ML20137X125

Forwards Summary & Trip Rept of 850904-05 Meetings W/Util & Eg&G in Bethesda,Md Re Inservice Testing of Pumps & Valves to Aid in Preparing Inservice Testing Package

ML20137X125
Person / Time
Site:	Three Mile Island
Issue date:	11/19/1985
From:	Stolz J Office of Nuclear Reactor Regulation
To:	Hukill H GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8512100416
Download: ML20137X125 (49)

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e. November 19, 1985 Docket No. 50-289 DISTRIBUTION GEdison WRussell Docket J11e '~

JPartlow NRC PDR' ACRS-10 L PDR Ringram Mr. Henry D. Hukill, Vice President ORB #4 Rdg JThoma and Director TMI-1 HThompson Gray File GPU Nuclear Corporation OELD EBrach.

P. O. Box 480 EJordan 40rnstein '

i Middletown, Pennsylvania 17057 BGrimes WPaulson

SUBJECT:

INSERVICE TESTING GF PUMPS AND VALVES On September 4 and 5,1985 a working meeting was held at the NRC offices in-L Bethesda, Maryland with GPU Nuclear Corporation, NRC, and EG&G Idaho, Inc.

representatives to discuss the inservice testing (IST) program of pumps and valves at THI-1. The meeting sumary dated September 16, 1985 contained a transcript of the meeting.

As a result of this meeting, your staff is preparing a new IST package scheduled for submittal to the NRC in late December 1985 or January 1986.

Enclosed is a trip report written by our contractor, EG&G, which discusses the meeting results. This trip report should be helpful to your staff in preparing your IST package.

Sinccrely,

• (,ta c mal SICD W JM J. SAh.'

John F. Stolz, Chief 1 Operating Reactors Branch #4 Division of Licensing

Enclosure:

As Stated cc w/ enclosure:

See next page ORB DL ORB #4

cr JStolz 1 1b 85 11/7 /85

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, 8542100416 851119 PDR ADOCK 05000289 P pop

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

i Mr. R. J. Toole Mr. Richard Conte O&N 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 i

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., Chairman 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 Dauphin County Commissioner Sheldon J. Wolfe, Esq., Chairman Dauphin County Courthouse 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 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 Carclina 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 Tucson, Arizona 85721 Environmental Resources P. O. Box 2063 Harrisburg, Pennsylvania 17120

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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 Committee 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 Committee 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 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 315 Peffer 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 l State College, Pennsylvania 16801 Ms. Ellyn R. Weiss l Harmon, Weiss & Jordan l Mr. Donald E. Hossler 2001 S Street, N.W.

l 501 Vine Street Suite 430 l Middletown, Pennsylvania 17057 Washington, D.C. 20009 l Mr. Ad Crable

Lancaster New Era l 8 West King 5treet l Lancaster, Pennsylvania 17602 l

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GPU Nuclear Corporation -

3- Three Mile Island, Unit 1

. , *A 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. 20555 t

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. p EGmG id.ha. NoraenAu w k.., .or commitm.nis.

7$" Date October 18, 1985 , g

.g Joel D. Page From C. B. RansoIn . C. Rockhold Mechanical Engineering Branch org. NRR and I&E Support c,g, EG&G Idaho, Inc.

Address NRC-DE Address TRIP REPORT FOR THE PUMP AND VALVE INSERVICE TESTING PROGRAM WORKING MEETING FOR THE THREE MILE ISLAND NUCLEAR STATION UNIT 1 On September 4 and 5,1985 a working meeting was held at .he NRC offices in Bethesda, Maryland with GPU Nuclear Corporation, NRC, and EG&G Idaho, Inc.

representatives to discuss the questions resulting from the review of the Three Mile Island Nuclear Station Unit 1 (THI-1) pump and valve inservice testing (IST) program. Attached is a list of the meeting attendees, the questions that served as an agenda for the meeting, and the responses to those questions as taken from the meeting minutes. The utility representatives were given a brief introduction outMning the agenda and the methods used for the documentation of questions and responses. This was followed by detailed

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discussions concerning specific pumps and valves in the TMI-1 IST program.

Of the 87 questions and comments discussed at this working meeting, 20 remain as open items to be resolved at a later date. These open items are identified in this trip report. There are several additional items where the licensee has agreed to make corrections or changes to their IST program as indicated in the responses to the questions.

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Attachment:

As Stated cc: E. C. Anderson R. J. Bosnak, NRC-DE F. C. Cherny, NRC-DE R. E. Lycn /4 -

C. F. Obenchain C. B. Ransom File H. C. Rockhold File

0. O. Thompson, NRC-DL

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ATTENDANCE LIST INSERVICE TESTING PROGRAM WORKING MEETING PLANT: THI-1 DATES: September 4 and 5, 1985 Name Representino Owen Thompson NRC-DL Richard Conte NRC-Region I Bob Knight GPUNC Joe Colitz GPUNC J. R. Bashista GPUNC Julien Abramovici GPUNC Mark Sanford GPUNC Henry Shipman GPUNC

. Richard Barley GPUNC Rick McGoey GPUNC Courtney Smyth GPUNC Richard F. Wilson GPUNC Clair Ransom EGF.G Idaho, Inc.

Herb Rockhold , EG8G Idaho, Inc.

Joel Page i NRC-DE Frank Cherny NRC-DE Owen Rothberg NRC-DE George Lear NRC-DE m , -,

MEETING MINUTES THREE MILE ISLAND NUCLEAR STATION UNIT 1 September 4 and 5, 1985 t

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. 1. VALVE TESTING PROGRAM A. GENERAL OVESTIONS AND COMMENTS

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

RESPONSE

The limiting values of full-stroke time for power valves in the IST program were provided in Appendix A of the GPUN submittal dated August 22, 1985. Valves AH-V1B and V1C have limiting stroke times of less than 2 seconds and will be added to Relief Request IX as rapid acting valves, MU-V51 has a limiting stroke time of 1.7 seconds and will also be added to Relief Request IX.

2. Are all valves that are Appendix J. Type C, leak tested included

• in the IST program and categorized A or A/C?

RESRONSE:

All Appendix J, Type C valves are included in the IST Program and they

- are categorized A or A/C.

QUESTION:

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 B-1 of the TMI-1 IST pump and valve submittal state the details of why it is not practical or safe to full-stroke these ..

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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

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

In the October 23, 1984 Supplement SER the staff agreed to the licensee's proposal of partial-stroke exercising CF-V4A/B on a cold shutdown frequency and a sample disassembly / inspection program for the valve grouping of CF-V4A/B and CF-VSA/B. CF-V4A/B and CF-VSA/B see essentially the same service conditions and they are the same size, manufacturer and catalog number. 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. If degradation is found which would make the valve's full stroke capability questionable, then the remaining three valves will be disassembled and inspected during that outage.

2. How are valves CF-V5A/B full-stroke exercised during cold shutdowns?

RESPONSE

The licensee proposed to test only one train of the decay heat removal system each cold shutdown due to the impracticality of switching ..

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. loops. This testing frequency is not in accordance with the Code or with current NRC positions,yDuring the licensee's proposed testing, valves CF-VSA and V5B do not receive a full-stroke exercise. The current NRC position is that these valves which are not full-stroke exercised with flow must be disassembled and exercised.

This remains an OPEN ITEM for the licensee to provide additional information on their proposed testing (including which valves receive a full-stroke, which receive a partial-stroke, and the percentages of partial-stroke exercising), and the testing frequency for all decay heat removal system components. The licensee will also submit additional information on the problems associated with switching the decay heat removal loops.

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-020?

RESPONSE

CA-V29 is in the depressurized RC sample return piping to the makeup tank upstream of MU-FlA/B. MU-FlA/B is shown on Drawing No. FD-016.

During nornel plant operation, the purpose of check valve CA-V29 is to close so that the makeup 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 a

1. What is the purpose of the chemical addition penetration No. 3077 Why is valve CA-V192 identified as a passive valve while valve CA-V189 is not?

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RESPONSE

Footnote (1) on page 3 of Table B-1 in the IST program is in error.

This footnote should be deleted. During normal plant operation check valve CA-V192 is open supplying 100 cc/ min reclaimed water purge to the No. 3 seal of each reactor coolant pump (RCP). This purge supply was provided in the original design to enhance RCP seal reliability but is not required to maintain seal integrity and is, therefore, isolated on reactor building containment isolation signals. The licensee will provide a relief request for valve CA-V192 stating that the valve is verified closed by a leak test each refueling interval per Surveillance Procedure 1303-11.18 and TMI-1 Technical Specification 4.4.1.2.1.b.1.

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

RESPONSE

CA-V134 supplies reclaimed 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.

I i E. CONTROL BUILDING CHILLED WATER SYSTEM

1. Do any of the temperature control valves shown on Drawing FD-011 l have a required fail-safe position?

RESPONSE

Some of these control valves may have a required fail-safe position l and would then be considered active valves that should be tested in the IST program. It remains an OPEN ITEM for the licensee to determine if any of the valves do have required fail-safe positions, and if any do, to determine how to test those valves.

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. F. EMERGENCY FEEDWATER AND FEEDWATER SYSTEMS

1. Provide a more detailed technical justification for not full-stroke exercising valves CO-V16A and C0-V168 during each

$b cold shutdown.

RESPONSE

This is an OPEN ITEM for the NRC to check TMI-1 Technical i Specification Amendment No. 78 to determine if the testing frequency proposed in the IST prograra for these valves is adequate.

G. DECAY HEAT REMOVAL SYSTE,5

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

RESPONSE

There are valves that perform a pressure boundary isolation function other than the valves covered by the Event V order. A PIV candidate list has been provided to the licensee. This topic is presently under consideration by the NRC, therefore, at this time no action is required in relation to this topic for the TMI-1 IST program.

l l 2. Provide a more detailed technical justification for not l full-stroke exercising valves DH-V1 and DH-V2 quarterly.

RESPONSE

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.

Quarterly testing would require defeating safety interlocks and would ,

! reduce redundancy by providing only one high pressure valve between the reactor coolant system and the low pressure decay heat removal system. The licensee will include these additional justifications ih ..

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the appropriate IST program footnote that justifies a cold shutdown exercising frequency for DH-V1 and DH-V2. The functional operability of the above-mentioned interlock is verified during the ESAS testing.

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 bar."-irrt and more than adequate protection for the decay heat removal system.

4. Review the safety function of valves DH-Y5A 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

i These valves are not leak rate tested and, therefore, are not categorized A. In order to prevent the flow of low grade water from the reactor building sump into the decay heat removal system during valve test, it is necessary to pump the sump and install a flange; this is done prior to exercising valves DH-V6A and V6B during refueling outagss. Due to the time, manpower, and personnel exposure (ALARA) requireil to perform these evolutions, it is not practical to' ..

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. perform this testing during cold shutdowns. The licensee will augment Relief Request I to incitde this justification.

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?

RESPONSE

A quarterly part-stroke test of DH-V14A/B is performed by recirculating the BWST with BS-P1A/B or DH-P1A/B. SP 1303-11.54 demonstrates that DH-V14A/B opens ~73% by pumping from the BWST to the reactor vessel each refueling outage. This remains an OPEN ITEM for the NRC to determine if the proposed partial-stroke of these valves (-67% of the required flow) is sufficient to demonstrate operability of these valves.

. 6. Provide a more detailed technical justification for not full-stroke exercising valves OH-V16A and DH-V168 during cold shutdown.

RESPONSE

One of these valves is full-stroke exercised during each cold shutdown. It remains an OPEN ITEM for the licensee to provide additional information and justification to support their proposed testing of these valves (Refer to the response to question B.2.)

7. -Review the safety function of valves DH-V22A and DH-V22B to determine if they should be categorized A/C.

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RESPONSE

The licensee,will categorize valves DH-V22A and V228 A/C instead of C.

8. Pro' vide a detailed technical justification for not full-stroke exercising valves DH-V22A and DH-V228 quarterly. How are these valves full-stroke exerciud during cold shutdowns while upstream valves DH-V16A and DH-V168 are only partial-stroke exercised?

RESPONSE

DH-V22A/B are on the discharge side of DH-P1A/B. DH-P1A/B only produce ~200 psig. Therefore, it is not possible to overcome normal RCS pressure with DH-P1A/B. Thus, it is impractical to test the opening function of DH-V22A/B each quarter.

DH-V16A/B are partial-stroke exercised each quarter since the piping configuration allows for recirculation of the BWST using pumps DH-P1A/B with flow through valves DH-V16A/B. The recirculation piping is upstream of DH-V22A/B; therefore, recirculation cannot be established through DH-V22A/B.

DH-V22A or 8 are full-stroke tested during cold shutdowns by recirculating the reactor vessel with DH-P1A 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-stroke exercises both DH-V22A and B.

The licensee has proposed to full-stroke exercise either DH-V16A or-V168 (one or the other but not both) during each cold shutdown. It

. remains an OPEN ITEM for the licensee to submit additional

! justifications to allow a determination to be made whether or not both valves should be exercised durir.g each cold shutdown, not to exceed once every 90 days (Refer to the response to questions B.2 and G.6).

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9. What is the safety function of valves DH-V38A and DH-V388?

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RESPONSE

Based on the LOCA symptoms, operators will use DH-V38A/B to balance decay heat flow (~1000 gpm per loop) per procedure 1210-7. This will be required particularly when one of the two decay heat pumps fails to operate. Such an action will ensure that sufficient low pressure injection flow is supplied to the RCS in the event of a core flood line break.

. 10. Review the safety function of valves DH-V59A and DH-V59B 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 co'ntrol 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 LIATER SYSTEM

1. Review the safety function of valves DR-V6A, DR-V68, OR-V7A, and DR-V78 to determine if they should be included in the IST program.

RESPONSE

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 valve internals.

DR-V7A/8. Each river water pump has one vacuum breaker check valve which permits air to enter the pump discharge column when the pump is ~..

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stopped. The atmospheric air is used to prevent a build-up of a

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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 and will test them quarterly by manually stroking the valve flappers open.

I. EMERGENCY FEEDWATER AND FEEDWATER SYSTEMS

1. How is 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?

RFSPONSF; 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 that the emergency feedwater 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).

l l Full flow testing of valve EF-V3 would introduce river water, silt and corrosives into the suction piping of the three emergency feedwater pumps and ultimately into the OTSGs. This is unacceptable from a chemistry control standpoint for normal operations. This valve is downstream of EF-V4 and V5; if EF-V4 and V5 are not stroked, then there is no flow to fully open EF-V3.

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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.

The licensee will provide a set of photographs of EF.V3 taken when the valve was disassembled. If the removal of the valve internals is not

. approved and accomplished by the end of the eddy-current test outage required by Technical Specification Amendment 103, the licensee will propose to disassemble this valve once every 10 years. This remains an OPEN ITEM for the licensee.

2. Provide a more detailed technical justification for not full-stroke exercising valves EF-VilA, EF-V118 EF-V12A, EF-V128, and EF-V13 during each cold shutdown. How is valve EF-V13 partial-stroke exercised quarterly?

RESPONSE

Full--stroke exercising these valves with flow results in the injection of highly oxygenated water from the condensate storage tanks into the OTSGs. Immediately after the test the oxyaenated water is drained from the OTSGs since oxygenated water incr;ases the probability of degrading the OTSG tubes. The licensee desires to minimize the

frequency that the tubes are exposed to highly oxygenated water by

. full-stroke exercising these valves "ollowing a lefueling outage or a cold shutdown when the cold shutdown >txceeds 30 days. This remains an l

0 PEN ITEM for the NRC to determine if 2he lic5.: E-s proposed testing i frequency is acceptable.

- EF-V13 is partial-stroke exercised quarterly by opening a drain valve at EF-V29 when EF-P1 is operating. EF-VilA and V11B cannot be partial-stroke exercised quarterly since the vent and drain connections are isolated by closure of EF-V10A and V108 during the pump test procedure.

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

Cateaory B Category C EF-V1A EF-V19A EF-V1B , EF-V19B EF-V2A EF-V21 EF-V2B

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 requirements of Technical Specification 4.9'.1.3. These valves are not required to perform an isolation safety function. They are installed to allow maintenance of the EFW pumps. Therefore, these valves should not be included in the IST program.

Valves EF-V2A/B are normally open during plant operation and are

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verified to be in the open position at least once per 31 days in i accordance with Technical Specification No. 4.9.1.3. These valves are not required to perform an isolation safety function since valves EF-V30A or -V30B can be used for isolation of the affected 0TSG if required by plant abnormal transient procedures. Therefore, valves EF-V2A/B should not be included in the IST program.

Valves EF-V19A/8 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 pumps in the recircu)ation mode.

l In addition, there are block orifices downstream of these check valves to reduce the pump discharge pressure to the pump suction pressure 12

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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 an isolation function. Therefore, the current surveillance test of the EFW pumps in the recirculation mode verifies the opening of these check valves and is an adequate test. Any failure of'the check valves to open would be detected by a high-differential pressure during the EFW pump test. The licensee will include EF-V19A/B and EF-V21 in the TMI-1 IST program and will exercise them quarterly in accordance with the Code.

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 shutdown.

RESPONSE

Full-stroke exercising EF-V4 and -V5 will introduce river water, silt, and corrosives into the suction piping of the emergency feedwater pumps. For chemistry control reasons, the river water must be flushed after performing the testing. The flush involves a slow fill and i drain procedure utilizing small vent and drain lines and valves, and does not remove all of the contaminants from the system. Therefore, f the licensee does not feel that testing these valves duritig cold shutdowns with the possible introduction of contaminants is warranted. The licensee will provide additional information in the basis for requesting relief in Relief Request I for the NRC to review.

K. DIESEL GENERATOR JACKET. AIR. AND GEAR BOX LUBE OIL COOLER COOLANT SYSTEM

1. How are check valves EG-V32A/A, EG-V32A/8, EG-V32B/A, and EG-V328/B individually verified to full-stroke exercise quarterly?

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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. It is verified that at least some of these valves open during the monthly performance of SP 1303-4.16. This procedure verifies that the diesels are capable of performing their design rating of 310.1 MW for one hour. This remains an OPEN ITEM for the licensee to determine if the current system testing provides sufficient information to determine individual valve operability.

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2. Do Valves EG-V31A, EG-V318, EG-V47A, and EG-V478 have a required fail-safe position?

RESPONSE

4 These valves are similar to thermostats on automobiles where there are no external controls. The valves could fail either closed or as is.

It may be possible to determine by observing temperature readings during the full load test whether each valve is open. This remains an OPEN ITEM for the licensee.

L. PENETRATION FLUID BLOCK. PENETRATION PRESSURIZATION AND HYDROGEN RECOMBINER SYSTEMS

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

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Subsequent to the licensee's submittal of July 10, 1984 the fluid

block system has been disatled, therefore, the valves listed in the '

! IST program have been deleted from all testing requirements. ~..

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M. EMERGENCY FEEDWATER AND FEE 0 WATER SYSTEMS

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

RESPONSE

GPUN will develop a method to verify the full closure capability of FW-V12A/B before startup from the Cycle 6 refueling outage (the

. Cycle 6 refueling outage is the next refueling outage). Until that time, the NRC has agreed that testing of FW-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. HYDROGEN PURGE SYSTEM AND MISCELLANEOUS PENETRATIONS

1. How are the following valves fail-safe tested?

HM-V1A HM-V3A HM-V1B HM-V3B HM-V2A HM-V4A HM-V2B HM-V4B

RESPONSE

HM-V1A/B, 2A/8, 3A/B, and 4A/B are solenoid operated valves which are deenergized to close. Therefore, they go to their fail safe position

, when electrical power is removed. Closed indication (from reed switches) is provided in the control room and the valve position indication is verified to be correct at least once every two years.

15

9 O. PENETRATION FLUID BLOCK. PENETRATION PRESSURIZATION. AND HYOR0 GEN RECOMBINER SYSTEMS

1. How are valves HR-V22A, HR-V228 HR-V23A, and HR-V238 fail-safe tested?

RESPONSE

b Same as Item N.1.

P. INTERMEDIATE COOLING SYSTEM

1. What is the safety function of valves IC-V1A and IC-V187

RESPONSE

IC-VIA/B are in the cooling water supply lines 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 abnornal conditions to place a second letdown cooler in service to maximize letdown flow. The licensee will identify these valves as being non-safety related in the IST program.

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 L power operation?

RESPONSE

IC-V2 has a test switch logic that allows it to only close 10%. 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, re&ctor coolant pump exchangers, and/or R. C.

drain tank heat exchanger. The licensee if required to perform a te'it ~ ..

16

on the ESAS quarterly which results in partial-stroke exercise of these valves to the mechanical block.

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 CROM stators) and reactor shutdown.

Q. MAIN STEAM SYSTEM AND DRAINAGE

1. Provide a detailed technical justific,ation for not full-stroke exercising valves MS-VlA, MS-VlB, MS-VlC, 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-V1A/B/C or D completely close during power operation in order to prevent damage to the OTSG that was not isolated.

2. What are the consequences of valve failure in the open position while full-stroke exercising valves MS-V4A and MS-V4B during power operation?

RESPONSE

Prior to stroke timing MS-V4A/B each quarter, its block valve MS-V15A/B is closed. There are no consequences since no steam flow results if MS-V4A/B remains open with MS-V15A/8 closed.

17

- - . .. _ _. -- - -.- -.- --= . .

.,,.n..s... . . , ,

s u

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?

- S. ,

RESPONSE: < T, i p - -

y .

This remains an 0PEfLi]E for the NRC. The 80% valve opening'value in th'e August 22,198i ficens'ee. transmittal appears to be incorrect; the licensee believes that the proper value is approximately 36% and the licensee will verify this value. The licensee will> propose to _

disassemble one of these valves every ten Yeart on a sample

- disassembly program. MS-V9B was disassemoled in 1984 and the licensee i

proposed to disa',Sefhble MS-V9A during the Cycle 6 refueling outage and to submit alEp'ofrt lon the inspection to the NRC. The licensee will also submit an operating history of MS-V9A/8 and a report on the disassembly of.MS-V9B to'the NRC. '

e MS-V9A/B are partial-stroke exercised individually per GPUN surveillance test procedulc No.130d-3G A/B.

MS-V9A/B are not required to perform a safety function in the closed

^

N

- position since the normally closed valves MS-V13A/8 and MS-V10A/B

,. perform this function.

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

Cateaory B Category C t

MAS-V4 MS-V22A HS-V8A MS-V228 MS-V8B MS-V6 .~ -

\.

l- 18 ,

1:

e .ee., s.,, - - - , , , ,<,---,,,--c - --,----mn c --w--n- , E - ~

q ,'

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RESPONSE

f AS-V4 is a normally closed valve, that does not perform any safety function and is'not required to change position during any transients. It is an isolation valve between main steam and auxiliary steam and is only opened to use auxiliary steam to test the turbine driven emergency feedwater pump.

It is an OPEN ITEM for the NRC to determine if EF-P1 (the turbine driven emergency feedwater pump) should be in the IST program. If it is determined that EF-P1 should be in the program, it is the staff's 5 position that MS-V8A/B perform a safety function and should be included in the IST program and be tested in accordance with the Code. 'The" licensee indicated that the valves cannot be exercised quarterly dur.ing power operation since there is a Technical s ,. Specification requirement that the valves remain open during I ~ operation. Therefore, if EF-P1 is required to be in the program, the licensee 'will propose to exercise MS-V8A/B during cold shutdowns. It is an OPEN ITEM for the licensee to determine if MS-V6 has a required fail-safe ;,osition. If MS-V6 does have a required fail-safe position, it is an active safety related valve that should be included in the IST program and be tested in accordance with the Code. The licensee indicated that if MS-V6 is determined to be safety related, they would (include a request for relief from measuring stroke times for MS-V6.

The status of MS-V22A/B hinges on the resolution of the MS-V6 open item and, therefore, remains open for both the NRC and the licensee.

R. MAKE'-bP AND PURIFICATION SYSTEM--LETDOWN PORTION

1. What is the safety function of valves MU-V1A and MU-V187

RESPONSE

MU-Vl/B are in the primary letdown piping to the letdown coolers.

Normally one cooler is in service. These valves do not provide an '

essential safety function. These valves may be used during certain ' ..

19

S. MAKE-UP AND PURIFICATION SYSTEM--HAKE-UP PORTION l

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

MU-V14A/B are stop check valves. These valves are full-stroke exercised and stroke timed quarterly utilizing the motor operators.

Category C testing verifies the full-stroke open function each refueling as required by T.S. 4.5.2.1 which states that tne valves be tested "during each refueling interval and following maintenance or modification" affecting system flow characteristics.

'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

Thernel shock to the injection nozzles is not a cons.ideration when i

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.

3. Provide a more detailed technical justification for not 7

[

full-stroke exercising valves MU-V73A, MU-V738, and MU-V73C l quarterly during power operation and cold shutdown.

22

. RESPONSE:

MU-V73A/B/C are the discharge check valves on make up pumps MU-P1A/B/C. During normal operations, MU-P1A 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/8/C. The licensee will provide the technical justification for not full-stroke exercising MU-V73A/8/C quarterly (the makeup pumps cannot develop full design accident flow into the RCS during power operation) or during cold shutdowns (full-stroke exercising the valve with flow should not be performed during cold shutdowns due to low-temperature overpressurization consideration).

4. Provide a more detailed technical justification for n.ot 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-V86B MU-V1078 MU-V94 MU-V107C MU-V95 MU-V1070 MU-V220

RESPONSE

These valves are in the four HPI legs to the RCS. Thernal shock to the injection nozzle considerations do not allow testing these valves g 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.

These valves are not Appendix J valves because they open in response to accident conditions. In addition, these HPI check valves do not

~..

23

... ~ _. - . ._. . _.

. meet the configuration criteria of WASH 1400 Event V and are not included in the Event V order dated April 20, 1981. Therefore, we believe that these HPI check valves are not required to be tested for a pressure isolation function. These valves are included in the GPUN appeal of the IST SER open items which we understand is currently

< under review by CRGR. This remains an OPEN ITEM. Also refer to the response to Question S.3.

5. What is the safety function of valves MU-V116 and MU-V2197 Does valve MU-V219 perform a containment isolation function?

RESPONSE

The safety function of both MU-V116 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. No change is required 4

in the IST program for valve MU-V219.

The licensee will provide a relief request from the Code requirement of verifying valve MU-V116 in its safety related position (closed)

~

quarterly or during cold shutdowns, and will propose to verify valve

closure during the leak-rate test performed at refueling outages.

6. What is the safety function of valve MU-2177 f

RESPONSE

l ,

This valve has no 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. MU-V217 will be identified as being non-safety related in the IST program.

24 1

. _ - . - ~ . . ~ _ _ . _ ,

~~~ - - -

. m _ _. . . .

7. Review the safety functions of valve MU-V112 to determine if it should be included in the IST program.

RESPONSE

MU-V112 prevents backflow of BWST 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 BWST, there will be a preferential drawdown from the BWST. Thus, even if back flow occurred as a result of MU-V112 failure, the water inventory will still be available for HPI. Therefore, MU-V112 is not required to be included in the IST program.

T. NITROGEN SUPPLY SYSTEM

1. Is there another containment isolation valve associated with NI-V27 on the nitrogen line at penetration 3077

RESPONSE

Yes. NI-V26 and NI-V27 are both manual locked closed isolatior, valves located outside of the reactor building. The licensee will include NI-V26 in the IST program if.that valve is currently leak-rate tested per Appendix J.

l U. RIVER WATER SYSTEN i 1. What is the safety function of valves NR-V4A'and NR-V4B7 l

I

RESPONSE

During a 1600 psig ESAS actuation NR-V4A and V4B automatically close l to prevent cooling water from being diverted from the nuclear river l water coolers.

i 25

~ . _ . . . . .

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

Cateaory B Category C NR-V6 NR-V22A NR-V2 NR-V228 NR-V19 NR-V22C NR-V18 NR-V29

RESPONSE

NR-V2 and V6 are cross-connect valves between the secondary river water system and the nuclear river water system. 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 subcritical. 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-V19 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. A concern was expressed that NR-V18 failing closed could defeat the function of the river water system and that the valve, therefore, is safety related. This remains an OPEN ITEM for the NRC, but will not require the licensee to take any action at the present time.

NR-V22A/B/C are vacuum breakers that are similar to those addressed in the response to question H.1. Therefore, these valves will also be added to the IST program.

26

^ ~ ~' ' ~ ^~

. - , . - ~ . . .

NR-V29 is the siphon breaker-ig 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. huCLEAR 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.

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, these valves will be full-stroke' tested on a cold shutdown frequency and partial-stroke exercised each quarter.

2. How is valve NS-V11 full-stroke exercised closed (its safety position) quarterly during power operation?

RESPONSE

NS-V11 is a containment isolation valve which supplies cooling water to the RC pump motor coolers and as in Item V.1 cannot be closed during normal plant operation. NS-V11's closed fur.ction is verified ,

each refueling outage when it is leak-rate tested per SP 1303-11.18.

NS-V11 is verified open on a quarterly basis.

3. Are valves NS-V52A/8/C and NS-V53A/8/C leak tested to Appendix J requirements to demonstrate their containment isolation function?

27

. . . - . - . ~.

RESPONSE

No. Valves NS-V52A/B/C and NS-V53A/B/C are isolation valves in the cooling water lines 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.

4. Do any of the following valves have a required fail-safe position?

NS-V55A cooling water to the control building coolers NS-V55B NS-V10B cool'.ng water to the control building air conditioning NS-V108

RESPONSE

This remains an OPEN ITEM for the licensee to determine if any of the listed valves have a required fail-safe position (refer to the response to question E.1).

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.

RESPONSE

RR-V10A/B are the minimum recirculation valves for RR-P1A/8. Their safety function is to automatically open when RR-P1A/B starts and then to close when a signal is received from the engineered safeguards 28

~~~ ' ~

4 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 dated July 10, 1984. "These valves will be added to the IST Submittal, Table B-1, Page 29 of 37 as follows:

RR-V10A/B, cage guided plug, 2", Diaphragm, 3, B T/FS, Q/Q.

RR-V12A/B are vacuum breakers which are similar to those addressed in the response to question H.1. Therefore, these valves will also be added to the IST program.

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

RESPONSE

RR-V3A/B/C and RR-V4A/8/C/D are isolation valves for the reactor building emergency cooling coils and they open automatically post-accident. In addition these valves are in a seismic Categorf 1 piping system which is a closed loop within the reactor building; therefore, they are not Category A valves.

2. Provide a more detailed technical justification for not full-stroke exercising the following valves quarterly during

< power operation and cold shutdowns.

S.

a 29 t

,e- w -n - - , , - . _ .- - _ , , ,.,,,_-,m- -_v.-e,_._-_y- . ,., _- , . ---y n y

RR-V8A RR-V8B RR-V9A RR-V98 RR-V9C

RESPONSE

RR-V8A/B and RR-V9A/B/C are valves in the supply and return water lines for the. reactor building emergency cooling coils. 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 outages generates unnecessary radioactive waste.

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

RESPONSE

Please delete "RR-V90" from the submittal. This valve does not exist. This was a typographical error.

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 shutting 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 coils 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. It remains an OPEN ITEM for the licensee to determine if valve RR-V6 has a required

~

fail-safe position (refer to the response to question E.1). ~..

30

Y. REACTOR BUILDING NORMAL COOLING SYSTEM

1. 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 operation. This system automatically isolates upon receipt of a containment isolation signal.

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

RESPONSE

RB-V7 is motor operated. The ISI Boundary Drawing will be revised to show this modification.

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 -V2A are partial-stroke exercised each quarter. They are not full-stroke tested because this would isolate normal cooling water to the reactor building atmospheric cooling coils. If RB-V7 or -2A were not reopened, this could quickly lead to violation of reactor building air temperature Limiting Condition for Operation (Tech.

Spec. 3.17) requiring a plant shutdown.

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

31

.c . ..

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

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

Category A Category A/C BS-VlA BS-V30A BS-VlB BS-V30B

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-VlA/B, 30A/B are not Category A valves.

t

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 prrgram of inspection is an acceptable means of full-stroke exercising check valves and should be performed at each refueling outaga.

RESPONSE

l The licensee proposes to partial-stroke exercise these valves on a quarterly basis and to verify the full-stroke capability of one valve (alternating between A and B) each 10 years by performing a

~ ..

l I 32 l

m , ~ ..... .

disassembly / inspection. 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 disassembled valve may be in question, the other valve will be disassembled and inspected at the same outage.

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

RESPONSE

BS-V23A/B are full-stroke exercised each quarter per SP 1300-3A by placing BS-P1A/B on recirculation of the BWST.

4. In reference to valves BS-V52A and BS-V528, 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

The staff agreed with the licensee's proposed testing of BS-V52A/B in the J. F. Stolz to H. D. Hukill SSER of October 23, 1984. Both valves were disassembled and inspected in January 1984 and found to be in "like 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). The licensee proposes to full-stroke both of these valves each 10 years by a disassembly / inspection. The licensee also stated that partial-stroke exercising these valves is not possible without contaminating the reactor coolant system with sodium Pydroxide.

s .

33

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-V12B which is administrative 1y kept locked open. The venting capacity of the 3" BS-V12B 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

1. What is the safety function of valves RC-V1 and RC-V3?

RESPONSE

RC-V1's function is control of RCS pressure. During a transient which increases RCS pressure, RC-V1 opens to allow for cooler water to spray

~

into the pressurizer, thus condensing steam and reducing RCS j pressure. Should RC-V1 fail open, cooler water would continue to flow j into the pressurizer, reducing pressure to below the normal operating point. For this reason the line also contains RC-V3, which can be used to control flow of cooler water to the pressurizer should the l

RC-V1 valve fail open. These valves have no essential safety function but are important to plant operation. The licensee will identify l

these valves as being non-safety related in th.e TMI-1 IST program, f 2. Review the safety functions of valves RC-V4 and RC-V23 to determine if they should be categorized A and A/C respectively.

i 34

RESPONSE

RC-V4 and RC-V23 are only used to spray the pressurizer when RCS pressure is less than 400 psig. During nornel operation these valves are shut and do not automatically open; therefore, they are entirely l passive (RC-V4 is procedurally required to be shut when the RCS is graater than 400 psig). Their leak tightness will be verified by current RCS leakage calculations.

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 A and A/C, respectively.

3. Is RC-RV-2 utilized for low , temperature overpressurization protection of the RCS at TM{-17 -

RESPONSE

~,

Per T.S.3.1.12.1, RC-RV-2 is utilized for low temperature overpressurization protection of the RCS. RC-RV-2 (the PORV) is a pilot operated valve that requires system pressure to stroke the valve. Therefore, testing the valve open with the RCS at pressure would result in a small break LOCA, which is not desirable. The PORV is a rapid acting valve, so stroke timing need not be trended. This remains an OPEN ITEM for the licensee. The NRC indicated that exercising the PORV during cooldown to refueling outage should be acceptable.

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.

35

Category B Catacory C SF-V1/2/3/4/5/6 SF-V7 SF-V8 SF-V11/12/13/14/15/16 SF-V50 SF-V51

RESPONSE

This remains an OPEN ITEM for the NRC to determine if the spent fuel pool cooling system should be included in the TMI-1 IST program. If it is decided that it should be included, furthEr discussions will be held with the licensee.

CC.- RIVER WATER SYSTEM

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

La_tegory B Category C SW-V24A SW-V6A SW-V24B SW-V6B SW-V23A SW-V8A

, SW-V23B SW-V8B

RESPONSE

SW-V24A/B are temperature control valves. It is an OPEN ITEM for the licensee to determine if these valves have a required fail-safe position. SW-V23A/B are the strainer blowdown valves for pumps SW-P1A/B. Strainer differential pressure is alarmed in the control room. SW-V23A/8 usually operate on a timed mode. They have no safety function and are installed for operator convenience.

36

. -. o . ..

4 SW-V6A/8 are the vacuum breakers on the discharge of pumps SW-P2A/8.

These vacuum breakers are similar to those addressed in the response to question H.1. Therefore, these valves will be added to the IST program.

I SW-V8A/8 are vacuum breakers that are similar to those addresse'd in the response to question H.1. Thererose, these valves will also be added to the IST program.

DD. MISCEll ANEOUS OUESTIONS AhD 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 shutdown.

RESPONSE

Testing the boric acid pumps and the boric acid recycle pumps will generate large amounts of liquid wastes. There are four pumps and the testing requires running each pump approximately 15 min which could generate up to 32,000 gal of radioactive liquid waste per pump. This much waste.is generated because injecting concentrated boric acid requires dilution of the RCS. The WDL-P13A/B boric acid recycle pumps do have a recirculation line and can, therefore, be tested quarterly and the licensee can measure pump AP and vibration. Flow cannot be measured when the pumps are running in a recirculation path because there is no-installed flow instrumentation. When testing the pumps during refueling outages, pump AP, vibration, and flow can be measured. The licensee proposed to test WDL-P13A/8 whenever these pumps are identified as Technical Specification pumps by making the AP and vibration measurements quarterly and measuring the flow, AP, and vibration during testing performed at refueling outages.

The boric acid pumps do not have a recirculation line and cannot be tested quarterly during power operation since this would add boric acid to the RCS which could result in power fluctuations.

37

Oue to the large amounts of radioactive liquid waste generated when testing these pumps, the licensee does not desire to test these pumps ,

i during cold shutdowns but desires to test CA-PlA/B during refueling outages. All power operated valves in these systems that are in the IST program will be tested quarterly in accordance with the Code. The check valves that are in the recirculation flow path of the bor'ic acid recycle pumps will bc exercised quarterly when t'ae pumps are tested.

The check valves in the flow path to the make-up tank can only be exercised during refueling outages when flow can be established through the valves. The licensee will include a discussion similar to this write-up in the appropriate relief requests.

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).

RESPONSE

4 1

See response to question M.1.

3. Since Technical Specification required testing is typically i utilized to verify system operability and Section XI required

test.ing 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 The individual valves affected by this staff position are addressed

-separately in the responses to other question. The Technical i Specifications provide for system operability testing, whereas the testing performed under ASME Section XI verifies individual component '

operation and the two are not necessarily dependent on each other. ~..

4 38 l

Therefore, the Technical Specification testing frequency does not necessarily suffice for meeting the Section XI requirements.

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-PlA or B, or WDL-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. This remains an OPEN ITEM. This item is related to item DD.1.

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

WDL-V49 WDL-V89 WDL-V50 WDL-V90 WDL-V61 WDL-V91 WDL-V62 WDL-V92 l RESPONSE:

l See the response to question D0.1.

2. PUMP TESTING PROGRAM i

A. EMERGENCY fEEDWATER SYSTEM l

l 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).

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. RESPONSE:

There is a flow instrument in the test flow path, however, the range of the flow instrument does not meet the Section XI IWP-4120 range requirements. The licensee will provide a relief request for measuring pump flow utilizing the installed flow instrumentation. The licensee's position that testing pumps in a fixed flow path and measuring AP but not flow is not consistent with the edition of the Code used by the licensee.

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?

RESPONSE

For cold shutdowns of short duration, heat loads (i.e, radwaste evaporator) do not allow operation of only one pump. The time involved before operation of only one pump is possible depends on many factors that vary for each shutdown.

C. NUCLEAR SERVICE CLOSED COOLING WATER SYSTEM

l. Do plant heat loads during cold shutdowns require operation of c

more than one nuclear service closed cooling water pump? Can

! individual pump flow rates be measured at that time?

l l

RESPONSE

l Same as B.1 response.

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l O. REACTOR BUILDING EMERGENCY COOLING SYSTEM

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

RESPONSE

FO-002 shows the flow path for RR-P1A/B quarterly testing. Quarterly testing is conducted with RR-V10A/B fully open and pump discharge valve RR-V1A/B closed. This produces a fixed flow rate through RR-V10A/B.

, 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.

RESPONSE: .

This item has the same justification as in the response to question X.2.

E

, E. SCREEN WASH SYSTEM

1. In reference to the pump flow measurement, the present NRC l

position is that lack of installed instrumentation is not l, suf ficient justification for not performing the required Section XI testing.

I

RESPONSE

l The licensee cannot measure flow when testing the screen Wash pumps due to the lack of installed flow instrumentation. The licensee stated that observing screen wash flow provides the operator with a visual indication of the pump flow. The NRC position is that not making the Code required measurements could prevent detection of pump

j. degradation and is, therefore, not acceptable. These pumps are not " ..

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covered in the plant Technical Specifications, but they are supplied with emergency power. It is an OPEN ITEM for the licensee and the NRC to investigate and discuss the safety significance of these pumps.

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