGuire Nuclear Station l
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Harold R. Denton March 31,-1983 Page 3 bec: (w/ attachment-enclosures) W. M. Sample (MNS) (5) (CN's 14-18) P. B. Nardoci (CN19) G. A. Copp (CN20) D. B. Blackmon (CN21) S. D. Alexander (CN22) P. R. Herran (CN23) R. A. Johansen (CN24) Steve Hart (CN25) W. G. Hallman (CN26) W. F. Beaver (CNS) (CN27) H. B. Tucker (CN28) ^ Mike Misenheimer (CN31) Licensing-PBN (CN's 32-35) Section File (CN29) Master File (CN30) (w/o attachments-enclosures) M. D. McIntosh (MNS) Rick Smith (MNS) G. Galbreath (MNS) B. H. Hamilton (MNS) H. B. Barron.(MNS) i Bill Leggette (MNS) N. A. Rutherford K. S. Canady R. O. Sharpe R. E. Harris W. H. McDowell-R. W. Revels M. G. Semmler (MNS) Jack Boyle (MNS) T. L. McConnell (MNS) G. W. Cage (MNS) D. R. Bradshaw (MNS) J. E. Snyder Section File MC-802.01 (w/ attachment 1 only) --tr. -e ,.. ~. y _e
,.p 1[- i s.: DUKE POWER COMPANY RESPONSE TO EGSG IDAHO, INC.'s QUESTI0flS At;D COW.E 4TS CO?iCERflItiG THE MCGUIRE,'UtlIT 1, RESUS.'ilTTAL DATED AUGUST 17, 1982 W I f l l l l l
,f e, Page 1 of 8 Y The fcilcaing question:; and comments are'idcr.ufiec Ly the page number of the IST prcgrca and, in parentheses, the applicaale iter.(s) of the working meeting minutes. The working meeting was held March 23, 24, & 25, 1982. Page 1.1-1 Do paragraphs I.A and I.B apply to all pumps in the IST (Pump Testing program? Item 1) DPC: No, they apply as stated in the paragraphs themselves (Pg. I.1-1). I.1-1 Should paragraphs I.A and I.B be combined? DPC: No, for the reasons stated in above response / revision. 1.1-1 What are the two systems referenced in paragraph I.C? identifies only one system. DPC: There is only one system--centrifugal charging pumps (Pg. I.1-1). I.1-2 Paragraph III.A, Alternate Testing, states the condition l of the chilled water pumps will be determined using vibra-tion data only while the data sheet (Attachment 1) states all parameters except bearing temperature will be monitored. Should the relief request be clarified to include the in-formation from Attachment I? DPC: Yes (Pg. I.1-2, I.1-4). I.1-3 How is flow rate of the Diesel Generator Room Sump Pumps verified? DPC: The time which it takes to pump a known volume from the sump is recorded and converted to a flow rate (P. I.1-3). E 1.1-4 NOTE 1 - Is vibration instrumentation accuracy + 20%. DPC: No, the portable instruments used to measure vibration have an uncertainty of +11%. Relief requested. (Pgs. I.1-1, 11.4-1 When is corrective action taken concerning valves with I.1-4). stroke times of less than 5 seconds? DPC: Maintenance will be initiated if valve time exceeds maximum limit (Pg. II.4-1). 11.5-2 Relief Request for valve IVE-11 is unnecessary because leak testing is the only testing required by the Code for Category A/C Passive valves. DPC: Relief request for IVE-11' will be deleted (Pg. II.5-2, II.5-3) )
M f.= ~ 'Page 2 of 8' ? II.6-5 Should the coordinates for valve ICA-86A be C-13? Should the coordinates for valve ICA-li68 be E-13? DPC: Yes, coordinates are C-13 and E-13 respectively (Pg. 11.6-5). 11.6-10 (C.9) How are valves ICA-165 and -156 verified operable? 1 DPC: By disassembly (Pg. II.6-10). 4 11.9-4 Is valve lHV-223 listed twice? Should the valve at coordinates E-10 be -233? j DPC: Yes, second listing of valve 1NV-223 at coordinates E-10 should be valve INV-233 (Pg. II.9-4). II.9-6 (F.7) Concerning valve li:V-78, what are the consequences if l pressurizer level control is lost? ] DPC: Could result in a plant shutdown (Pg. II.9-6). 11.9-8 Should " Alternate Testing" specify cold shutdown? DPC: Yes (Pg. II.9-8). II.9-9 (F.16) Concerning valves 1NV-244A and -245B, what are the conse- ~' quences if charging is lost? DPC: Could result in loss of pressurizer level control and could result in' plant shutdown (Pg. II.9-9). II.9-10 (F.23) Should valve liiC-225 be INV-225? Why can't lHV-225 and -231 (F.18) be exercised during power operation and cold shutdown? DPC: See ' response "A" on last page. 11.9-11 (F.18) Should valve INC-223 be INV-223? Why can't this valve be (F.14) exercised during power operation? Why is it partial-stroke exercised during cold shutdown? DPC: ' See response "B" on last page'. 11.9-12 (F.17) What operational problems are associated with exercising (F.14) INV-221A and -222B during power operation? DPC: See response "C" on last page. II.10-5 Should IKC-47 Test Alter. be RF instead of CS to agree with the relief request? DPC: Yes (Pg. II.10-5). II.10-12 Why would failure of valves IKC-3328 and -333A while testing i force unit shutdown? DPC: See response "D" on last page. 11.10-13 (G.10) Why would failure of valve IKC-320A while testing force unit shutdown? DPC: It would isolate flow to the RCDT heat exchanger resulting in boiling of the water in the RCDT, causing overpressuri-zation of the RCDT (Pg. II.10-13). r 1 ~ r
Page 3 of 8 ^ 11.13-5 Are all valves listed operated only during cold shutdowns?- Wnat are the restrictions of Tech. Spec. 4.6.1.9? DPC: See response "E" on last page. 11.14-2 Should if(S-21 Test Alter. be RF instead of blank? DPC: Yes (Pg. II.14-2). 11.14-3 Shoula INS-4, -13, and -16 Test Alter. ce RF instead of blank? DPC: Yes (Pg. II.14-3). II.14-4 (J.2) Hcw are valves INS-30, -33, -16, -13, -46 anc -41 full-stroked during refueling outages? DPC: By disassembly (Pg. II.14-4). II.14-5 (J.4) How are valves INS-21 and -4 full-strcke exercised? Accord-ing to the minutes, the closed position is USR. The relief request does not address partial-stroke and the basis does ~ not agree with the minutes. DPC: See response "F" on last page. l II.15-2 Should valves IRV-32A, -33B, -77B, and -76A have relief request indicated? DPC: Yes (Pg. II.15-2). 11.15-4 (K.1) Same valves as II.15-2. What are the consequences if cooling-water is lost to containment? DPC: Would result in a steep rise in lower containment temperature which could exceed tech. spec. limits and cjLute a plant shutdown 11.21-2 (T.2) Should valves ICF-137 have relief and CS indicated?hP. II.15-4). DPC: No, indication of relief and CS on page II.21-2 was inadvertent. Valve will be full stroked and timed quarterly (Pg. II.21-2). II.21-3 (T.2) Valves ICF-134, -135, and -136, same as -137 above, are continuation of question II.21-2. Minutes of the meeting state all four valves will be exercised quarterly. DPC: As above, indications were inadvertent. Valves will be full stroke exercised and stroke timed quarterly (Pg.11.21-3). 11.21-4 Should valves ICF-151, -153, -155, and -157 indicate a relief request and be identified for CS testing? These valves were tested quarterly in the old program. DPC: Indication of relief and CS on page II.21-4 was inadvertent. Valves will be tested quarterly (Pg. II.21-4). 11.21-8 (T.3) Provide a more detailed technical basis why valves ICF-126, j -127, -128, and -129 cannot be full-stroke exercised during power operation. DPC: Cycling valve during power operation could induce unwanted transients in steam generators. It would result in an increase in flow to the main feedwater nozzles causing vibrations in the preheater section of the steam generators (Pg. II.21-8).
~ f Page 4 of 8 9 t 11.23-2 Relief request colu:.n for valve INF-229 is blank. DPC: Should have a "X" indicating relief request (Pg. II.23-2). 11.24-2 Should valves IVI-124 and -149 be AC instead of A? DPC: Yes, valves are category AC (Pg. II.24-2). 11.25-1 System title should be Main Steam. DPC: Yes, " stream" was a typo. (Pg. II.26-1) II.25-2 Should Test Alter.. column be blank? l DPC. No, the test alter column for the valves on Page II.26-2 should have "CS" in accordance with the relief request (Pg.II. i 1 II.25-3 (Y.2) Does the Basis for Relief apply equally to all~ valves listed? 26-2) Should the relief request be rewritten to reflect the meeting minutes? DPC: See response "G" on last page. 11.30-2 Why is Category C valve INM-67 leak tested? ~ DPC: Valve is Category AC, not C. (Pg. II.30-2). II.30-3 Why is Category C valve INM-68 leak tested? ~ DPC: Valve is.Cateogry AC, not C (Pg.11.30-2). 11.31-4 Should valve 1RN-63A listed be -63B? DPC: Yes, valve is 1RN-63B (Pg. II.31-4). 11.31-5 Should valves 1RN-21A and -22A Test Alter, column indicate RF instead of CS? DPC: See response "H" on last page. 11.31-6 Should valves IRN-26B and -25B Test Alter. column indicate RF instead of CS? DPC: Same as above (Pg. II.31-13). I1.31-11 Should valve IRN-253BA listed be -253A? DPC: Yes, Valve is 1RN-253A. (Pg. II.31-11). 11.31-12 What equipment could be damaged while exercising Category B ~ valves 1RN-63B and -64A? DPC: The positive displacement charging pump and the computer room l Do valves IRN-21 A, -22A, (-25. II.31-12)8 all serve the same air conditionino. Pa 11.31-13 (AA.2) 8, and -2o strainer? l DPC: No, they serve nuclear service water strainers 1A and 1B, not just 1A as was indicated on rel'ief request (Pg. II.31-13). 11.31-16 (AA.15) What equipment could be damagedwhile exercising Category B valve IRN-42A? DPC: The positive displacement charging pump and the computer room air conditioning (Pg. II.31-16).
Page 5 of'8 II.32-2 Are tne pressurizer PORVs exercised quarterly in accor-dance with Technical Spcifications rather than Section XI requirements? ~ DPC: Valves are tested in accordance with Tech. Specs, which require cycling of. PORV every 18 months. Relief requested (Pg. 11.33-2 (CC.2) Should valves 1FW-13, -4, and -11 be identified as passive??II.32-2, DPC: Valves should be categorized A passive and leak II.32-5). rate tested per Appendix J (Pg. II.33-2). 11.33-3 (CC.4) Does valve IFW-28 require a relief request? DPC: No. This valve will be full stroke exercised quarterly using the full flow test line to RWST. 11.34-2 (DD.3) Do valves I!1D-8 and -23 require a relief request? DPC: No. These valves will be full stroke exercised quarterly (ref. CC.4) using the full flow test line to RWST. II.34-3 Should valves IND-70 and -71 Test. Alter.~ column be blank? DPC: No, test alternative column should indicate "RF" in accordance with relief requests (Pg. II.34-3, II.34-5, II.34-7-). 11.34-4 (DD.1) Is the 600# setpoint correct? The meeting minutes state 385#. ~' DPC: The setpoint should be 385 psig. (Pg. II.34-4). II.34-5 (DD.4) Should valves 1.ND-70 and -71 have separate rel.ief requests? Existing relief request does not agree with meeting minutes. DPC: Valves should have separate relief requests. New relief re. quests. conform to meeting minutes. (Pg. II.34-3, II.34-5,11.34-7). II.35-3 Should valve 1NI-27 listed be -21? DPC: Yes, valve is 1NI-21 (Pg. II.35-3). 11.35-4 Should valve INI-48 Test Alter column be blank? DPC: No, test alternative column should indicate "RF*" in accordance with relief request.. (Pg. II.35-4). II.35-5 Should valve IN1-436 Test Alter. column indicate Appendix J testing? (RF*) DPC: Yes, testing alternative should be RF* (Pg. II.35-5). 11.35-9 Should valve 1NI-166 listed be -160? DPC: Yes, valve is 1NI-160. (Pg. 11.35-9). II.35-9 (EE.15) Should valve 1NI-153 be deleted from the program to agree with the meeting minutes? DPC: Yes, valve is non-safety related and therefore should be deleted (P Should valve 1NI g. II.35-9). 11.35-10 (EE.21) 166 listed be -176? Should valves INI-175 and -176 have relief requests supplied? DPC: See response "I" on last.page. II.35-13 (EE.23) Should UHI Rupture Disc have relief request indicated? DPC: No, relief indication was inadvertent. The UHI rupture disc will be tested per Tech. Specs., no relief required (Pg. II.35-13).
i g ~ f w.,. g /, Page 6 of 8 \\ p II.35-18 (EE.6) Should two relief requests be written because the flow path is not identical for all four valves? Existing relief request does not agree with meeting minutes and is not as cceplete. DPC: Two relief requests are necessary becuase of differing flow paths, and were written to conform to meeting minutes. (Pg. II. II.35-20 (EE.6) Should two relief requests be written because the flow path]35-5, II.35-18, is not identical for all four valves? Existing relief u.35-20)e 11 request does not agree with meeting minutes and is not as complete. DPC: Same as above (Pg. 11.35-5, II.35-18, II.35-20). 11.35-21 (EE.10) Why can't the SI pumps be operated during power operation or cold shutdown? DPC: See response "J" on last page. 11.35-22 (EE.ll) Does failure while testing render SI inoperable? What are the consequences if suction from the FWST is isolated to the SI pumps? DPC: See response "K" on last page. 11.35-23 (EE.ll) What are the consequences of not having a flow nath? DPC. Would result in damage to the SI pumps. (Pg.1I.35-23). II.35-24 (EE.13) Provide a more detailed technical basis why valves lNI-116 and -148 cannot be exercised during power operation and cold shutdown. DPC: See response "L" on last page. 11.35-25 (EE.16) Provide a more detailed technical basis why valves INI-128, (EE.13) -159, -160, -156, -124, and -157 cannot be exercised during power operation and cold shutdown? DPC: Same.as above (Pg.II.35-25). 11.35-26 (EE.16) Are valves INI-129, -125, -134, and -126 full-stroke exercised during cold shutdowns? DPC: Yes, (Pg. 11.35-26). II.35-28 (EE.21) Why can't the SI pumps be run during power operation or cold shutdown? DPC: See response "M" on last page. 11.35-30 (EE.23) Why can't valves INI-184 and -185 be exercised during cold shutdown? l DPC: Valves can't be tested without renaering both trains of RHR inoperable, and during cold shutdowns the RHR pumps are required for decay heat removal. (Pg. 11.35-30).
n. + ~,' Page 7 of 8 .A II.35-31 (EE.27) Why can't valves 10I-243, -249, -250, -251, -252 and -253 be exercised during cold shutdown? DPC: At cold shutdown, the high velocity water could cause damage to reactor internals. This also could cause low temperature overpressurization. (Pg. II.35-31). Duke Power Company Responses (Cont.) A. 1NC-225 should be 1NV-225. Valves cannot be full or partial stroke exercised during power operation or cold shutdown because shutting these valves would isolate the normal charging suction and the alternate suction paths would result in increasing the RCS boron inventory and could result.in plant shutdown. Full stroke exercising during cold shutdown could result in a low temperature overpressurization of the RCS. (Pg. II.9-10). B. 1NC-223 should be 1NV-223. Valve cannot be full or partial stroke exercised during power operation since shutting the valve would isolate the normal charging suction and the alter-nate suction paths would result in increasing the RCS boron inventory and could result in plant shutdown. Valve cannot be full stroM exercised during cold shutdown since this could result in a low temperature overpres ization of the RCS (Pg. II.9-11). ~ C. Shutting these valves would isolate the normal charging suction and the alternate suction paths would result in increasing the RCS boron inventory and could result in a plant shut down. (Pg. II.9-12). D. It would inhibit the flow path through the RCDT heat exchanger, and since no alternate flow'. path is available steam would be released to the RCDT which would.become overpressurized. (Pg. II.10-12). E. Technical Specification 3/4.6.1.9 restricts opening of valves IVP-1, IVP-2, IVP-3, and IVP-4 at power to less than or equal to 90 hours per 365 days. The rest of the VP valves may not be opened at all during power operation (Pg. II.13-5). F. Valves are full stroke exercised by disassembly, and will be partial stroked quarterly. Basis for. relief is that full stroke exercising with flow.would; require spraying the reactor building. (Pg. II.14-5). G. Valves 1SM-1,3,5, and 7, main steam isolation valves, will be' partial stroke ~ exercised quarterly. These valves cannot be full stroke exercised during power operation since shutting an MSIV could result in plant shutdown. Tech. Spec. requirements'do not; permit. ~ plant operation with a steam generator isolated. The MSIV bypass valves,1SM-9,10,11 and i 12, will be full stroke exercised quarterly. However, these valves cannot be stroke timed at this frequency since this operation will be utilizing the hand controller. These valves will be. stroke timed during cold shutdowns. The r.elief request has been rewritten (Pg. II.26-3). H. No, it has been determined that these valves can be timed at cold shutdowns 'instead of during ESF testing at refueling. The relief request has been revised accordingly. (Pg. II.31-13). I. Valve listing should be 1NI-176. Valves INI-l'5 and INI-176 should have relief requests since they cannot be full or partial stroke axercised during power operation because the RHR pumps cannot overcome RCS pressure to open these check valves. These valves will be full stroke exercised during cold shutdowns. (Pg. II.35-10, II.35-29). J. Valve cannot be full stroke exercised during power operation since the only full flow flowpath is into the RCS and the SI pumps cannot overcome RCS ' pressure. During cold shutdown this valve cannot be full ' stroke exercised since this could result in a. low temperature overpressurization of the RCS. (Pg. II.35-21).
c ) Page 8 of 8 Duke Power Company Responses '(Cont.) K. Failure of valve in closed position would isolate suction from FWST to both safety injection pumps. This would render both trains of SI inoperable. (Pg. II.35-22). L. Valves cannot be full or partial stroke exercised during power operation since the safety injection pumps cannot discharge into the RCS at operating pressure. During cold shutdown these valves cannot be full: or parital stroke exercised since the SI pumps are required by Tech. Specs. to be deenergized.to prevent a low temperature overpressurization. (Pg. II.35-24). M. Valves cannot be full or partial stroke exercised during power operation since the SI pumps cannot overcome RCS pressure to permit flow through these valves. During cold shutdown exercising these valves could result in a. low temperature overpressurization of the RCS. (Pg. II.35-28). .i I, 4 i ) 1 .i I ,}}