ML20129C847

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Requests Addl Info or Clarification of Inservice Testing Program for Pumps & Valves for Second 120-month Interval. Meetings Scheduled for 850820-21 in Bethesda,Md to Discuss Responses to NRC Questions Contained in Encl
ML20129C847
Person / Time
Site: Crane 
Issue date: 07/15/1985
From: Stolz J
Office of Nuclear Reactor Regulation
To: Hukill H
GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8507290572
Download: ML20129C847 (15)


Text

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JUL 151985 o

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Docket No. 50-289 DISTRIBUTION Docket File:

JPartlow WRussell NRC PDR ACRS-10 L PDR RIngram Mr. Henry D. Hukill, Vice President ORB #4 Rdg 0 Thompson and Director - TMI-1 HThompson JThoma GPU Nuclear Corporation OELD Gray File P. O. Box 480 EJordan Glainas Middletown, Pennsylvania 17057 BGrimes RBosnak FCherny JPage

Dear Mr. Hukill:

The staff is reviewing your July 10, 1984 submittal on inservice testing of pumps and valves (IST) for the seccad 120-month interval.

In order to complete our review we and our consultants, EG&G Idaho, need additional information or clarification of your IST program, as outlined in the enclosure. We request that you meet with the staff and discuss your responses. The personnel who attend should be able to provide technical expertise and commitments on the part of GPUN since the staff's final safety evaluation will be based on the results of the meeting.

The meeting has been scheduled for two days, August 20 and 21, 1985, in room P-114, Phillips Building, 7920 Norfolk Avenue, Bethesda, Maryland beginning at 10 a.m.

Mr. Robert Knight of your office has agreed to this schedule.

For further assistance, contact the project manager, Owen Thompson (301) 492-7471.

Sincerely,

=vm wa a w u JVD X. D%%*

John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing

Enclosure:

As Stated cc w/ enclosure:

See next page ORB #4:D ORB #4:DL

4:DL 0 Thompson;cr JThoma b JS[8 7//f/85 7/ff/85 7/

8507290572 850715 PDR ADOCK 05000289 P

PDR

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Mr. Henry D. Hukill Three Mile Island Nuclear Station GPU Nuclear Corporation Unit No. I cc:

Mr. R. J. Toole Mr. Richard Conte 0&M Director, TMI-1 Senior Resident Inspector (TMI-1)

GPU Nuclear Corporation U.S.N.R.C.

Middletown, Pennsylvania 17057 P.O. Box 311 Middletown, Pennsylvania 17057 Richard J. McGoey Manager, PWR Licensing

- GPU Nuclear Corporation Regional Administrator, Region I 100 Interpace Parkway U.S. Nuclear Regulatory Comission Parsippany, New Jersey 70754 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. C. W. Smyth TMI-1 Licensing Manager Mr. Robert B. Borsum GPU Nuclear Corporation Babcock & Wilcox P. O. Box 480 Nuclear Power Generation Division Middletown, Pennsylvania 17057 Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 G. F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trowbridge Governor's Office of State Planning 1800 M Street, N.W.

and Development Washington, D.C.

20036 ATTN: Coordinator, Pennsylvania State Clearinghouse Ivan W. Smith, Esq., Chaiman P. O. Box 1323 Atomic Safety and Licensing Board Harrisburg, Pennsylvania 17120 U.S. Nuclear Regulatory Comission Washington, D.C.

20555 Mr. Earl B. Hoffman I

Dauphin County Courthouse Dauphin County Comissioner I

Sheldon J. Wolfe, Esq., Chairman Atomic Safety and Licensing Board Front and Market Streets U.S. Nuclear Regulatory Comission Harrisburg, Pennsylvania 17101 Washington, D.C.

20555 Dauphin County Office of Emergency Mr. Gustave A. Linenberger, Jr.

Preparedness i'

Atomic Safety and Licensing Board Court House, Room 7 U.S. Nuclear Regulatory Comission Front and Market Streets Washington, D.C.

20555 Harrisburg, Pennsylvania 17101 Dr. James Lamb, III Mr. David D. Maxwell, Chairman Administrative Judge Board of Supervisors 313 Woodhaven Road Londonderry Township Chapel Hill, North Carolina 17514 FRD#1 - Geyers Church Road Middletown, Pennsylvania 17057 Mr. David Hetrick Administrative Judge Mr. Thomas M. Gerusky, Director Professor of Nuclear Energy Bureau of Radiation Protection University of Arizona Pennsylvania Department of Tucsun, Arizona 85721 Environmental Resources P. O. Box 2063 l

Harrisburg, Pennsylvania 17120 l

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GPU Nuclear Corporation Three Mile Island, Unit 1 cc:

Thomas Y. Au, Esq.

Sen. Allen R. Carter, Chairman Office of Chief Counsel Joint Legislative Comittee on Energy Department of Environmental Resources P. O. Box 142 505 Executive House Suite 513 P. O. Box 2357 Senate Gressette Building Harrisburg, Pennsylvania 17120 Columbia, South Carolina 29202 Mr. Bob Stein, Director of Research Ms. Frieda Berryhill, Chairman Comittee on Energy Coalition for Nuclear Power Plant P. O. Box 11867 Postponement 104 Blatt Building 2610 Grendon Drive Columbia, South Carolina 29211 Wilmington, Delaware 19808 Ms. Jane Lee William S. Jordan, III, Esq.

183 Valley Road Harmon, Weiss & Jordan l

Etters, Pennsylvania 17319 20001 S Street, N.W.

Suite 430 Ms. Marjorie M. Aamodt Washington, D.C.

20009 Mr. Norman Aamodt 200 North Church Street Lynne Bernabei, Esq.

Parkesburg, Pennsylvania 19365 Government Accountability Project 1555 Connecticut Ave., N.W.

Ms. Louise Bradford Washington, D.C.

20009 TMIA 1011 Green Street Michael W. Maupin, Esq.

Harrisburg, Pennsylvania 17102 Hunton & Williams 707 East Main Street Mr. Marvin I. Lewis P. O. Box 1535

'6504 Bradford Terrace Richmond Virginia 23212 Philadelphia, Pennsylvania 19149 Jordan D. Cunningham, Esq.

Mr. Chauncey Kepford Fox, Farr and Cunningham Ms. Judith H. Johnsrud 2320 North 2nd Street Environmental Coalition on Nuclear Power Harrisburg, Pennsylvania 17110 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Ellyn R. Weiss Harmon, Weiss & Jordan Mr. Bruce Molholt 2001 S Street, N.W.

Haverford College Suite 430 Haverford, Pennsylvania 19041 Washington, D.C.

20009 l

Mr. Donald E. Hossler Michael McBride, Esq.

501 Vine Street LeBoeuf, Lamb, Leiby & McRae Middletown, Pennsylvania 17057 Suite 1100 1333 New Hampshire Avenue, N.W.

Mr. Ad Crable Washington, D.C.

20036 Lancaster New Era 8 West King Street Lancaster, Pennsylvania 17602

GPU Nuclear Corporation Three Mile Island, Unit I cc:

Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety & Licensing Appeal Board Panel (8)

U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

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s THREE MILE ISLAND, UNIT 1

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VALVEcTESTING PROGRAM

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A.

General Questions and Comments 1.

Provide the limiting value of full-stroke time for each power operated valve in the IST program.

2.

Are all valves that are Appendix J, Type C, leak tested included in the IST program and categorized A or A/C?

3.

All Category A&B active valves must be stroke timed during quarterly testing unless specific relief is requested from the stroke timing requirements of Section XI.

B.

Core Flooding System 1.

In reference to valves CF-V4A/B, the NRC position is that a sample disassembly program of inspection is an acceptable means of full-stroke exercising check valves and should be performed at each refueling outage.

2.

How are valves CF-VSA/B full-stroke exercised during cold shutdowns?

C.

Chemical Sampling and OTSG Chemical Cleaning System 1.

What is the purpose of valve CA-V29 located in the lower left hand corner of Drawing FD-0207 D.

Chemical Addition and Waste Disposal System 1.

What is the purpose of the chemical addition penetration No. 307?

Why is valve CA-Vl92 identified as a passive valve while valve CA-V189 is not?

2.

Does valve CA-V134 perform any function important to safety?

E.

Control Building Chilled Water System 1.

Do any of the temperature control valves shown on Drawing FD-Oli have a required fail-safe positon?

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Emergency Feedwater and Feedwater Systems 1.

Provide a more detailed.tec.hnical justification for not full-stroke exercising valves CO-V16A and CO-V16B during each cold shutdown.

G.

Decay Heat Removal System 1

1.

Review the safety function of valves DH-V1, DH-V2, and DH-V3 to determine if they should be categorized A.

2.

Provide a more detailed technical justification for not full-stroke exercising valves 6H-V1 and DH-V2 quarterly.

3.

Review the safety function of valves DH-V4A and DH-V4B to determine if they should be categorized A.

4.

Review the safety function of valves DH-V6A and DH-V6B to determine if they should be categorized A.

Provide a more detailed technical i

justification for not full-stroke exercising these two valves during power operation or cold shutdown.

5.

How are valves DH-V14A and DH-V148 partial-stroke exercised quarterly?

What alternate methods have been investigated to full-stroke exercise these valves at the Code specified frequency?

6. ' Provide a more detailed technical justification for not f'ull-stroke exercising valves DH-V16A and DH-V16B during cold shutdowns.

7.

ReviewthesafetyfunctionofvalvesDH-V22AandDHY228todetermine if they should be categorized A/C.

f 8.

Provide a detailed technical justification for not full-stroke exercising valves DH-V22A and DH-V22B quarterly. How are these valves full-stroke exercised during cold shutdowns while upstream valves OH-V16A and DH-V168 are only partial-stroke exercised?

9.

What is the safety function of valves DH-V38A and DH-V38B?

10. Review the safety function of valves DH-V59A and DH-V598 to determine if they should be included in the IST program.

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H.

River Water System 1.

Review the safety function -of yalves DR-V6A, DR-V6B, DR-V7A, and DR-V78 to determine if they should be incl 6ded in the IST program.

I.

Emergency Feedwater and Feedwater Systems 1.

How is the EF-V3 partial-stroke exercised quarterly? Provide a detailed technical justification for not full-stroke exercising this valve at the Code specified frequency. Have the internals been removed from this valve?

2.

Provide a more detailed technical justification for not full-stroke exercising valves EF-VilA, EF-VilB, EF-V12A, EF-V128, and EF-V13 during each cold shutdown. How is valve EF-V13 partial-stroke exercised quarterly?

3.

Review the safety function of the following valves to determine if they should be included in the IST program.

Category B Category C EF-VIA EF-V17A EF-VlB EF-V17B EF-V2A EF-V21 EF-V2B J.

Nuclear Services Closed Cycle Cooling Water System 1.

Provide a more detailed technical justification for not full-stroke exercising valves EF-V4 and EF-V5 during cold shutdowns.

K.

Diesel Generator Jacket, Air, and Gear Box Lube Oil Cooler Coolant System 1.

How are check valves EG-V32A/A, EG-V32A/B, EG-V328/A, and EG-V32B/B individually verified to full-stroke exercise quarterly?

2.

Do valves EG-V31A, EG-V31B, EG-V47A, and EG-V47B have a required fail-safe position?

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Penetration Fluid Block, Penetration Pressurization, and Hydrogen Recombiner Systems

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1.

When is the Fluid Block System expected to b' disabled and the valves e

listed removed from the IST program? If these valves remain in the IST program and leakage is important to performing their safety function, they must be categorized A/C.

M.

Emergency Feedwater and Feedwater Systems 1.

Provide the specific technical justification for not verifying valves FW-V12A and FW-V128 closed during cold shutdown and re-fueling outages. What alternate methods have been considered to verify operability of these valves?

N.

Hydrogen Purge System and Miscellaneous Penetrations 1.

How are the following valves fail-safe tested?

HM-VIA HM-V3A HM-VlB HM-V3B HM-V2A HM-V4A HM-V2B HM-V4B 0.

Penetration Fluid Block, Penetration Pressurization, and Hydrogen Recombiner Systems

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1.

How are valves HR-V22A, HR-V22B, HR-V23A, and HR-V238 fail-safe tested?

P.

Intermediate Cooling System 1.

What is the safety function of valves IC-VIA and IC-V1B?

2.

How are valves IC-V2, IC-V3, IC-V4, and IC-V6 partial-stroke exercised during power operation? What are the consequences of valve failure while full-stroke exercising these valves during power operation?

Q.

Main Steam System and Orainage 1.

Provide a detailed technical justification for not full-stroke exercising valves MS-V1A, MS-V1B, MS-VIC, and MS-VID during power operation.

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.C 2.

What are the consequences of valve failure'in the open position j

while full-stroke exercising valves MS-V4A and MS-V4B during power operation?

3.

What alternate methods have been investigated for full-stroke exercising valves MS-V9A and MS-V9B? Are these valves exercised individually? Do these valves perform a safety function in the closed position?

4.

Review the safety function of the following valves to determine if they should be included in the IST program and categorized as indicated.

Category B Category C AS-V4 MS-V22A MS-V8A MS-V22B MS-V8B MS-V6 R.

Make-up and Purification System - Letdown Portion 1.

What is the safety function of valves MU-VIA and MU-VlB?

2.

Provide a detailed technical justification for not full-stroke exercising valves MU-V2A, MU-V2B, and MU-V3 quarterly during' power operation.

3.

Does partial-stroke exercising MU-V3, which normally full-strokes in less than i second, present any operational complications due to isolation of the letdown flow?

4.

Provide a detailed technical justification for not full-stroke exercising valves MU-V25 an'd MU-V26 quarterly during pov3r operation.

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What is the safety function of valve MU-V51?

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6.

Review the safety function of the following valves to determine if they should be included in,rthe IST program.

..w Category B Category C MU-VilA MU-V47 MU-VilB S.

Make-up and Purification System - Make-up Portion 1.

Provide a more detailed technical justification for not full-stroke exercising valves MU-V14A and MU-V148 open quarterly and during cold shutdowns.

2.

Is thermal shock to the injection nozzles a consideration when full-stroke exercising valves MU-V16A, MU-V168, MU-V16C, and MU-V16D during power operation? Are these valves presently being leak-rate tested as containment isolation valves?

3.

Provide a more detailed technical justification for not full-stroke exercising valves MU-V73A, MU-V738, and MU-V73C quarterly during power operation and cold shutdown.

4.

Provide a more detailed technical justification for not full-stroke exercising the following valves quarterly during power operation and cold shutdowns. Do any of these valves perform a containment isolation or pressure boundary isolation function?

MU-V86A MU-V107A MU-V868 MU-V107B MU-V94 MU-V107C MU-V95 MU-V1070 MU-V220 1

5.

What is the safety function of valves MU-Vil6 and MU-V219? Does valve MU-V219 perform a containment isolation function?

6.

What is the safety function of valve MU-V217?

7.

Review the safety function of valve MU-Vil2 to determine if it should be included in the IST program.

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T.

Nitrogen Supply System 1.

Is there another containment isolation valve associated with NI-V27 on the nitrogen line at penetration 307?

U.

River Water System 1.

What is the safety function of valves NR-V4A and NR-V4B?

2.

Review the safety function of the following valves to determine if they should be included in the IST program and categorized as indicated.

Category B Category C NR-V6 NR-V22A NR-V2 NR-V228 NR-Vl9 NR-V22C NR-V18 NR-V29 V.

Nuclear Service Closed Cycle Cooling Water System 1.

Provide the specific technical justification for not full-stroke exercising valves NS-V4, NS-V15, and NS-V35 during power operation.

2.

How is valve NS-Vil full-stroke exercised closed (its safety position) quarterly during power operation?

3.

Are valves NS-V52A/B/C and NS-V53A/B/C leak tested to Appendix J requirements to demonstrate their containment isolation function?

4.

Do any of the following valves have a required fail-safe positon?

NS-V55A cooling water to control building NS-V558 coolers NS-V48A cooling water to control building NS-V48B air conditioning W.

River Water System 1.

Review the safety function of valves RR-V10A, RR-V108, RR-V12A, and RR-V128 to determine if they should be included in the IST program.

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X.

Nuclear Services Closed Cycle Cooling Water. System 1.

Review the safety function.of the following valves to determine if they should be categorized A.

RR-V3A RR-V4B RR-V3B' RR-V4C RR-V3C RR-V4D RR-V4A 2.

Provide a more detailed technical justification for not full-stroke exercising the following valves quarterly during power operation and cold shutdowns.

RR-V8A RR-V8B RR-V9A RR-V98 RR-V9C 3.

Provide the P&ID that shows valve RR-V90.

4.

Review the safety function of valves NS-V12 and RR-V6 to determine if they should be included in the IST program.

Y.

Reactor Building R/0/C System 1.

What is the purpose of this system?

2.

Is valve RB-V7 motor operated as indicated in the IST program or pneumatic as indicated on the ISI Boundary sketch.

3.

Provide the specific technical justification for not full-stroke exercising valves RB-V7 and RB-V2A quarterly during power operation.

4.

Review the safety function of valve RB-V2 to determine if it should be included in the IST program.

Z.

Reactor Building Spray System 1.

Review the safety function of the following valves to determine if they should be categorized as indicated.

Category A Category A/C BS-VIA BS-V30A BS-VlB BS-V308 8

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2.

How are valves BS-V30A and BS-V308 partial-stroke exercised quarterly? In reference,to, full-stroke exercising these valves, the NRC position is that a sample disassembly program of inspection is an acceptable means of full-stroke exercising check valves and should be performed at each refueling outage.

3.

How are valves BS-V23A and BS-V238 full-stroke exercised quarterly?

4.

In reference to valves BS-VS2A and BS-V52B, the NRC position is that a sample disassembly program of inspection is an acceptable means of full-stroke exercising check valves and should be per-formed at each refueling outage.

5.

Are there any vacuum breakers that perform a safety function installed on the sodium hydroxide tank?

AA. Reactor Coolant System 1.

What is the safety function of valves RC-V1 and RC-V37 2.

Review the safety functions of valves RC-V4 and RC-V23 to determine if they should be categorized A and A/C respectively.

3.

Is RC-RV2 utilized for low-temperature overpressurization protection of the RCS at TMI-l?

BB. Spent Fuel Coolant System 1.

Review the safety function of the following valves to determine if they should be included in the IST program.

Category B Category C SF-Vl/2/3/4/5/6 SF-47 SF-48 SF-Vil/12/13/14/15/16 SF-V50 SF-V51 CC. River Water System 1.

Review the safety function of the following valves to determine if they sho.uld be included in the IST program and categgrized as indicated.

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Category B Category C SW-V24A

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SW-V6A SW-V248 SW-V6B SW-V23A SW-V8'A SW-V23B SW-V8B DD. Miscellaneous Questions and Comments 1.

Provide a more detailed technical justification for not full-stroke exercising the valves and testing the pumps identified in Relief Request IV and Pump Note 12, respectively, during cold shutdowns.

2.

Provide an explanation of the alternate test methods that have been investigated to verify operability of main feedwater check valves FW-V12A and FW-V128.

(Reference Relief Request X).

3.

Since Techniccl Specification required testing is typically utilized to verify system operability and Section XI required testing is utilized to verify individual component operability, then testing in accordance with Technical Specifications may not meet the requirements of Section XI. Therefore, provide the specific technical justification for not testing components identified in Relief Request III whose function is important to safety at the Code specified frequency.

4.

Are the boric acid recycle pumps and/or boric acid pumps utilized to establish the proper boron concentration in the RCS when approaching cold shutdown conditions?

5.

Provide a detailed technical justification for not full-stroke exercising and stroke timing the following valves quarterly in accordance with Section XI.

WDL-V49 WDL-V89 WDL-VSO WDL-V90 WDL-V61 WDL-V91 WDL-V62 WDL-V92 10

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a PUMP TESTING PROGRAM A.

Emergency Feedwater and Feedwiter System 1.

Is' instrumentation available to allow measurement of flow (Q) while testing the EFW pumps?

(Note 9 does not agree with Section XI, 1980 Edition.)

B.

Nuclear Service River Water System 1.

Do plant heat loads during cold shutdowns require operation of more than one nuclear service river water pump? Can individual pump flow rates be measured at that time?

C.

Nuclear Service Closed Cooling Water System 1.

Do plant heat loads during cold shutdowns require operation of more than one nuclear service closed cooling water pump? Can individual pump flow rates be measured at that time?

D.

Reactor Building Emergency Cooling System 1.

Provide the P&ID that shows the flow path utilized during reactor building emergency cooling pump quarterly testing.

2.

Provide the specific technical justification for not performing the reactor building emergency cooling pump complete Section XI testing.

  • during cold shutdowns instead of refueling outages.

E.

Screen Wash System 1.

In reference to the pump flow measurement, the present NRC position is that lack of installed instrumentation is not sufficient justification for not performing the required Section XI testing.

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