ML20148E977

Forwards Request for Addl Info Re Util 870820 Submittal of Rev 3 to Inservice Testing Program.Response Requested within 30 Days

ML20148E977
Person / Time
Site:	Clinton
Issue date:	01/21/1988
From:	Stevens J Office of Nuclear Reactor Regulation
To:	Spangenberg F ILLINOIS POWER CO.
References
TAC-62989, NUDOCS 8801260152
Download: ML20148E977 (6)

Text

January 21, 1988 DISTRIBUTION:

DiEEFFUi"'- OGC4thite Flint Docket No. 50-461 NRC & Local PDRs EJordan PDIII-2 r/f JPartlow GHolahan ACRS(10)

Mr. Frank A. Spangenberg JStevens PDIII-2 Plant File Manager-Licensing and Safety LLuther

-Clinton Power Station P.O. Box 678 Mail Code V920 Clinton, Illinois 61727

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION CONCERNING INSERVICE TESTINGPROGRAM(TACN0.62989)

A preliminary review of Revision 3 of the Illinois Power Company Inservice Testing (IST) Program dated August 20, 1987 for Cifnton Power Station, Unit I has been completed. This revision contains substantive changes beyond the scope of Revision 2 and the issues discussed during the meeting held on December 9 and 10, 1986.

As a result of our preliminary review of Revision 3, a list of questions and comments has been generated (Enclosure 1). Please respond to these questions within 30 days.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

For further information or clarification, please contact Janice A. Stevens at (301) 492-4993.

Sincerely, 15!

Janice A. Stevens, Project Manager 0801260152 880121 Project Directorate III-2 PDR ADOCK 05000461 P

PDR Division of Reactor Projects - III, IV, V and Special Projects

Enclosure:

j As stated l cc: See next page i

l PDIII-2 -

PDIII-2 x PD JStevens LLuthe r D er 1/ ;;11 /88 1/ , /88 1/ u /88

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Mr. Frank A. Spangenberg, III Clinton Power Station Illinois Power Company Unit 1 cc: Mr. L. Larsor, Mr. D. P. Hall Project Manager Vice President General Electric Company Clinton Power Station 175 Curtner Avenue, N/C 395 P.O. Box 678 San Jose, California 95125 Clinton, Illinois 61727 Regional Administrator, Region III Mr. R. D. Freeman 799 Roosevelt Road Manager-Nuclear Station Engineering Dpt. Glen Ellyn, Illinois 60137 Clinton Power Station P.O. Box 678 Chaiman of DeWitt County Clinton, Illinois 61727 c/o County Clerk's Office DeWitt County Courthouse ,

Sheldon Zabel, Esquire Clinton, Illinois 61727 Schiff. Hardin & Waite 7200 Sears Tower 233 Wacker Drive Illinois Department Chicago, Illinois 60606 of Nuclear Safety Division of Engineering' Resident Inspector 1035 Outer Park Drive, 5th Floor U.S. Nuclear Regulatory Commission Springfield, Illinois 62704 RR 3, Box 229 A Clinton, Illinois 61727 Mr. Donald Schopfer g-Project Manager Sargent & Lundy Enginoers I

55 East Monroe Street Chicago, Illinois 60603 e

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,- . . ENCLOSURE 1 ke CLINTON POWER STATION PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS

1. There are many valves in the IST program that are identified to be tested at a cold shutdown frequency. The Code permits testing valves at cold shutdowns if it is impractical to test them quarterly and they are specifically identified by the owner. These valves have been identified in the IST program and Relief Request No. 2016 details how the cold shutdown testing is to be performed, however, it is the NRC position that the licensee should provide technical justifications in which they explain why it is impractical to exercise these valves quarterly during power operations. These justifications should be part of the IST progra'n to facilitate evaluation by the NRC to determine if they agree that quarterly testing is in fact impractical. Provide the cold shutdown justifications for all valves or groups of similar valves that are identified to be tested on a cold shutdown frequency in the IST program.

2. The licensee requested relief from measuring pump bearing temperatures (refer to Relief Request No. 3001) but did not propose any additional testing to help determine pump mechanical condition. What alternate testing has been considered for evaluation of pump mechanical condition?

3. Relief from the allowable range requirements for pump flow rates and differential pressures cannot be granted on a general basis (refer to Relief Request No. 3006). The Code allows the owner to specify reduced ranges if the Code limits cannot be met for specific pumps in the IST program, however, the NRC does not agree with a general relief to relax limits for all pumps in the program. A general relief request could relax limits for pumps that normally fall well within the Code specified ranges, therefore, there would be no justification for not complying with the Code for those pumps.

4. Relief Request No. 3004 does not provide sufficient information for using pump discharge pressure to evaluate pump hydraulic performance for the 1

• shutdown service water pumps instead of differential pressure. The justification showed that the normal lake level variations over-the past three years are small enough that the licensee can adequately monitor pump hydraulic degradation by using pump discharge pressure and flow rate, however, provisions should be made to calculate pump differential pressure if the lake level goes out of a specified range (i.e.

691 3 feet). Also, the relief request should provide the allowable ranges of pump discharge pressure for our review or it should specifically state that the Code allowable ranges for differential pressure are applied to the discharge pressure measurements.

5. Do the pump flow rate calculations being performed on the standby liquid control pumps and diesel fuel oil transfer pumps meet the accuracy requirements of IWP-4110? If not, this should be addressed in the appropriate relief requests.

6. Relief request No.1002 is too general and is, therefore, unacceptable in its current form. We agree that testing should not be performed that would place the plant in a situation where it would be required to change the plant mode (i.e. shutdown) or enter an LCO with a short action statement where adequate time would not be available to correct a problem if a component failed during testing. However, entering an LC0 is not an adequate justification by itself for not performing required testing.

7. Relief request No. 2001 does not provide sufficient information for not testing feedwater header check valves quarterly or during cold shutdowns. The relief request should include a more detailed technical justificatior, that provides information such as an explanation of how interrupting flow could severely affect plant operation. Also, the relief request should more clearly explain why these valves cannot be exercised closed during cold shutdowns.

8. Provide a more detailed technical justification for not exercising valve ICll-F122 during cold shutdowns (refer to Relief Request No. 2002). Can the reactor recirculation pumps be stopped during cold shutdowns?

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9. The justification in Relief Request No. 2003 states that injecting plant demineralized water at normal temperatures during cold shutdowns would cause thermal transients that could damage various reactor protection system instrumentation. What is the basis for this statement? How much of a differential temperature is necessary to cause thermal shock damage to these components?

10. What alternate methods have been evaluated to detect degradation of valve 1E12-F095 (refer to relief request No. 2007)?

11. Relief Request No. 2008 states that valves 1G33-F052A and B will be disassembled and inspected on an alternating basis during refueling outages. A sample disassembly program is an acceptable testing method as long as it complies with the NRC guidelines for sample disassembly of check valves and the appropriate features of these guidelines are stated in the relief request.

The NRC staff guidelines on sample disassembly and inspection are:

a. Valve sample disassembly and inspection utilizing a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke capability and/or its reverse l flow closure capability. This program involves grouping similar valves together and testing one valve in each group during each refueling outage. The sampling technique requires that each valve j in the group be of the same design (manufacturer, size, model number l and materials of construction) and have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

b. A different valve of each group is required to be disassembled, inspected and manually full-stroke exercised at each refueling outage, until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must alsc be disassembled, inspected and manually full-stroke exercised during the same outage.

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12. Provide a more detailed technical justification for not exercising the

. valves identified in Relief Request No. 2009 during cold shutdowns. The fact that this testing requires a lot of time is an inconvenience but it is not an adequate basis for not testing the valves at a cold shutdown frequency.

13. Provide a more detailed technical justification for not exercising valves 1E12-F050A and B during cold shutdowns (refer to Relief Request No. 2010). Are both trains of shutdown cooling required to be in operation? Why can't these valves be exercised during the shutdown cooling mode of RHR operation?

14. Provide the technical justification for not utilizing system flow to exercise the valves affected by Relief Request No. 2014 quarterly during power operations or during cold shutdowns.

j 15. The infoemation in Relief Request No. 2016 can be stated elsewhere in the IST program. Relief is not necessary because the licensee's proposals for cold shutdown testing conform to the Section XI requirements and/or the NRC staff positions.

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16. How long can the reactor water cleanup system be out of service without j substantially degrading reactor coolant chemistry during cold

shutdowns? How long does it take to exercise the valves addressed in

! , Relief Request No. 2017?

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17. Provide a more detailed technical justification for not exercising valve IE12-F475 quarterly during power operations or during cold shutdowns (refer to Relief Request No. 2018).

18. Provide a more detailed technical justification for not measuring the operating torque for the valves addressed in Relief Request No. 2019 quarterly during power operations or during cold shutdowns.

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