ML20134J159
| ML20134J159 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/22/1985 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 5211-85-2138, NUDOCS 8508290192 | |
| Download: ML20134J159 (41) | |
Text
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GPU Nuclear Corporation NggIgf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
August 22, 1985 5211-85-2138 Office of Nuclear Reactor Regulation Attn: John F. Stolz, Chief Operating Reactors Branch No. 4 Washington, D.C.
20555
Dear Mr. Stolz:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Pump and Valve Inservice Testing (IST)
This is in regard to your letter of July 15, 1985 and July 29, 1985 which requested additional information or clarification of GPUN's July 10, 1984 submittal on inservice testing of pumps and valves (IST). We have been requested to meet with your staff and the NRC contractor, EG8G Idaho, on September 4-5, 1985 to discuss their questions.
We understand that EG&G Idaho reviewers received only the aperture cards for ISI Sketches and some of the prints from the cards were illegible. Had they received the full set of prints (ISI Sketches and Piping and Instrumentation Drawings) which we sent to the NRC, the answers to many of their questions would have been apparent. Therefore, we have provided 4 sets of the drawings (listed in Attachment 1) directly to your staff and to the contractor. Two sets were sent to Mr. Owen Thompson of the NRC and two sets to Mr. Herb Rockhold of EG8G Idaho, We understand the drawings were received in both locations on August 19, 1985. addresses the questions and comments from your letter of July 15, 1985.
0500290192 050022 DH ADOCK 0300 9
GPU Nucloar Corporation is a subsidiary of the General Public Utilities Corporation d
l/l
5211-85-2138 August 22, 1985 i
Since only two meeting days have been scheduled for what appears to be a lengthy list of agenda items, we are providing this information along with the i
drawings. 11opefu11y we can eliminate as many of the items as possible from that agenda prior to the meeting.
Sincerely,
.$,f*5b' II. D.
ukill Director, TMI-1 HDH/MRK/spb cc:
J. Thoma, NRC Project Manager R. Conte, NRC Resident Inspector H. Rockhold, EG8G Idaho
- 0. Thompson, NRC 0339A l
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ATTACHMENT I Corresponding GAI Drawine Number system 302 Drawinas ID-ISI-FD-001 Main Steam and Drains 011, 012, 121, and 719 Systems ID-ISI-FD-002 River Water System 202 ID-ISI-FD-003 Decay Heat Closed Cycle 645 Cooling Water System ID-ISI-FD-004 Core Flooding System 711 ID-ISI-FD-005 Decay Heat Removal System 640 and 669 1
ID-ISI-FD-008 Condensate System 101 ID-ISI-FD-009 Emergency Feedwater and 081 i
Feedwater System ID-ISI-FD-010 Nuclear Service Closed Cycle 610 I
Cooling Water System ID-ISI-FD-011 Controlled Building Chilled 847 Water System ID-ISI-FD-012 Reactor ButIdtng Spray System 712 ID-ISI-FD-013 Diesel Generator Jacket.
354 Air and Gear 8on Lube 011 Cooler Coolant System ID-ISI-FD-014 Screen Wash and Slutce 203 System Alver Water Pumps Lubrication System ID-ISI-FD-015.
Penetration Fluid Block, 705, 707, 725 and Penetration Pressurization, 0-901-22-001 and Hydrogen Recombiner Systems ID-ISI-FD-016 Makeup and Purification 660 System (Letdown Portion)
ID-ISI-FD-017 Makeup and Purification 661 System (Makeup Portion)
ID-ISI-FD-018 Spent Fuel Cooling System 630 ID-IS!-FD-019 Reactor Coolant System 650 ID-ISI-FD-020 Chemical Sampling and OTSG 671 and 196 Chemical Cleaning Systems ID-IS!-FD-021 Chemical Addition and Liquid 670, 690, 692, and 669 Waste Disposal Systems ID-ISI-FD-022 Intermediate Coolng System 620 ID-!SI-FD-023 Hydrogen Purge System and 231, 271, 694, 706.
Miscellaneous Penetrations 720, 721, and 831
Attachment No. 2 INSERVICE TESTING OF PUMPS AND VALVES A
GPUNC RESPONSE TO NRC CONTRACTOR QUESTIONS AND COMMENTS
REFERENCES:
1)
Letter, R. W. Reid to R. C. Arnold, November 17, 1976 2)
Letter, J. F. Stolz to H. D. Hukill, August 3, 1981, CHS/81-194 3)
Letter, H. D. Hukill to J. F. Stolz, July 10, 1984, 5211-84-2149 4)
Letter, J. F. Stolz to H. D. Hukill, October 23, 1984, 5211-84-3359 5)
Letter, H. D. Hukill to J. F. Stolz, March 19, 1985, 5211-85-2035 I.
VALVE TESTING PROGRAM A.
GENERAL QUESTIONS AND COMMENTS QUESTION:
A.1 Provide the limiting value of full-stroke time for each power operated valve in the IST program.
RESPONSE
Appendix A provides the requested list of limiting value of full stroke time for all the power operated valves in the IST Program. Please be advised that this limiting stroke time is subject to change. When limiting stroke times are changed, appropriate analysis per INV-3413 and 10 CFR 50.59 Will be performed to demonstrate applicable Code and safety standard compliance.
QUESTION:
A.2 Are all valves that are Appendix J. Type C, leak tested included in the IST program and categorized A or A/C?
RESPONSE
All Appendix J. Type C valves are included in the IST Program and they are categorized A or A/C.
QUESTION:
A.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.
RESPONSE
All Category A and B active valves are stroke timed each quarter unless it is impractical to do so during plant operation.
Footnotes in Table 8-1 of the IST Pump and Valve Submittal (Reference 3) state the Attachment No. 2 details of why it is not practical or safe to full stroke the footnoted valves during plant operation.
Relief is not needed since ASME Section XI IWV-3412 states " Valves that cannot be exercised during plant operation shall be specifically identified by the Owner and shall be full-stroke exercised during cold shutdowns".
Table B-2 identifies these valves.
B.
CORE FLOODING SYSTEM OUESTION:
B.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.
RESPONSE
Relief has previously been granted for this item.
See Item B.2 of Reference 4 which documents acceptability of part stroking CF-V4A/B on a cold shutdown frequency since CF-VSA o_r B is full stroke tested each cold shutdown.
CF-V4A/B and CF-VSA/B see essentially the same service condition and they are the same size, manufacturer and catalog number.
t In addition, CF-V4B was disassembled in November 1983 and was found to be in satisfactory condition.
CF-V4A, or CF-V48, or CF-VSA, or CF-V5B (1 of the four) will be disassembled each 10 years for an inspection.
In accordance with the relief previously granted, if degradation which would make the valve's full stroke capability questionable is found, then the remaining three valves will be disassembled and inspected during that outage.
The partial test of CF-V4A/B each cold shutdown adequately demonstrates the system performance as defined in the bases of THI-1 Tech. Spec. 4.5.2.3.
QUESTION:
B.2 How are valves CF-VSA/B full-stroke exercised during cold shutdowns?
RESPONSE
Normal Decay Heat Removal System Operation during plant cold shutdown with a flow rate of ~3000 gpm demonstrates that CF-V5A or B has opened. Surveillance Procedure (SP) 1303-11.54 which is performed each refueling demonstrates full LPI flow stroke operation of both CF-VSA and B.
In Table B-1 of the IST valve submittal under " Test Frequency Column" for CF-VSA/B add an asterisk to the "C".
"C*" will be used to designate valves where either A or B valve is tested on a cold shutdown frequency by the normal operation of providing Decay Heat Removal flow at ~3000 l
gpm.
In addition, both A and B valves designated "C*" will be tested each refueling Interval. l
Attachment No. 2 C.
CHEMICAL SAMPLING AND OTSG CHEMICAL CLEANING SYSTEM QUESTION:
C.1 What is the purpose of valve CA-V29 located in the lower left hand corner of Drawing FD-020?
RESPONSE
CA-V29 is in the depressurized RC sample return piping to the Makeup Tank upstream of MU-FIA/B. MU-F1A/B is shown on Drawing No. FD-016.
During normal plant operation, the purpose of check valve CA-V29 is to close so that the MU Tank is not depressurized.
CA-V29 has no safety function since loss of MU Tank Pressure is acceptable following an accident.
The BWST will be used for Makeup pump suction.
D.
CHEMICAL ADDITION AND WASTE DISPOSAL SYSTEM OUESTION:
D.1 What is the purpose of the chemical additicn penetration No. 307?
Why is valve CA-V192 identified as a passive valve while valve CA-V189 is not?
RESPONSE
Footnote (1) on Page 3 of Table B-1 in Reference 3 is in error.
This footnote should be deleted.
During normal plant operation, check valve CA-Vl92 is open supplying 100 cc/ min reclaimed water purge to the No. 3 seal of each Reactor Coolant Pump.
This purge supply was provided in the original design to enhance RC Pump seal reliability but is not required to maintain seal integrity and is therefore isolated on Reactor Building containment isolation signals. CA-Vl92 has been and will continue to be leak tested each refueling interval per Surveillance Procedure 1303-11.18 and TMI-I Tech. Spec. 4.4.1.2.1.b.1.
QUESTION:
0.2 Does valve CA-V134 perform any function important to safety?
RESPONSE
CA-V134 supplies Recialmed water to the BWST.
CA-V134 is normally closed during plant operation.
No emergency procedures require re-filling of the BWST and manual valve CA-V134 does not perform a safety function.
E.
CONTROL BUILDING CHILLED WATER SYSTEM QUESTION:
E.1 Do any of the temperature control valves shown on Drawing FD-Oli have a required fall-safe position? -
Attachment No. 2
RESPONSE
ASME Section XI, IWV-1200, 1980 Edition through 1980 Winter Addenda exempts valves used for system control.
If desired, further detail on valve failure modes can be provided at the meeting.
F.
EMERGENCY FEEDWATER AND FEEDWATER SYSTEMS OUESTION:
F.1 Provide a more detailed technical justification for not full-stroke exercising valves C0-V16A and C0-V16B during each cold shutdown.
RESPONSE
Relief has previously been granted in Reference No. 4.
As stated in Relief Request II, TMI-l must limit the exposure of the secondary side of the OTSG to oxygenated water.
Therefore, the appropriate test interval should be refueling or a cold shutdown when cold shutdown exceeds 30 days. Also the bases for TMI-l Tech. Spec. 4.9.1.6 state that these surveillance requirements are adequate "to ensure that the overall EFW System functional capability is maintained".
G.
DECAY HEAT REMOVAL SYSTEM OUESTION:
G.1 Review the safety function of valves DH-VI, DH-V2, and DH-V3 to determine if they should be categorized A.
RESPONSE
DH-VI and DH-V2 are high pressure motor operated valves that are interlocked shut and ca'inot be opened unless the Reactor Coolant System is <400 psig.
DH-V3 is a low pressure valve; therefore, it does not perform a pressure barrier function.
In Addition, these valves do not meet the configuration criteria of WASH 1400 Event V.
These valves are not included in the Event V Order dated April 20, 1981. Attached to and referenced in the Event V Order is the Technical Evaluation Report (TER)
Primary Coolant System Isolation Valves dated October 24, 1980, by the NRC's contractor, Franklin Research Center (FRC).
Page 5 of the TER states that FRC has found no other valve configuration of concern in this plant.
Therefore, we believe that DH-VI, V2, and V3 are not required to i
be tested for the pre 3sure isolation function.
DH-VI and V2 are included l
In the GPUN's Appeal (Reference 5) of the IST SER Open Items which we understand is currently under review by CRGR.
QUESTION:
G.2 Provide a more detailed technical justification for not full-stroke exercising valves DH-VI and DH-V2 quarterly.
Attachment No. 2
RESPONSE
It is allowable per ASME Section XI, IWV-3412 to full stroke valves on a cold shutdown frequency where it is impractical or unsafe to test each quarter.
It is impractical and unsafe to test DH-V1 and V2 each quarter because they are interlocked closed when RCS pressure is above 400 psig.
Such testing would require defeating safety interlocks.
Such testing of DH-VI or V2 would reduce redundancy by providing only one high pressure valve between the Reactor Coolant System and the low pressure Decay Heat Removal System. He believe not testing DH-VI and DH-V2 during normal operation conforms with the NRC staff position that states that unsafe testing is not to be conducted.
See Enclosure 2, Item No. 3 from Reference 1.
QUESTION:
G.3 Review the safety function of valves DH-V4A and DH-V4B to determine if they should be categorized A.
RESPONSE
DH-V4A/B are automatically opened to provide initiation of Low Pressure Injection flow in response to Engineered Safeguards Actuation signals.
They are normally closed during power operation except for testing.
Upstream check valves DH-V22A/B and CF-V5A/B are WASH 1400 Event V valves.
These valves are tested per Technical Specifications to assure reasonable leak tightness.
In addition, neither GPUN, NRC, nor FRC Identify DH-V4A/B as Event V configuration.
Therefore, they are not Category A.
We believe that Category A testing of DH-V22A/B and CF-VSA/B provides two individually tested pressure barriers and more than adequate protection for the Decay Heat Removal System.
QUESTION:
G.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 justification for not full-stroke exercising these two valves during power operation or cold shutdown.
RESPONSE
DH-V6A/B are in a system which is effectively a closed loop outside the Reactor Building.
That piping system is Seismic Category 1/N2 design.
The motor operated valves are remotely opened by the Control Room Operator following an accident and do not receive an automatic post-accident closing (or opening) signal.
-S-
Attachment No. 2 Relief has previously been granted to allow testing DH-V6Ai3 each refueling interval per SER Item 4.3.1.1 of Amendment No. 71 to TMI-l Technical Specifications. DH-V6A/B are tested each refueling for the reason given in the IST Valve Submittal Table B-2, Page 3 of 13 (Reference 3).
He believe it is impractical to test these valves each cold shutdown. A refueling interval stroke time test since 1978 has not shown any problem with these valves.
QUESTION:
G.5 How are valves DH-V14A and DH-V14B partial-stroke exercised quarterly? What alternate methods have been investigated to full-stroke exercise these valves at the Code specified frequency?
RESPONSE
A quarterly part-stroke test of DH-V14A/B is performed by recirculating the BHST with BS-PlA/B or DH-PIA /B.
SP 1303-11.54 demonstrates that DH-V14A/B opens ~731. by pumping from the BHST to the Reactor Vessel each refueling outage.
Relief has previously been granted from full stroking DH-V14A/B each refueling per Reference No. 4.
T.S. 4.5.2.2 specifies that testing "during each refueling period and following maintenance or modification" affecting system flow characteristics is an acceptable frequency for determining continued operability of this system.
Past test results give no basis to warrant an increased test frequency.
He have evaluated the possibility of testing both DH-P1A/B and BS-PIA /B at the same time.
(DH-PlA/B pumping from the BHST to the reactor vessel and BS-PIA /B on recirculation of the BHST.)
This was evaluated as impractical due to potential risk to safety related equipment, potential impact on refueling water clarity, and the limited time allowable to pump to the reactor vessel.
QUESTION:
G.6 Provide a more detailed technical justification for not full-stroke exercising valves DH-V16A and DH-V16B during cold shutdown.
RESPONSE
DH-V16A/B is the discharge check valve on DH-P1A/B and relief has been previously granted for DH-V16A/B to allow testing each refueling interval per Reference No. 4.
T.S. 4.5.2.2 specifies that testing "during each refueling period and following maintenance or modification" affecting system flow characteristics is an acceptable frequency for determining continued operability of this system.
Past test results give no basis to warrant increased test frequency.
( l
~
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Attachment No. 2 In Table B-1 of the IST Valve Submittal (Reference No. 3) under " Test Frequency Column" f'a DH-V16A/B, delete "R" and add "C*".
"C*" will be used to designatc valves where either A or B valve is tested on a cold shutdown frr;uency by the normal operation of providing Decay Heat Removal flow at ~3000gpm.
In addition, both A and B valves designated "C*" 4111 be tested each refueling interval.
QUESTION:
G.7 Review the safety function of valves DH-V22A and DH-V228 to determine if they should be categorized A/Cy
RESPONSE
DH-V22A/B are essentially categorized A/C.
The symbol "a" was used instead of "A".
The "A" is used to differentiate between "A" valves which are leak tested by Appendix J and "a" valves which are leak tested as NASH 1400 valves.
QUESTION:
G.8 Provide a detailed technical justification for not full-stroke exercising valves DH-V22A and DH-V228 quarterly.
How are these valves full-stroke exercised during cold shutdowns while upstream valves DH-V16A and DH-V168 are only partial-stroke exercised?
RESPONSE
Add the following footnote to Reference No. 3, Table B-1, Page 8 of 37 for DH-V22A/B.
"(4) DH-V22A/B are on the discharge side of DH-PIA /B.
DH-PIA /B only produce ~200 psig.
Therefore, it is not possible to overcome nornal RCS pressure with DH-PIA /B.
Thus, it is impractical to test the opening function of DH-V22A/B each quarter.
DH-V22A or B are full stroke tested during cold shutdowns by recirculating the reactor vessel with DH-PIA or B at ~3000 gpm.
Normal Decay Heat Removal System operation at a flow rate of
~3000 gpm demonstrates that DH-V22A or B has opened.
SP 1303-11.54, which is performed each refueling interval, full strokes both DH-V22A and B.
T.S. 4.5.2.2 specifies that testing "during each refueling period and following maintenance or modification" affecting system flow characteristics is an acceptable frequency for determining continued operability of this system.
Past test results give no basis to warrant increased test frequency."
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Attachment No. 2 In Table B-1 of the IST Valve Submittal under " Test Frequency Column" for DH-V22A/B replace "C" with "C*".
"C*" will be used to designate valves where either A or B valve is tested on a cold shutdown frequency by the normal operation of providing Decay Heat Removal flow at ~3000 gpm.
In addition, both A and B valves designated "C*" will be tested each refueling interval.
DH-V16A/B are part stroked each quarter because the piping configuration allows BWST recirculation flow rate through DH-V16A/B.
DH-PIA /B is used to recirculate the BWST.
The recirculation piping is upstream of DH-V22A/B; therefore, recirculation cannot be established through DH-V22A/B.
See Drawing No. FD-005.
QUESTION:
G.9 What is the safety function of valves DH-V38A and DH-V38B?
RESPONSE
Based on the LOCA symptoms, operators will use DH-V38 A/B to balance DH flow (~1000 gpm per loop) per procedure 1210-7.
This will be required particularly when one of the two DH pumps fails to operate.
Such an action will ensure that sufficient LPI is supplied to the RCS in the event of a core flood line break.
QUESTION:
G.10 Review the safety function of valves DH-V59A and DH-V598 to determine if they should be included in the IST program.
RESPONSE
The piping in which these valves are located provides non-safety grade, long term post accident Reactor Building Sump pH control capability as an operator convenience.
Immediate sump pH control is automatically provided by the drawdown of the Sodium Hydroxide tank in the Building Spray System.
Therefore, DH-V59A/B need not be included in the IST program.
H.
RIVER WATER SYSTEM i
OUESTION:
H.1 Review the safety function of valves DR-V6A, DR-V68, DR-V7A, and DR-V7B to determine if they should be included in the IST program.
RESPONSE
4 The internals of DR-V6A and B have been removed.
Therefore, there is no active mechanism to test. A 10 CFR 50.59 safety evaluation was performed which allowed the removal of the internals.
f. _ _ _
Attachment No. 2 DR-V7A/B.
Each river water pump has one vacuum breaker check valve which permits air to enter the pump discharge column when the pump is stopped.
The atmospheric air is used to prevent a build-up of a partial vacuum in the pump discharge column.
A non-functioning vacuum breaker could permit the pump to be started with a partial vacuum in the discharge column potentially resulting in a water hammer (shock loading) of the pump and related piping.
In order to provide additional assurance that the vacuum breaker check valves will open after pump shutdown, GPUN will add these valves to the IST program.
I.
EMERGENCY FEE 0 WATER AND FEEDWATER SYSTEMS QUESTION:
I.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?
RESPONSE
EF-V3 is part stroke tested quarterly using SP 1303-3G by supplying condensate water through EF-V14 then through EF-V3 to EF-V24.
SP 1300-3G has controls to ensure EF piping remains filled and to minimize chemical contamination.
EF-V3 was disassembled in December 1984 for IST purposes and found to be in excellent condition (like new).
Therefore, there is reasonable assurance that EF-V3 would open if required.
Full flow testing of valve EF-V3 would introduce river water, silt and corrosives into the suction piping of the three Emergency Feeddater Pumps and ultimately into the OTSGs.
This is unacceptable from a chemistry L
control standpoint for normal operations.
This valve is downstream of EF-V4 and 5; if EF-V4 and 5 are not stroked, then there is no flow to fully open EF-V3.
The internals for this valve are still in place at this time.
Instructions and a 10 CFR 50.59 safety evaluation for removal of the internals are in progress.
QUESTION:
I.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?
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Attachment No. 2
RESPONSE
Request for relief of this item was previously granted per Reference No. 4.
Our previous response to this item was addressed in Reference No. 3.
EF-V13 is part stroke exercised quarterly by opening a drain valve at EF-V29 when EF-P1 is operating.
QUESTION:
I.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-V178 (Note that EF-Vl9A/B are the EF-V2A EF-V21 correct valves which perform EF-V2B a similar function to EF-V21)
RESPONSE
The motor operated valves EF-VIA/B are located in the suction header of the EFW pumps. These valves are normally open during plant operation and are verified to be in the open position at least once each 31 days in accordance with the Technical Specification requirements of 3
1 Section 4.9.1.3.
These valves are not required to perform an isolation safety function.
They are installed to allow maintenance of the EFW j
pumps.
Therefore, these valves should not be included in the IST program.
Valves EF-V2A/B are normally open during plant operation and are verified to be in the open position at least once per 31 days in accordance with i
Technical Specification No. 4.9.1.3.
These valves are not required to 3'.
perform an isolation safety function since valves EF-V30A or 8 can be
-used for isolation of the affected OTSG if required per plant Abnormal Transient Procedures.
Therefore, valves EF-V2A/B should not be included in the IST program.
Valves EF-Vl9A/B and EF-V21 are check valves for the EFW pump recirculation lines.
Since the EFW pump recirculation control valves are locked open, these check valves will be tested to fully open during surveillance test of the EFW pump under the recirculation mode.
In addition, there are block orifices downstream of these check valves to reduce the pump discharge pressure to the pump suction pressure which is approximately equal to the static head of the CST water.
These valves are to prevent windmilling the EFW pumps and are not required to perform i
an isolation function.
Therefore, the current surveillance test of the EFW pumps in the recirculation mode verifles the opening of these check valves and is an adequate test. Any failure of the check valves to open would be detected by high delta P during the EFW pump test.
1
Attachment No. 2 J.
NUCLEAR SERVICES CLOSED CYCLE COOLING WATER SYSTEM QUESTION:
J.1 Provide a more detailed technical justification for not full-stroke exercising valves EF-V4 and EF-V5 during cold shutdown.
RESPONSE
Relief has previously been granted for EF-V4 and EF-V5 to allow full stroke testing on a refueling interval basis (Reference No. 4, Section 4.4.2.1).
These valves are part of the cross-connect between the Emergency River Water and Emergency Feedwater Systems.
Because of the reasons given in Relief Request I of Table B-2 of the valve testing program (Reference No. 1), the valves should only be full-stroke tested during refueling outages which will provide reasonable assurance of valve operability.
K.
DIESEL GENERATOR JACKET, AIR, AND GEAR BOX LUBE OIL COOLER COOLANT SYSTEM QUESTION:
K.1 How are check valves EG-V32A/A, EG-V32A/B, EG-V328/A, and EG-V328/B individually verified to full-stroke exercise quarterly?
RESPONSE
EG-V32A/A, A/B, B/A, and B/B are located downstream of the Diesel Generator Jacket Coolant Radiator.
These valves must open to allow coolant to be pumped out of the radiator.
Their function is verified open during the monthly performance of SP 1303-4.16.
This procedure verifles that the diesels are capable of performing their design rating of 3 +.1 MW for one hour.
Acceptable jacket water temperature of 120 to 180*F is verified.
If water temperature is found satisfactory EG-V32A/A, A/B, B/A and B/B have functioned open.
System design does not allow individual testing of these valves.
QUESTION:
K.2 Do valves EG-V31A, EG-V318, EG-V47A, and EG-V47B have a required fall-safe position?
RESPONSE
EG-V31A/B, 47A, 47B are temperature control valves.
Therefore, they are exempt per ASME Section XI, INV-1200(a).
If desired, further detail on valve failure modes can be provided at the meeting.
Attachment No. 2 L.
PENETRATION FLUID BLOCK, PENETRATION PRESSURIZATION, AND HYDROGEN RECOMBINER SYSTEMS QUESTION:
L.1 When is the Fluid Block System expected to be disabled and the valves 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.
RESPONSE
Subsequent to our submittal of Reference No. 3, the Fluid Block System has now been disabled and the valves listed in the IST program have now been deleted from all testing requirements.
M.
EMERGENCY FEEDWATER AND FEE 0 HATER SYSTEMS OUESTION:
M.1 Provide the specific technical justification for not verifying i
valves FH-V12A and FH-V128 closed during cold shutdown and refueling outages.
What alternate methods have been considered to verify operability of these valves?
l
RESPONSE
Per Item B.4 of Reference No. 4, GPUN will develop a method to verify the full closure capability of FH-V12A/B before startup from the Cycle 6 refueling outage. Until that time, NRC has agreed that testing of FH-V12A/B will not be required based on disassembly and repair of the valves in 1980. Therefore, this item is resolved for Cycle 5 operation.
N.
HYOR0 GEN PURGE SYSTEM AND MISCELLANEOUS PENETRATIONS OUESTION:
N.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
RESPONSE
l l
HM-VIA/B, 2A/B, 3A/B, and 4A/B are solenoid operated valves which are deenergized to close.
Therefore, they go to their fall safe position 4
when electrical power is removed. Closed indication (from reed switch) t i
is provided in the Control Room
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Attachment No. 2 O.
PENETRATION FLUID BLOCK, PENETRATION PRESSURIZATION, AND HYOR0 GEN i-RECOMBINER SYSTEMS QUESTION:
0.1 How are valves HR-V22A, HR-V228, HR-V23A, and HR-V238 fail-safe i
tested?
RESPONSE
Same as Item N.I.
P.
INTERMEDIATE COOLING SYSTEM OUESTION:
l P.1 What is the safety function of valves IC-VIA, and IC-V1B?
RESPONSE
l IC-VIA/B s'upplies cooling water to the Primary System Letdown Cooler.
Normally one cooler is in service.
These valves do not provide an essential safety function.
They may be used during certain abnormal conditions to place a second Letdown Cooler in service to maximize letdown flow.
QUESTION:
l P.2 How are valves IC-V2, IC-V3, IC-V4, and IC-V6 partial-streke exercised during power operation? What are the consequences of valve failure while full-stroke exercising these valves during-power operation?
RESPONSE
IC-V2 has a test switch logic that allows it to only close 107..
For IC-V3, V4, and V6, valve stem mechanical blocks are used to allow partial stroking of the valves.
IC-V2, V3, V4, and V6 are in the supply or-return lines to the Primary Letdown Coolers, Control Rod Drive Cooling Coils, Reactor Coolant Pump Exchangers, and/or R.C. Drain Tank Heat Exchanger.
IC-V2, V3, V4, and V6 fall under the NRC Staff Position which states that "all valves whose failure in a non-conservative position during the cycling test would cause a loss of system function should not be exercised".
If these valves were not reopened promptly, loss of the above coolers could result in component overheating (especially CRDM stators) and reactor shutdown.
Attachment No. 2
-Q.
MAIN STEAM SYSTEM AND DRAINAGE QUESTION:
Q.1 Provide a detailed technical justification for not full-stroke exercising valves MS-VIA, MS-VIB, MS-VIC, and MS-VID during power operation.
RESPONSE
Full-stroke testing during power operation is not practical because of the potential for possible turbine pressure instabilities downstream of the valves and possible unnecessary challenges to safety valves upstream of MS-V1. Also, Abnormal Procedure 1203-42 requires the reactor to be tripped if MS-VIA/B/C or D completely close during power operation in order to prevent damage to the OTSG that was not isolated.
QUESTION:
Q.2 What are the consequences of valve failure in the open position l
while full-stroke exercising valves MS-V4A and MS-V4B during power operation?
RESPONSE
l Prior to stroke timing MS-V4A/B each quarter, its block valve MS-VISA /B is closed.
There are no consequences since no steam flow results if MS-V4A/B remains open with MS-VISA /B closed.
QUESTION:
Q.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?
RESPONSE
This item was addressed in Reference No. 5 as follows:
"These valves supply steam from the OTSGs to the steam driven Emergency Feedwater Pump (EF-P1).
During a cold shutdown, it is impractical to stroke test these valves (full stroke or partial stroke) since the steam which would be needed to operate these valves is not available during cold shutdown conditions.
Full stroke testing of MS-V9A/B is also impractical due to other limitations during plant conditions when steam is available.
EF-P1 must be tested using the recirculation line to the Condensate Storage Tank bypassing the OTSG.
This is to prevent degradation of the OTSGs by excessive thermal stress cycling of the emergency feedwater nozzles.
The number of thermal cycles on the emergency L
Attachment No. 2 feedwater nozzles is limited to (40) cycles over the life of the plant. Due to the small size of the recirculation line, EF-P1 cannot be tested at full capacity; and MS-V9A/B will not open fully. Under these restrictions it is only possible to obtain approximately 48% flow which corresponds to about 80% opening of MS-V9A/B.
Plant modifications which would be required to perform full stroke tests of MS-V9A/B either by piping in auxiliary steam or by replacing the recirculation piping with larger piping capable of recirculating the full EFW pump capacity would introduce exorbitant cost. GPUN has not fully examined the cost and safety impact of modifications which would be required to test MS-V9A/8, however, we do not feel that such modifications would be beneficial.
MS-V98 was disassembled for IST examination purposes in late 1984 and found to be in excellent condition.
Since no indication of potential degradation was found, this provides additional assurance of the continued capability of MS-V9A/B to open fully when needed.
It is impractical to test MS-V9A/B when steam is not available and it is also impractical to perform a full stroke test on MS-V9A/B.
GPUN concludes that quarterly testing of MS-V9 at 48% flow (80% open) when steam is available meets the intent of the ASME Code Section XI and the relief which is being requested is therefore justified."
MS-V9A/B are exercised individually per GPUN surveillance test procedure No. 1300-3G A/B.
MS-V9A/B are not required to perform a safety function in the closed position since the normally closed valves MS-V13A/B and MS-V10A/B perform this function.
QUESTION:
Q.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
RESPONSE
AS-V4 is a normally closed valve, does not perform any safety function and is not required to change position during any transients.
It is an l
1 solation valve between main steam and auxiliary steam and is only opened to use auxiliary steam to test the turbine driven emergency feedwater l
pump when MS is not available. i.
r 1
Attachment No. 2 MS-V8A/B are normally open valves and are not required to bring the plant to hot shutdown after a transient and do not have to change position during a transient.
Therefore, MS-V8A/B are not included in the IST Program.
MS-V6 is a normally open, control valve which falls open to supply steam to the turbine driven emergency feedwater pump.
MS-V6 is a pressure regulating valve and is exempt from testing per IHV-1200.
MS-V22A/B prevent overpressurization of the piping.
Since the upstream pressure regulation valve MS-V6 will self-regulate the downstream pressure to less than 175 psig, MS-V6 is adequate to protect down stream piping.
These two safety valves are not required to perform a safety function.
Therefore, MS-V22A/B should not be included in the IST program.
R.
MAKE-UP AND PURIFICATION SYSTEM - LETDOHN PORTION QUESTION:
R.1 What is the safety function of valves MU-VIA and MU-VlB?
RESPONSE
MU-VIA/B are in the Primary Letdown piping to the Letdown Coolers.
Normally one cooler is inservice.
These valves do not provide an essential safety function.
These valves may be used during certain abnormal conditions to place a second Letdown Cooler in service to maximize letdown flow.
QUESTION:
R.2 Provide a detailed technicGl justification for not full-stroke exercising valves MU-V?A, MU-V28, and MU-V3 quarterly during power operation.
RESPONSE
MU-V2A/B and MU-V3 are part stroked each quarter.
This is per ASME Section XI, IHV-3412(a) requirements. A full stroke test is not required because it is impractical.
It is impractical to isolate Letdown during power operation because this may preclude timely restoration of letdown flow.
If letdown flow is totally isolated, the reactor coolant system loses its normal means of purification and compensation for volume addition due to design RC Pump Seal Injection in-leakage and may lead to reactor shutdown. Also thermal cycle considerations on the Letdown Coolers do not allow full closures of MU-V2A/B or MU-V3 during normal plant operation.
QUESTION:
R.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?
i Attachment No. 2
RESPONSE
See Item R.2.
MU-V3 is part-stroke exercised by installing a mechanical clevis assembly to physically limit valve travel to prevent significant i
letdown flow reduction.
QUESTION:
i R.4 Provide a detailed technical justification for not full-stroke exercising valves MU-V25 and MU-V26 quarterly during power operation.
RESPONSE
HU-V25 and MU-V26 are in the RC Pump Seal Return line and are part stroked each quarter.
Isolation of the RC Pump Seal Return Line at power risks permanent damage to the RC Pump Seals and Reactor Coolant System leakage, and may result in reactor shutdown.
QUESTION:
R.5 What is the safety function of valve MU-V51?
l
RESPONSE
The safety function of MU-V51 is to open by Control Room Operator action during some emergency procedures to supply concentrated boric acid from the Boric Acid Mix Tank to the Makeup and Reactor Coolant Systems to maintain a 1% reactor Shutdown Margin by soluble poison reactivity control.
QUESTION:
R.6 Review the safety function of the following valves to determine if they should be included in the IST program.
Category B Category C HU-VilA MU-V47 MU-VilB
RESPONSE
MU-VilA and MU-VilB provide isolation capability for maintenance on makeup filters MU-FIA/B. Since there is no safety function associated with these valves, they should not be included in the IST program.
MU-V47 prevents loss of makeup tank pressure when the letdown is isolated or in a bleed mode of operation.
The loss of makeup tank pressure is acceptable following an accident when the BHST will be used for makeup pump suction.
Therefore, this valve should not be included in the IST program. _ ______
Attachment No. 2 S.
MAKE-UP AND PURIFICATION SYSTEM - MAKE-UP PORTION QUESTION:
S.1 Provide a more detailed technical justification for not full-stroke exercising valves MU-V14A and MU-V14B open quarterly and during cold shutdowns.
RESPONSE
This relief has previously been granted in Reference No. 4.
MU-V14A/B are stop check valves.
The motor operated function (Category B) is stroke timed each quarter. Category C testing verifles full stroke open function each refueling.
The frequency of testing required by T.S. 4.5.2.1 which states that "during each refueling interval and following maintenance or modification" affecting system flow characteristics is sufficient to demonstrate HPI system operability.
In addition, past test results provide no basis to warrant increasing the test frequency.
QUESTION S.2 Is thermal shock to the injection nozzles a consideration when full-stroke exercising valves MU-V16A, MU-V16B, MU-V16C, and MU-V16D during power operation? Are these valves presently being leak-rate tested as containment isolation valves?
RESPONSE
Thermal shock to the injection nozzles is not a consideration when stroke timing MU-V16A/B/C/D each quarter because thermal shock is avoided by coordinating pump lineup switching when stroke timing MU-V16A-D.
MU-V16A/B/C/D are not Appendix J valves since they automatically open in response to accident conditions.
QUESTION S.3 Provide a more detailed technical justification for not full-stroke exercising valves MU-V73A, MU-V73B, and MU-V73C quarterly during power operation and cold shutdown.
RESPONSE
Relief has previously been granted in Reference No. 4.
MU-V73A/B/C are the discharge check valves on MU-PIA /B/C. During normal operations, MU-PIA or B or C supplies normal makeup to the RCS, RC Pump seal injection, and recirculation flow.
The total of these flow rates is much less than accident design flow rate and this is considered a partial stroke test of MU-V73A/B/C.
No other testing method is practical during normal plant operation.
I l
l Attachment No. 2 T.S. 4.5.2.1 requires a test of the High Pressure Injection (HPI) System to be conducted on a refueling interval.
This test demonstrates the continued operability of the system, and therefore, is adequate to assure the operability of these valves.
In addition, past test results give no basis to warrant increased test frequency.
QUESTION S.4 Provide a more detailed technical justification for not full-stroke exercising the following valves quarterly during power operation and cold shutdown.
Do any of these valves perform a containment isolation or pressure boundary isolation function?
MU-V86A MU-V107A MU-V868 MU-V1078 MU-V94 MU-V107C MU-V95 MU-V1070 MU-V220
RESPONSE
Relief has previously been granted to allow full stroke tests to be conducted each refueling interval in Reference No. 4 These valves are in the four HPI legs to the RCS.
Thermal shock to the injection nozzle considerations do not allow testing these valves each quarter.
T.S. 4.5.2.1 requires a test of the High Pressure Injection (HPI) System to be conducted on a refueling interval.
This test demonstrates the continued operability of the system, and therefore, is adequate to assure the operability of these valves.
Past test results give no basis to warrant an increased test frequency.
These valves are not Appendix J valves because they open in response to accident conditions.
In addition, these HPI check valves do not meet the configuration criteria of WASH 1400 Event V and are not included in the Event V Order dated April 20, 1981. Attached to and referenced in the Event V Order is the Technical Evaluation Report (TER) Primary Coolant System Isolation Valves dated October 24, 1980, by the NRC's contractor, Franklin Research Center (FRC).
Page 5 of the TER states that FRC has found no other valve configuration of concern in this plant.
Therefore, we believe that these HPI check valves are not required to be tested for pressure isolation function.
These valves are included in the GPUN Appeal (Reference No. 5) of the IST SER Open Items which we understand is currently under review by CRGR.
QUESTION S.5 What is the safety function of valves MU-V116 and MU-V219? Does valve MU-V219 perform a containment isolation function?
Attachment No. 2
RESPONSE
The safety function of both MU-Vil6 and MU-V219 is to perform containment isolation.
MU-V219 does not receive a containment isolation signal and is exempted from Appendix J testing requirements.
QUESTION S.6 What is the safety function of valve MU-V217?
RESPONSE
This valve has no essential safety function.
It provides high makeup flow by manual actuation from the Control Room in case of a reactor trip or other abnormal transients, avoiding any unnecessary challenges to the HPI system.
QUESTION S.7 Review the safety function of valve MU-Vil2 to determine if it should be included in the IST program.
RESPONSE
MU-Vil2 prevents backflow of BHST water to the makeup tank during High Pressure Injection after an accident.
This function of the valve does not affect operation of the HPI. As the water drains down from the BHST, there will be a r:eferential drawdown from the BHST.
Thus, even if back flow occurred as a result of MU-V112 failure, the water inventory will be still available for HPI.
Therefore, MU-Vil2 is not required to be included in the IST program.
T.
NITROGEN SUPPLY SYSTEM QUESTION T.1 Is there another containment isolation valve associated with NI-V27 on the nitrogen line at penetration 307?
RESPONSE
Yes.
NI-V26 and NI-V27 are both manual locked closed isolation valves located outside of the reactor building.
i U.
RIVER HATER SYSTEM QUESTION i
U.1 What is the safety function of valves NR-V4A and NR-V4B?.
Attachment No. 2
RESPONSE
During a 1600 psig ESAS actuation NR-V4A and B automatically close to prevent cooling water from being diverted from the NR Coolers.
QUESTION U.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-V22B NR-V19 NR-V22C NR-V18 NR-V29
RESPONSE
NR-V2 and 6 are cross-connect valves between the secondary river and nuclear river water systems.
In accordance with Abnormal Procedure No. 1203-19, Nuclear River Water would not be cross connected to supply Secondary River Water unless the reactor were subtritical.
These valves are normally closed, remain closed during an accident, and receive no automatic signal; therefore, they have no safety function.
NR-V18 and NR-V19 are not required to be repositioned during transient conditions or to mitigate any accident.
NR-Vl9 is normally maintained closed unless additional de-icing water is required at the screenhouse intake.
NR-V18 is normally full open or throttled to maintain the proper nuclear river water system pressure.
NR-V18 and NR-Vl9 do not provide an essential safety function.
NR-V22A/B/C - These vacuum breakers are similar to those addressed in the response to question H.l.
Therefore these valves will also be added to the IST Program.
NR-V29 is the siphon breaker in the Heat Exchanger Vault. During normal plant operation, the NR piping is filled and vented with two NR pumps in operation. Siphon flow from the Heat Exchanger Vault is prevented by the vent (candy cane) downstream of NR-V18.
Therefore, NR-V29 has no safety function.
V.
NUCLEAR SERVICE CLOSED CYCLE COOLING HATER SYSTEM QUESTION V.1 Provide the specific technical justification for not full-stroke exercising valves NS-V4, NS-V15, and NS-V35 during power operation.
l l !
Attachment No. 2
RESPONSE
NS-V4, V15, and V35 supply or return cooling water for the RC Pump Motor Coolers.
If, for testing purposes, these valves were closed and they were not able to be reopened, this would shortly require deenergizing all four Reactor Coolant Pump Motors.
Therefore, in accordance with ASME Section XI, IWV-3412 and NRC letter to Met-Ed dated November 17, 1976,, Paragraph 1, these valves will be full stroke tested on a cold shutdown frequency and part stroked each quarter.
QUESTION V.2 How is valve NS-Vil full-stroke exercised closed (its safety i
position) quarterly during power operation?
RESPONSE
NS-V11 is a Containment Isolation Valve which supplies cooling water to l
the RC Pump motor coolers and as in Item V.1 cannot be closed during normal plant operation. NS-V11's close function is verified each refueling when it is leak rate tested per SP 1303-11.18.
NS-Vil is also confirmed for open function on a quarterly basis.
l l
QUESTION V.3 Are valves NS-V52A/B/C and NS-V53A/B/C leak tested to Appendix J l
requirements to demonstrate their containment isolation function?
RESPONSE
No. Valves NS-V52A/B/C and NS-V53A/B/C are cooling water isolation to the motors on the Reactor Building Emergency Cooling fans and they remain open post-accident.
In addition this Seismic Category 1 piping system is a closed loop within the reactor building and it remains pressurized greater than the peak Reactor Building pressure following an accident.
QUESTION V.4 Do any of the following valves have a required fail-safe position?
NS-V55A cooling water to control building
- (Note:
We believe l
NS-V55B coolers the correct numbers for valves referred NS-V48A* cooling water to control building to in this question NS-V488* air conditioning are NS-V108A/B)
RESPONSE
V.4 NS-V55A/B and NS-V108A/B are control valves and are exempt from IST l
by ASME Section XI, IWV-1200, 1980 Edition through Winter 1980 Addenda.
l l
l 1 i
Attachment No. 2 H.
RIVER HATER SYSTEM QUESTION f
H.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.
RESPONSE
RR-V10A/B are the minimum recirculation valves for RR-PlA/B.
Their safety function is to automatically open when RR-PIA /B starts and then to close when a signal is received from the Engineered Safeguards System.
RR-V10A/B are included in the IST program and have been and will continue to be tested each quarter but they were inadvertently omitted from the IST Submittal (Reference 3).
Therefore, please add a line entry to the IST Submittal, Table B-1, Page 29 of 37 as follows:
RR-V10A/B, cage l
guided plug, 2", Diaphragm, 3, B, T/FS, Q/Q.
l l
RR-V12A/B - These vacuum breakers are similar to those addressed in the i
i response to question H.l.
Therefore, these valves will also be added to l
l the IST Program.
t 1
X.
NUCLEAR SERVICES CLOSED CYCLE COOLING WATER SYSTEM QUESTION X.1 Review the safety function of the following valves to determine if they should be categorized A.
I RR-V3A RR-V4B l
RR-V3B RR-V4C i
RR-V3C RR-V40
{
RR-V4A i
RESPONSE
i RR-V3A/B/C and RR-V4A/B/C/0 are isolation valves for the Reactor Building i
emergency cooling coils and they open automatically post-accident.
In addition these valves are in a Seismic Category I piping system which is a closed loop within the reactor building; therefore, they are not l
Category A valves.
QUESTION f
i X.2 Provide a more detailed technical justification for not full-stroke
[
exercising the following valves quarterly during power operation l
and cold shutdowns.
l i
l l
RR-V8A l
RR-V8B j
RR-V9A l
RR-V9B f
i RR-V9C l
! l a
Attachment No. 2
RESPONSE
Relief has previously been granted per Item 4.7.1.1 of SER (Reference No. 2).
RR-V8A/B, RR-V9A/B/C supply / return water to/from the Reactor Building Emergency Cooling Colls.
Table B-2 page 6 of the IST Submittal (Reference No. 3) provides adequate technical justification for a refueling interval test. A quarterly or cold shutdown test is not practical because the drainage and flush water from the cooling coils must be considered radioactive waste.
To process this drainage and flush water on any other Interval except refuelings generates unnecessary radioactive waste.
QUESTION X.3 Provide the P&ID that shows valve RR-V9D.
RESPONSE
Please delete "RR-V90" from the submittal.
This valve does not exist.
This was a typographical error.
QUESTION X.4 Review the safety function of valves NS-V12 and RR-V6 to determine if they should be included in the IST program.
RESPONSE
NS-V12 performs no direct function in shuttir.g down the reactor or mitigating the consequences of an accident.
The valve is normally closed.
Its function during plant operation is to keep the Reactor Building Emergency Cooling Colls pressurized when the coils are in standby.
The valve should not be included in the IST program.
RR-V6 is a backpressure regulating control valve and is exempt from the IST program by ASME Section XI, IHV-1200, 1980 Edition through Winter 1980 Addenda.
Y.
REACTOR BUILDING NORMAL COOLING SYSTEM QUESTION Y.I What is the purpose of this system?
RESPONSE
The purpose of the Reactor Building Normal Cooling System is to provide non-safety grade cooling to the Reactor Building during normal plant l
operation.
This system automatically isolates upon receipt of a containment isolation signal.
In Reference No. 1, Table B-1, Page 30, please reverse entry "R/Q/C" under " System /ISI Drawing No." Column with entry " Normal Cooling Water" under " Test frequency" Column.
l l
Attachment No. 2 QUESTION Y.2 Is valve RB-V7 motor operated as indicated in the IST program or pneumatic as indicated on the :SI Boundary sketch.
RESPONSE
RB-V7 is motor operated.
The ISI Boundary Drawing will be revised to show this modification.
QUESTION Y.3 Provide the specific technical justification for not full-stroke exercising valves RB-V7 and RB-V2A quarterly during power operation.
RESPONSE
RB-V7 and 2A are part stroked each quarter.
They are not full stroke tested because this would isolate normal cooling water to the Readtor Building atmospheric cooling coils.
If, in the unlikely event, RB-V7 or 2A are not reopened, this could quickly lead to violation of Reactor Building air temperature Limiting Condition for Operation (Tech.
Spec. 3.17) requiring plant shutdown.
This agrees with the NRC's staff position (Reference No. 1) which states " valves whose failure in a non-conservative position during the cycling test would cause a loss of system function should not be exercised."
QUESTION Y.4 Review the safety function of valve RB-V2 to determine if it should be included in the IST program.
RESPONSE
Check valve RB-V2 was initially a CIV, but TMI-l added RB-V2A because of Appendix J testability concerns.
RB-V2A is the Technical Specification designated CIV; therefore, RB-V2 has no safety function.
Z.
REACTOR BUILDING SPRAY SYSTEM QUESTION Z.1 Review the safety function of the following valves to determine if they should be categorized as indicated.
Catetory A Category A/C BS-VIA BS-V30A BS-VlB BS-V308 l !
Attachment No. 2
RESPONSE
These valves are isolations for the Reactor Building Spray System.
They open post-accident and receive no automatic closing signal.
In addition this Seismic Category 1 piping system is essentially a closed loop outside the Reactor Building; therefore, BS-VIA/B, 30A/B are not Category A valves.
QUESTION Z.2 How are valves BS-V30A and BS-V30B 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.
RESPONSE
Relief has been previously granted for the full stroke test of BS-V30A/B in Reference No. 4.
BS-V30A/B are part stroked by attaching a nitrogen bottle (~200 psig) to BS-V47A/B and then forcing nitrogen through BS-V30A/B.
For IST purposes, BS-V30A was disassembled in June 1984 and was found to be in good condition (no unusual degradation and free to open).
If disassembly / inspection reveals that the full stroke capability of the i
l disassembled valve may be in question, the other valve will be disassembled and inspected at the same outage.
QUESTION Z.3 How are valves BS-V23A and BS-V238 full-stroke exercised quarterly?
RESPONSE
1 l
BS-V23A/B are full stroked each quarter per SP 1300-3A by placing BS-PIA /B on recirculation of the BHST.
[
QUESTION l
Z.4 In reference to valves BS-V52A and BS-V528, the NRC position is i
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.
RESPONSE
Relief has been previously granted by Reference No. 4 allowing disassembled inspection of BS-V52A/B on a 10 year interval.
Both valves were disassembled and inspected in January 1984 and found to be in "Ilke i
new" condition. Additionally, these valves are of corrosion-resistant stainless steel and are in a system which is static (i.e., there is no flow in this system except under accident conditions).
=
Attachment No. 2 QUESTION Z.5 Are there any vacuum breakers that perform a safety function installed on the sodium hydroxide tank?
RESPONSE
A common relief valve / vacuum breaker (BS-V38) connects to the vapor space at the top of the Sodium Hydroxide Storage Tank.
The tank is also vented to the atmosphere via valve BS-V128 which is administratively kept locked open.
The venting capacity of the 3" BS-V12 valve is more than adequate to assure the tank is maintained at an atmospheric pressure during design drawdown.
The vacuum breaker is therefore redundant to the vent line and does not perform any safety function.
AA.
REACTOR COOLANT SYSTEM 00ESTION AA.1 What is the safety function of valves RC-VI and RC-V3?
RESPONSE
RC-VI's function is control of RCS pressure.
During a transient which increases RCS pressure, RC-VI opens to allow for cooler water to spray into the pressurizer, thus condensing steam and reducing RCS pressure.
Should the RC-VI valve fail open, cooler water would continue to flow into the pressurizer, reducing pressure to below the normal operating l
point.
For this reason the line also contains RC-V3, which can be used j
to control flow of cooler water to the pressurizer should the RC-VI valve fall open.
These valves have no essential safety function but are l
Important to plant operation.
l OUESTION AA.2 Review the safety functions of valves RC-V4 and RC-V23 to determine if they should be categorized A and A/C respectively.
RESPONSE
RC-V4 and RC-V23 are only used to spray the pressurizer when RCS pressure is less than 400 psig. During normal plant operation these valves are shut and do not automatically open; therefore, they are entirely passive (RC-V4 is procedurally required to be shut when the RCS is greater than 400 psig).
Their leak tightness will be verifled by current RCS leakage calculations.
RC-V4 and RC-V23 are included in the GPUN Appeal (Reference No. 5) of certain Amendment No. 71 SER IST Open Items which we understand is currently under review by CRGR..
Attachment No. 2 DH-V64 and DH-V69 are the containment isolation valves in the RC-V4/23 related line.
The DH valves are leak tested per Appendix J requirements and are categorized as Category A and A/C, respectively.
QUESTION AA.3 Is RC-RV2 utilized for low-temperature overpressurization protection of the RCS at TMI-1?
RESPONSE
Per T.S. 3.1.12.1, RC-RV-2 is utilized for low temperature overpressurization protection of the RCS.
BB.
SPENT FUEL COOLANT SYSTEM QUESTION BB.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-V1/2/3/4/5/6 SF-47 SF-48 SF-VII/12/13/14/15/16 SF-V50 SF-V51
RESPONSE
l SF-Vl/2/3/4/5/6 and SF-Vil/12/13/14/15/16 do not provide a safety function.
These valves are used for maintenance and for system alignment.
The positions of these valves may be changed to accomplish various system alignments.
The failure of any valve in any position (close/open) cannot affect the safety function of the system because of the following:
i l
a)
These are redundant flow paths to provide cooling water to the spent fuel pool.
l b)
Even if valve failures occurred, the time to reach pool bolling will allow enough time to fix the problem and return the spent fuel pool cooling system to service.
Therefore, addition of these l
valves to the IST program is not required.
SF-V47 does not provide a safety function.
This is a manually operated valve used for maintenance and for system alignment. Valve SF-V47 should be open when the purification of the pool B is scheduled.
Failure of this valve cannot affect the safety of the plant because of the following:
ai There are alternate flow paths to provide pool and water purification.
! l
Attachment No. 2 b)
Interruption of pool water purification does not violate the Tech.
Spec. requirements.
Therefore, addition of this valve to the IST program is not required.
SF-V50 and SF-V51 do not provide a safety function.
These valves prevent the backflow from the spent fuel pool if a drain valve in the system is opened.
The physical piping configuration does not allow pool level to be siphoned below a safe level.
Therefore, the inclusion of the valves in the IST program is not required.
SF-V48 is open at all times except when no fuel is present in the pool and draining is desired.
Therefore, no safety function is performed by the valve during normal system operation.
CC.
RIVER WATER SYSTEM QUESTION CC.1 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 SW-V24A SW-V6A SW-V24B SW-V6B SW-V23A SH-V8A SW-V23B SW-V8B
RESPONSE
SW-V24A/B are temperature control valves, and therefore, excluded from the IST Program by ASME Section XI, IWV-1200(a).
SW-V23A/B are the strainer blowdown valves for SW-PlA/B.
Strainer differential pressure is alarmed in the control room.
SW-V23A/B usually operate on a timed mode.
They have no safety function and are installed for operator convenience.
SW-V6A/B is the vacuum breaker on the discharge of SW-P2A/B.
These vacuum breakers are similar to those addressed in the response to question H.l.
Therefore, these valves will also be added to the IST program.
SW-V8A/B - These vacuum breakers are similar to those addressed in the response to question H.1.
Therefore, these valves will also be added to the IST program.
i Attachment No. 2 DD. MISCELLANE0US QUESTIONS AND COMMENTS QUESTION 00.1 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 shutdown.
RESPONSE
i CA-PIA /B; HDL-P13A/B and associated valves ar. Included in the GPUN Appeal (Reference No. 5) of certain Amendment No. 71 SER IST Open Items which we understand is currently under review by CRGR.
Testing at cold shutdown generates additional radioactive waste that must be processed. A refueling test is adequate to demonstrate the operability of these components.
In addition, quarterly testing of some of the associated valves without testing the pumps provides little or no i
additional increase in operational readiness.
j OUESTION DD.2 Provide an explanation of the alternate test methods that have been investigated to verify operability of main feedwater check valves FH-V12A and FH-V128.
(Reference Relief Request X).
RESPONSE
See Question M.1 Response.
]
OUESTION 00.3 Since Technical 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.
RESPONSE
4 The Technical Specifications as indicated provide for system operability testing, whereas the testing performed under ASME Section XI verifles individual component operation.
In certain instances, however, the technical specifications testing can accomplish both system and component operability, since a component malfunction or component degraded condition will lead to both decreased overall system and component performance.
1
Attachment No. 2 For example, using the relief request III of Table B-2 (Reference No. 3) for HPI check valves, the testing of these valves during power operation would lead to an undesirable transient to the HPI nozzles by injecting cold 8HST water into a hot RCS.
By design, the number of allowable thermal cycles is limited.
The system is tested on a refueling interval basis to verify adequacy for accident mitigation.
By measuring flows through each HPI injection line, system adequacy is shown and at the same time it is also shown that the respective valves have opened sufficiently to pass the required flow, likewise demonstrating valve operability.
QUESTION 0D.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?
RESPONSE
CA-PIA or 8, or HDL-P13A or B (one or perhaps more, dependent on which tanks contain boric acid of the proper concentration) are used to establish boron concentration in the RCS when approaching cold shutdown.
During plant operation, boron may be reclaimed and stored in the RBAT (or the RBAT may be empty).
Then, when the plant is shutdown, the reclaimed boric acid inay be used to increase the RCS boron concentration prior to a normal plant cooldown. During emergency conditions, the BHST is the primary source to borate the plant.
QUESTION 0D.5 Provide a detailed technical justification for not full-stroke exercising and stroke timing the following valves quarterly in accordance with Section XI.
HDL-V49 HDL-V89 I
HDL-V50 HDL-V90 HDL-V61 HDL-V91 HDL-V62 HDL-V92
RESPONSE
See DD.1 response.
II. PUMP TESTING PROGRAM A.
Et.iERGENCY FEEDWATER SYSTEM QUESTION A.1 Is instrumentation available to allow measurement of flow (0) while testing the EFH pumps?
(Note 9 does not agree with Section XI, 1980 Edition). -
. _ _ =
- - = - - -
Attachment No. 2
RESPONSE
Flow rate instrumentation is available.
However, ASME Section XI, INP-4120 scale range criteria cannot be achieved.
EF-PI, and EF-P2A/B testing is conducted on recirculation to the Condensate Storage Tanks.
Installed orifices limit flow rate to a fixed value.
Flow rate is the independent variable and AP is the dependent variable.
This testing method agrees with ASME Section XI, IWP-3100 requirements.
Third line of Table A-2 of the Pump Submittal, add a prior to P.
B.
NUCLEAR SERVICE RIVER WATER SYSTEM 00ESTION B.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?
RESPONSE
For cold shutdowns of short duration, heat loads (i.e., Radwaste Evaporator) do not allow operation of only one pump.
C.
NUCLEAR SERVICE CLOSED COOLING WATER SYSTEM QUESTION C.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?
RESPONSE
Same as B.1 response D.
REACTOR BUILDING EMERGENCY COOLING SYSTEM QUESTION D.1
-Provide the P&ID that shows the flow path utilized during reactor building emergency cooling pump quarterly testing.
RESPONSE
F0-002 shows the flow path for RR-PlA/B quarterly testing. Quarterly testing is conducted with RR-V10A/B fully open and pump discharge valve RR-VIA/B closed.
This produces a fixed flow rate through RR-V10A/B.
j QUESTION D.2 Provide the specific technical justification for not performing the reactor building emergency cooling pump complete Section XI testing i-during cold shutdowns instead of refueling outages.
l l
Attachment No. 2
RESPONSE
This item has the same justification as Question X.2 response.
E.
SCREEN WASH SYSTEM QUESTION E.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.
RESPONSE
Relief has been previously granted for measuring flow rate as described I
in Item 3.4(a) of SER for Amendment No. 71 to THI-l's Technical Specifications.
SH-PIA /B supply spray water to the River Water Traveling Screens and Sluice Canal. Adequate flow rate is visually verified.
This is adequate for this type of pump application because the pump's design function is more concerned with providing adequate flow velocity (to wash screen debris down an open sluiceway to an open trash pit) than it is with flow rate for heat removal as it is with most other IST pumps.
1 APPENDIX A Page 1 of 5 Limiting Value of Stroke Time for IST Motor Operated Valves VALVE iLIMITING STROKE TU G (Sec.)
OPEN or CLOSE 1.
AH-VIA
< 1.0 CLOSE 2.
AH-VID
< 1.0 CLOSE 3.
AH-V1B
< 2.0 CLOSE 4.
AH-VIC
< 2.0 CLOSE 5.
BS-VIA 20 OPEN 6.
BS-V1B 20 OPEN 7.
BS-V2A 27 OPEN 8.
BS-V2B 25 OPEN 9.
BS-V3A 65 OPEN j
- 10. BS-V3B 60 OPEN I
- 11. CA-V1 27.8 CLOSE
- 12. CA-V2 2
CLOSE
- 13. CA-V3 20.5 CLOSE
- 14. CA-V4A 25.5 CLOSE
- 15. CA-V4B 22.8 CLOSE
- 16. CA-V5A 2
CLOSE
- 17. CA-V5B 2
CIDSE
- 18. CA-V13 8.6 CLOSE
- 19. CA-V189 5.9 CLOSE
- 20. CF-V2A 23.3 CLOSE
- 21. CF-V2B 18.3 CLOSE
- 22. CF-V19A 3.0 CLOSE
- 23. CF-V19B 3.0 CLOSE
- 24. CF-V20A 3.0 CLOSE
- 25. CF-V208 3.0 CLOSE
- 26. CH-V1 2
CLOSE
- 27. CM-V2 2
CLOSE
- 28. CM-V3 2
CLOSE
- 29. CM-V4 2
CLOSE
- 30. DE-V1 144 OPEN
- 31. DE-V2 144 OPEN
- 32. DE-V3 120 OPEN
- 33. DE-V4A 12 OPEN
- 34. DE-V4B 12 OPEN
- 35. DE-V5A 13 OPEN
i APPENDIX A (CONTINUED)
Page 2 of 5 VALVE LIMITING STROKE TIME (Sec.)
OP_EN pr CLOSE
- 36. N V5B 13 OPEN
- 37. DM-V6A G6.25 OPEN
- 38. DM-V6B 83.75 OPEN
- 39. DM-V7A 25.4 OPEN
- 40. DM-V75 26.3 OPEN
- 41. DR-VIA 188 OPEN
- 42. DR-V1B 183 OPEN
- 43. EP-V4 39 OPEN
- 44. IP-V5 41 OPEN
- 45. EP-V30A 7.5 OPEN
- 46. IP-V308 7.5 OPEN
- 47. h VIA 2
OPEN
- 48. E V1B 2
OPEN
- 49. hV2A 2
OPEN
- 50. E V2B 2
OPEN
- 51. E V3A 2
OPEN
-52. h V3B 2
OPEN
- 53. EV4A 2
OPEN
- 54. h V4B 2
OPEN
- 55. HR-V22A
'2 OPEN g
1
- 56. HR-V225 2
OPEN
- 57. HR-V23A 2
OPEN
- 58. HR-V238 2
OPEN
- 59. IC-VIA 31 OPEN i
- 60. IC-V1B 28 OPEN
- 61. IC-V2 38.0 CLOSED
- 62. IC-V3 18.0 CLOSED
- 63. IC-V4 15.0 CLOSED
- 64. IC-V6 3.0 CLOSED
- 65. MS-VIA
<120 CLOSED
- 66. MS-ViB
<120 CLOSE
- 67. MS-VIC
<120 CLOSED
- 68. MS-VID
<120 CLOSE
- 69. MS-V2A 74 CLOSED
- 70. MS-V2B 74 CLOSE
APPENDIX A (CONTINUED)
Page 3 of 5 VALVE LIMITING STOKE TIME (Sec.)
OPEN or CLOSE
- 71. MS-V4A 5
OPEN
- 72. MS-V4B 5
OPEN
- 73. MS-V10A 33 OPEN
- 74. MS-V108 33 OPSI i
- 75. MS-V13A 23 OPEN
- 76. )S-V135 23 OPEN
- 77. W -VIA 36 OPEN
- 78. W -V1B 37 OPEN
- 79. W-V2A 31.3 CLOSE
- 80. W -V25 31.7 CLOSE
- 81. W -V3 2.0 CLOSE
- 82. W -V12 26 CIASE
- 83. W -V14A 14 GTI::t
- 84. W -V145 15 OPEN
- 85. W -V16A 13.7 OPEN
- 86. W-V165 13.7 OPEN
- 87. W -V16C 13.7 OPEN
- 88. MU-V16D 13.7 OPEN
- 89. W-V18 2.0 CLOSE
- 90. MU-V20 6
CLOSE
- 91. MU-V25 19.33 CLOSE
- 92. W-V26 3.0 CLOSE
- 93. MU-V36 10 CLOSE
- 94. MU-V37 11 CLOSE
- 95. MU-V51 1.7 OPEN
- 96. MU-V217 9.0 OPEN
- 97. NR-VIA 183 OPEN i
- 98. NR-V1B 188 OPEN i
- 99. NR-VIC 176 OPEN 100. NR-V4A 196 CLOSE 101. NR-V4B 198 CIDSE 102. NE-V45A 2
OPEN 103. NR-V45B 2
OPEN 104. NR-V45C 2
OPEN 105. NS-V4 33.0 CLOSE
APPENDIX A (CONTINUEDL Pcg2 4 of 5 VALVE LIMITING STROKE TIME (Sec.)
OPEN or CLOSE 106. MS-V15 54.0 CLOSE 107. Ms-V35 36.0 CLOSE 108. NS-V52A 2.0 OPW 109. NS-VS2B 2.0 OPa I 110. NS-V52C 2.0 OPEN 111. NS-V53&
2.0 0FM 112. NS-V535 2.0 OPW 113. MS-V53C 2.0 0 FIN 114. FF-V100 4.5 0FW 115. FF-V103 17.0 OPW 116. FF-V132 18.0 OPM 117. FF-V135 4.65 Oru 118. RB-V2A 47.0 CLOSE 119. RB-V7 36.0 CLOSE 120. E-V1 7
0FW 121. E-V2 13.8 CLOSE 122. E-V3 38 0FW 123. E-V4 32 OPEN 124. RC-V28 9.5 OPEN 125. E-V40A 2.0 OPEN 126. RC-V40B 2.0 OPEN 127. E-V41A 2.0 0 FIN 128. RC-V415 2.0 OPEN 129. RC-V42 2.0 OPEN 130. RC-V43 2.0 0 FIN 131. RC-V44 2.0 OPEN 132. 3R-VIA 183 OPEN 133.
RR-V1B 181 OPEN 134. RR-V3A 75 OPEN 1 35. RR-V3B 75 OPEN l
136. RR-V3C 75 OPEN 137. RR-V4A 73 OPEN 138. RR-V4B 73 0 FIN 139. RR-V4C 74 OPEN 140. RR-V4D 74 OPEN I
l
APPENDIX A (CONTINUED)
Page 5 of 5 VALVE LIMITING STROKE TIME (Sec.)
OPEN or CLOSE 141. RR-V5 191 OPEN 142. RR-V10A 25 OPEN 14 3.
RR-V10A 29 CLOSE 144. RR-V10B 29 OPEN 145. RR-V10B 31 CLOSE 146. SW-VilA 2,
OPM 147. SW-Vils 2
OPEN 148. SW-V17A 2
OPEN 149. SW-V17B 2
OPEN 150. WDG-V3 10.5 CLOSE 151. WDL-74 2
CIA 8E 152. WDL-V49 2.0 OPH 153. WDL-V50 2.0 OPEN 154. WDL-V61 5.25 OPM 155. WDL-V62 2.90 CLOSE 156. WDL-V89 14.5 OPW 157. WDL-V90 7.4 OPEN 158. WDL-V91 11.4 OPU 159. WDL-V92 8.5 OPW 160. WDL-V303 19.5 CIASE 161. WDL-V304 3.0 CLOSE 162. WDL-V534 11.1 CLOSE 163. WDL-V535 5.9 CLOSE