ML20116M899

Forwards NRC Response to Section 3.2.3.1 of SE for Second Ten Year Insp Interval for IST Program

ML20116M899
Person / Time
Site:	Hatch
Issue date:	11/23/1992
From:	Beckham J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
HL-3014, TAC-M59202, TAC-M59203, NUDOCS 9211230111
Download: ML20116M899 (13)

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,, 4 Geotgia Power Cornpany 40 invemess Contor Parkway Post Otteo Box 1295

, ' OM19 ham, AJatane 35201

, Te!<$;5 ore 205 eM7279 J. T. ex khamia..

A Georgia Power

%cn Pres.r$ont Nuciow Hatch Project N *w.'WoM me.:ns W HL-3014 004251 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UPITS 1, 2 hnC 00CKETS 50-321, 50-366 OPFRATING LICENSES DPR-57, NPF-5 SiuGND TEN YEAR INSPECTION IfiTERVAL IST PP0 GRAM SAFETY EVALUATION RESPONSE NRC 1AC NOS. M-59202 AND M-59203 Gentlemen:

By letter dated May 28, 1992, Georgia Power Company (GPC) submitted a proposed schedule for addressing the Appendix A items contained in the Safety Evaluation (SE) issued on GPC's Second 10-Year Inspection Interval IST Program. In the proposed schedule, the Appendix A items were categorized into three tables. Table 1 included items for which GPC is in agreement with the SE. Table 2 included items for which GPC submitted additional justification by letter dated June 5, 1992. Table 3 included items whic!, GPr intended to evaluate and provide a response by -

November 17,199F In accordance with the submitted schedule, the enclosure provides a response for the items included in Table 3. A response to 5ection 3.2.3.1 of the SE is also provided in the enclosure. Copies of the revised relief requests reflecting the proposed changes are provided as an attachment to-the enclosure.

2000SG 9211230111 92112a PDR ADOCK 05000321 /Iod 0 PDR 1 g

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GeorgitiPower eb-U.S. Nuclear Regulatory Commission Page Two GPC will implement the appropriate IST program changes, as required, within 6 nonths of receipt of NRC cpproval. Should you have any questions in this re;sd, please contact this office.

Sincerely, _

,' h

. . T . Beckha:a, Jr . k JKB/cr -

Enclosure cc: Eeoraia Power Comoany Mr. H. L. Sumner, General Manager - Nuclear Plant NORMS U.S Nuclear R'culatory Commission. WashinatonmC.C.

Mr. K. Jabbour, Licensing Project Manager - Hatch <

U.S. Nuclear Reaulatory Commission. Reaion H Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector - Hatch _

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t ENCLOSURE PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPP.-57, NPF-5 FABLE 3 ITEMS FROM APPENDIXJ

ENCLOSURE PLANT HATCH - UNITS 1, 2 NRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 TABLE 3 ITFES FROM APPENDIl l Backaround lhe enclosure provides a summa y listing and GPC's response to the 11 items from Apper.d'x A of the IST Program Safety Evaluation (St) categorized by GPC as Table 3 items. A response to Section 3.2.3.1 of the SE is also included.

Appendix A .

o item Number .GPC Response '

A7 Item A7 concerns the leak rate testing performed on valves that provide both a containment isolation function and a pressure isolation function.

Per the IST program, containment isolation vulves (CIVs) and valves serving a dual CIV and pressure ir91ation valve (PlV) functicn are tested per 10 CFR 50, Appendix J, and ASME .,

Sectior. XI, paragraphs IWV-3426 and IWV-3427(a). PlVs-are leak tested per ASME Section XI, IWV-3420 except for IWV-342)(b). Va'ves performing a dual CIV/PIV function are tested only to CI! acceptance criteria as it is more st-ingent than the PIV acceptance criteria, item A7 requested the IST program be revised to include documentation for each valve performing a dual CIV/PIV function demonstrating that the Appendix J leak test-bounds the ASME Section XI leak test or otherwise verifies the valve's ability to' perform its pra sure GPC has performed the necessary isolation function.

studies and calculations to justify that the Appendix J leak test 'oounds the Section XI leak test. The study shows that the CIV leak test provides reasonable assurance of the valve's leak tight integrity. This information e'll be retained in plant records and is dvailable for NRC review. -

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A10 Relief Requast RR-V-39 proposed to measure the stroke time of the scram discharge volume vent and drain valves as a group rather than individually. Item A10 stated that the proposed method does not allow for detection of-individual valve degradation and some method should be developed to monitor irdividual valve condition.

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ENCLOSURF (Continued) l TABLE 3 ITEMS FROM APPENDIX A Appendix A Item Ncmber GPC Response A10 (Continued) GPC has investigated tht possibility of measuring individual stroke times and concluded this method would represent an ur.aecessary hardship, given the design of~

the scram discharge volume vent and drain valves; The subject valves are not equipped with individual valve control switches and are controlled by a single test'

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switch, and_ the test circuit- uses an- alternate vent path which directly affe ts the valves' operating time.

Consequently, the opening time during normal operation _ .

testing is not representative of- the actual opening time. Also, full stroke time testing during normal:

operation would require disabling the Reactor Protection =

System scram signal to the subject valves. - The :i installation d electrical jumpers and opening links in-

an energized control circuit results in the potential of a reactor scram.

All Relief Requests RR-V-3? and RR-V-40 'equested relief-from measuring the stroke time- of -the 'til'. purge supply-valves. The. valves are' not equipped with remote l position indicating lights _and the valve stem is not l observable for- position indication. GPC proposed to verify valve movement quarterly by observing a change in

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the system purge flow rate. Item All' stated that GPC's '

l_ proposed testing provides no means of detecting valve-degradation and some- means-:should~ be developed to monitor valve condition.

i- The relief requests have been . revised' to provide L

additional justification and to provide' for trending:of I' the local -leak rate .te:, ting ' data -in an attempt to L monitor valve degradation.

A13 Relief Requests RR-V-14 and RR-V-17 requested relief .

from exercising the RHR injection check valves. on a quarterly basis to verify forward flow operability.

Plaat design does not provide any method for a fGli flow exercise during r.ormal' operation - or during aormal 'RHR HL-3014 '

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EllCLOSUREL (Continued) .

TABLE 3 ITEMS FROM APPENDIX'A-Appendix A Item Nurnber GPC Response ,

A13 (Continued) operation during shutoowa. :Iten A13 stated that_ the.

relief requests provided no justification for! not- I partial-stroke exercising both valves during each cold. l shutdown and requested GPC to investigate and_ implement,-

if practicable, a method to demor. strate that these valves fully open when subjected ~to shu.down- cooling- ..

flow. .

q The relief rea m 3 have been revised to provide' i l jurtification 'cr not partial-stroke exercising both.

valves _ during each cold-shutdown.._ The: revision also provides for a partial exercise ~ of at least one of these valves each co'd shutdown with. testing to L alternate between valves for each cold shutdown. LGPC has'also investigated Aether the valves can. be demonstreted tx De fully ope w,'en r.ubjected to shutdown cooling flow.

For Unit 1, the valves are not full open during RHR operation in the shutdown cooling mode. To Full ope,i in this mode, two RHR pum;,s would-be required; nowever, the net J.ositive suction head requirements are not met with this al ignment. Consequently, both _ valves will -be partial-stroke exercised each refueling outage ar.d mach check valve will be mechanically exercised in accordance with IWV-3522(b), et each refueling outage, to veri fy_-

full. stroke-capability.- For-Unit 2, the valves have.a smaller cross-sectional-' area and are fully exercised-when_ subjected to chutdown cooling fl ow. The. relief L requests have been revised accordingly and-copies' are attached to-the enclosure.-

! A14 Relief Request RR-V-22 requested relief from-exercising l' and -stroke timing the RHRSW 'heate exchanger outlet-l valves. Item A14 stated _that-the proposed testing does l not provide for detection of valve degradation and some L method -should be developed to detect and monitor-valve condition. The relief request ihas been revised to provide. additional justificetion _ for the proposed-testing and to implement comparison time testing--per l

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ENCLOSURE (Continued)-

TABLE 3_JTEMS FROM APPEND 1X A Appendix A Item Number GPC Resbonse-

- A14 (Continued) IWV-3417(a) to detect valve degradation. 14 copy of the-revised relief request is attached to the enc'osure. .

A15 Relief Requests RR-V-13 and RP-V-16 requested: relief:

from exercising the core spray injection. check valves on-a quarterly basis to verif'. #orward flow cperability.

Plant design does not pronde a_ method for full flow exercising of these valves _during normal ' system operation. Item A15 stated that GPC should full stroke exercise _ these valves using a mechanical exerciser per:

IWV-3522(b) or verify a full stroke exercise when the valves are subjected -to system flow on at least- a ,

refueling outage frequency if practical.

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Full flow testing of these valves during shutdownL conditions is not practical due to the resulting i degradation -of reactor coolant qua ,ty. Consequently, '

each check valve will be mechanically exercicedi=in-accordance with IWV-3522(b), at each refueling outege,.

to verify _ full stroke capability. The relief _ requests-have been revised accordingly and copies are attached to the enclosure.

A20 Item A20 concerned the IST-program scope for the reactor core isolation cooling system (RCIC) - val ves.

Previously,- RCIC system valves, other than those which perfnrm La cantainment isolation 'furction, _could';be; deleted from the IST program if the, accident analysis-did not take credit for the RCIC. system. GPC's position continues to be that the. system should'not.be included-in the IST program asLit is not included-in any accident-analysis, HL-3014 004251 E-4 x

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ENCLOSURE (Continued)

TABLE 3 ITEMS FROM APPEN0lX A Appendix A i item Number GPC Response '

A22 Relief Request RR-V-20. requested relief from exercising and stroke timing seventeen plant service water.. power.

operated valves and proposed to verify proper operation by assigning a maximum stroke time and measuring stroke _-

times by direct observation during quarterly - test.

These valves are air operated ar.d do not have indicating lights or control switches. Item A22 stated that.the proposed tests do.not provide fur detection of-valve >

degr_adation and that some method should be developed to detect and- monitor -valve conditions - Relief Request RR-V-20 has been revised such that- the subject valves will be stroke timed by observing ' actual stem movement when the associated room coolers are placed in service.

The requirements of IWV-3413, except as. described f bove, and IWV-3417 will be applied to provid> a method t to -

detect- and monitor valve condition. -A copy -'of the-revised relief request is attached to the enclosure.

A23 Relief Request RR-V-19 requested relief from exercising the high preswrc coolant injection (HPCI) system pump-room cooler utlet check valves and proposed to sample disassemble, inspect, and manually exercise these valves -

during refueling outager. The design of the system does not provide a _means for positive verification -of-the-flow. rate. through-each valve. Item A23 stated that GPC: -

should partial stroke exercise these valves.with flow :

following disassembly and that! GPC-should-investigate the use of non-intrusive diagno_stic techniques to_ verify these valves full _ stroke exercise open when subjected--to partial flow.

The relief -request -has been revised and nb longer proposes -to sample di s9ssemble, inspect, and manually- ,

exercise the' . valves. The relief equest references-GPC's Plant Service Water System perforaance monitoring program which ' performs periodic '11.x measurements throughout the system to detect. potential flow ._and/or

-component degradation. The subject -. puap -room coolers are included in the monitoring _ program. T_hese measurements are typically ~ performed corresponding .to each ' scheduled refueling outage. Temporary ultrasonic HL-3014

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i ENCLOSURE (Continued)

TABLE 3 ITEMS FROM APPENDIX A Appendix A Item Number GPC Response A22 (Continued) flov: measuring instruments are used tr obtain the system fleu rates and these rates are compared to the design-basis acceptance criteria for each location. -The monitoring program will confirm that the check - valves are capable or performing their safety function.

Tre. ding of the flow measurements will provide data-which 10 potentially indicative of check ivalve degradation.

A24 Relief Request RR-V-41 requested relief from exercising the diesel generator service water outi?t check valves and proposed to perform a partial-stroke exercise --

quarteray and a full-stroke. exercise at refueling-outages during the diesel generator- tests by observing; that the diesels are properly cooled. item A24 stated-that GPC hsd not identified the power levels at" which.

the diesels are operated during the Equarterly and refueling outage test and requested GPC to perform a study verifying that the refueling ~ outage. diesel test produces a sufficient load on the cooling system to quali fy these as a full stroke exercise. Also, GPC was requested to determine i# direct flow measurements can >

be used to verify the flen through these valves.

Relief Request RR-V-41 has been revised to provide the approximate power levels at which the diesels' are tested. The diesel testing- performed duringLrefueling outages. is of sufficient magnitude to confire'that the valves will open sufficiently to perform their uesign safety function. Additionally, GPC proposes ~ to disassemble, manually exercise, and visually inspect- one valve every third refueling outage on a rotating basis.

The flow elements inoicated on the P&I0s.(P41-N526 and N528) were installed' and utilized during construction only. Present Instrument and Controls Department ~

records do not contain flow versus differential pressure

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curves for these elements; thu's, their use for direct-flow measurement for IST of the. discharge check valves is impractical.

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H ENCLOSURE (Contino %

TABLE 3-ITEMS FROM f f iQL L Appendix A Item Number -GPC Response .

A24 (Continued) A copy of the revised relief request-is attached:to the-enclosure.  :

A26 Relief Request RR-V-31 requested relief from measuringL the stroke times of the torus to drywell vacuum breaker-test valves. Item A26 stat <J that GPC's proposal provided no means of dett. ting valve degradation.

A subsequent review has shown that the subject test valves provide ro active safety function. The valves' are located 'n the torus to drywell vacuum breaker test circuit. Theref)re, _ these_ valves .have. been-recategorized as "A passive" in the IST program and are not required to be exercised and stroke timed per ASME Sectica XI. Consequently, tne relief ra ;uest is: not required and is being withdrawn.

SER ltem Set. tion 3.2.3.1 Although this _ item is not'~ contained in -Appendix A, Section 3.2.3.1 of the - SE discusses.GPC's proposed testing of the main-steam safety relief valves. Section 3.2.3.1 stated that GPC - has not formally'_. requested relief from measuring the stroke times- of these valves-l and that GPC's- prop al does' not p* ovide adequate information-to' monitor valve degradation.

l Relief Request RR-V-29 has been ~ revised to : provide-additional information relative to the valve degradation concern. All pilot operating _--assemblies and at -least I one valve body are removed and sent to an_ independent:

testing laboratory each. refueling outage. Because of-the maintenance, testing, and adiostments performed each refueling outage, additi(nal t: sting ~ methods to dotact i~ valve degradation are unw? r r anted . A copy of the l revised relief request is attached to the enclosure.

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ATTACHMENT TO ENCLOSURE PLANT HATCH - UNITS 1, 2 <

NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, HPF-5 REVISED RELIEF REQUESTS

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, l RELIEF-REQUEST-RR-V 32 i i

l SYSTEM: TIP System VALVE: 2C51-F3012 CATEGORY: A CLASS: 2 FUNCTION: Containment Isolation TEST REQUIREMENT: IWV-3413 requires that power operated valves be stroke timed quarterly and IWV-3417(b) requires-comparison testing.

BASIS FOR REllEF: This valve is not provided with indicating lights and the valve stem is not observable for position indication, There are no other system provisions other than indirect means (i.e., flow measurement) to determine valve position. Therefore stroke timimg is impractical.

This is a rapid acting solenoid valve which if stroke-timing was possible, comparison time testing would not be required per the guidance of GL 89-04 Position 6. Per Position 6 of GL 89-04, valves with stroke times of less than or equal to 2 seconds are considered rapid acting valves which do not require comparison time testing.

The nitrogen purgo line is relatively small (3/8") and the FSAR evaluation indicates that even in the event of a neutron monitoring instrumentation dry tube failure, the radioactive release would remain within the required limits.

This valve is local leak rate tested -(LLRT) at each refueling outage in accordance with 10 CFR 50, Appendix J.

LLh, should indicate any problem with the valve seating characteristics which cculd be indicative of improper valve operation, l

l ALTERNATE TESTING: Valve will be exercised quarterly and N, flow will be observed as an indirect means of determining the required change in position. Observation of N, flow canfirms valve position only and does not provide data relative to valve stroke time.

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RR-V-32 (cont.)-

Additionally,- the valve is exercised closed each refueling outage and closure-is verified by means of 10 CFR 50 Appendix J local leak rate testing (LLRT).

LLRT data will be trended in an attempt to monitor and detect any valve degradation.

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