ML20148P633

Requests Meeting W/Util to Resolve Encl Questions & Comments Re Inservice Testing Program.Formal Responses to Questions Prior to Meeting Not Required,However Draft Responses Should Be Prepared for Discussion in Meeting

ML20148P633
Person / Time
Site:	Hope Creek
Issue date:	04/01/1988
From:	Rivenbark G Office of Nuclear Reactor Regulation
To:	Miltenberger S Public Service Enterprise Group
References
TAC-65730, NUDOCS 8804120031
Download: ML20148P633 (15)

Text

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Docket No. 50-354 Mr. Steven E. fiiltenberger Vice President and Chief Nuclear Officer Post Office Box 236 Hancocks Bridge, New Jersey 08038

SUBJECT:

HOPE CREEK IST PROGRAM QUESTIONS AND COMMENTS TAC #65730 Re: HOPE CREEK GENERATING STATION We have completed a preliminary review of the Inservice Testing Procram that Public Service Electric and Gas Company (PSEAGI has proposed for the Hope Creek Generating Station. During our review, we developed the enclosed set of questions and concents concerning the proposed program. We would like to meet with you in about two months to resolve these questions and comments. The meeting should be held at the Hope Creek site. Formal responses to these questions and comments prior to the meeting are not required; however, draft responses should be prepared for discussion in the '"eeting.

After you have reviewed the questions sufficiently to schedule the meeting with the staff, please contact us so that we can select a mutually acceptable date for the meeting.

Sincerely, M

G orge ivenbark, Pro,ect Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/enclosura:

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• 1. April 1, 1988 Docket No. 50-354 Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Post Office Rox ?36 Hancocks Bridae, New Jersev 08038

SUBJECT:

HOPE CREEK IST PROGRAM OUESTIONS AND COMMENTS TAC 365730 Re: HOPE CREEK GENERATING STATION We have completed a preliminary review of the Inservice Testing Program that Public Service Electric and Gas Compan.y /PSEAG) has proposed for the Hope Creek Generating Station. During our review, we developed the enclosed set of questions and comments concerning the proposed program. We would like to meet with you in about two months to resolve these questions and comments. The meeting should be held at the Hope Creek site. Formal responses to these questions and comments prior to the meeting are not required; however, draft responses should be prepared for discussion in the meeting.

After you have reviawed the questions sufficiently to schedule the meeting with the staff, please contact us so that we can select a mutually acceptable date for the meeting.

Sincerely, George Rivenbark, Project Manager Proiect Directorate I-2 Division of Reactor Projects I/II ,

Office of Nuclear Reactor Regulation

Enclosure:

As stated cc w/ enclosure:

See next pace i

O Mr. Steven E. Miltenberger Hope Creek Generating Station Public Service Electric & Gas Co.

cc:

Gregory Minor Mr. B. A. Preston, Manager Richard Hubbard Licensing and Regulation Dale Bridenbaugh Nuclear Department MHB Technical Associates P.O. Box 236 1723 Hamilton Avenue, Suite K Hancocks Bridge, New Jersey 08038 San Jose, California 95125 M. J. Wetterhahn, Esquire Susan C. Remis Conner & Wetterhahn Division of Public Interest Advocacy Suite 1050 New Jersey State Departnent of 1747 Pennsylvania Avenue the Public Advocate Washington, D.C. 20006 Richard J. Hughes Justice Complex CN-850 R. Fryling, Jr., Esquire Trenton, New Jersey 08625 Law Department - Tower SE 80 Park Place Office of Legal Counsel Newark, New Jersey 07101 Department of Natural Resources and Environmental Control Resident Inspector 89 Kings Highway U.S. Nuclear Regulatory Commission P.O. Box 1401 P.O. Box 241 Dover, Delaware 19903 Hancocks Bridge, New Jersey 08038 Ms. Rebecca Green Richard F. Engel New Jersey Bureau of Radiation Deputy Attorney General Protection Division of Law 380 Scotch Road Environmental Protection Section Trenton, New Jersey 08628 Richard J. Hughes Justice Complex CN-112P Mr. Anthony J. Pietrofitta Trenton, New Jersey 08625 General Manager Power Production Engineering Mr. S. LaBruna Atlantic Electric General Manager-Hope Creek Operations 1199 Black Horse Pike Hope Creek Generating Station Pleasantville, New Jersey 0823?

P.O. Box 118 Hancocks Bridge, New' Jersey 08038 Regional Administrator, Region I U.S. Nuclear Reculatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 i

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HOPE CREEK GENERATING STATION PUMP AND VALVT. INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS

1. VALVE TESTING PROGRAM A. General Questions and Comments

1. Cold shutdown testing of valves identified by the lir.ensee is acceptable when the licensee commits to commence testing as soon as the cold shutdown condition ir >ed, but'nct later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and contiti. .

1; complete or the plant is ready to return to power. (See Generic Valve Relief Request No.

I.)

2. The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them during plant operation providing those valves are specifically identified by the licensee and are full-stroke exercised during cold shutdowns.

The NRC staff requires that the licensee provide a detailed technical justification for each valve that cannot be exercised quarterly that clearly explains the hazards involved ( such as endangering personnel, equipment damage, or resulting in a plant trip ) that would be encountered during that testing. The staff will then verify that it is not practical to exercise these valves and that the testing should be performed during cold shutdowns. '

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3. Provide a listing of the limiting values of full-stroke time for all power operated valves in the Hope Creek IST program for our review.

4. Provide a list of all valves that are Appendix J, Type C, leak rate tested and that are not included in the Hope Creek IST program and categorized "A" or "A/C".

5. Relief requests and cold shutdown justifications that reference the FSAR, Technical Specifications, and other documents should be expanded to provide a brief discussion of the applicable technical information contained in the referenced document. (See Relief Request V-06)

6. Excess flow check valves should be included in the IST program as Category A/C valves and tested in accordance with Section XI to the extent practical.

7. Category A, passive, valves should be identified in the IST program.

8. The IST program should include the required safety position and 4

clearly identify the testing frequency of each valve.

9. Are individual leak rate limits assigned to each relief valve that is categorized A/C and Appendix J, Type C, leak rate tested?

10. The staff considers air operators on air operated testable check valves to be an operator rather than a mechanical exerciser, therefore, measuring opening torque is unnecessary. Relief Request V-17 is unnecessary as written, however, revision will be necessary if the test operator does not move the check valve disk l

to the full open position. l l

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11. If the spent fuel pool cooling system performs a safety-related function, then the appropriate pumps and valves should be included in the IST program.

12. Those valves, if any, that perform both a containment isolation function and a pressure boundary isolation function must be leak tested to both Appendix J and Section XI requirements.

13. Relief requests must be specific in identifying the Section XI requirements from which relief is being sought.

B. Main Steam and Drains System P&ID M-41-1, Sh. I and 2

1. How are valves 1-AB-V051 through -V058 verified to close during cold shutdowns?

2. If valves 1-AB-PAV-4500 and 1-AB-PAV-37 are simple check valves, then they must be tested in accordance with the requirements for Category C, active, check valves.

3. Why are valves 1-AB-PAV-4504A through -4504R categorized A/C while valves 1-AB-PAV-4505A through -4505D are categorized C 7

4. Those safety relief valves (1-AB-PSV-F013A through -F013R) which perform an ADS function are required to be categorized B/C and l tested to the requirements of Section XI for both categories.

Provide a more detailed technical justification for not full-stroke exercising these valves quarterly. How is stroke time measured when testing these valves?

5. Why are valves 1-AB-V043 through -V050 categorized A/C7 l

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6. Provide o morD detailed technic;C juttificati6n t'or not exercising valves 1-AB-V043 thfuuyh -VC50, and -VICO through

-V114 ciosed during cold shutdowns when tha containment is de 'inerted.

7. Solenoid operated air control valves are considered to be part of the larger valve assembly that they operate and need not be included in the IST program separately. (See Relief Request V-14)

8. Provide a detailed technical justification for not full-stroke exercising valves 1-AE-V003 and -V007 quarterly.

9. Provide a detailed technical justification for not full-stroke exercising valves 1-AE-HV-F032A, -F032B, -F074A, and -F074B quarterly and during cold shutdowns.

10. Provide the P&ID that shows the location of valve 1-AE-HV-4144 (1-AE-V138),

11. Review the safety-related function of valves lwAB-HV-F067A,

-F067B, -F067C, and -F0670 to determine if they should be included in the IST program and tested in accordknce with the requirements of Section XI.

! C. Reactor Water Cleanup System P&ID M-44-1

1. Provide a detailed technical justification for not full-stroke exercising valves 1-AE-V127, -V128, and 1-AE-HV-F039 quarterly.

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A in D. Reactor Recirculation System P& ids M-43-1 and M-42-1

1. How are valves 1-BB-V043 and -V047 verified closed during cold shutdowns?

2. Provide a more detailed technical justification for not full-stroke exercising the excess flow check valves listed in Relief Request V-06 during cold shutdowns.

E. Residual Heat Removal System  :

P&lD M-51-1 i

1. Can valves 1-BC-V030, -V033, -V127, and -V130 be full-stroke exercised open during the quarterly pump test? l I

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2. What alternate means of measuring valve degradation have been '

investigated other than "freedom of motion" as referenced in Relief Request V-18?

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3. Review the safety-related function of check valves V090, V195, V207, and V210 to determine if they should be included in the IST program. (P&ID M-51-1, Sh. 1, C-5)

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4. Review the safety-related function of valves 1-BC-HV-4420B and l 1-BC-HV-4421 to determine if they should be included in the IST program. (P&lD M-51-1, Sh. 1, D-3 and D-2, respectively)

5. What is the safety-related function of check valves 1-AP-V055 and

-V058 if the normal position of the manual valve downstream of each is closed as shown on the P&lD?

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6. How are check valves 1-BC-V206 and -V260 verified closed quarterly?

F. Reactor Core isolation Coolina System P& ids M-49-1 and M-50-1

1. How is check valve 1-BD-V006 verified to full-stroke exercise open quarterly?

2. How are check valves 1-BD-V028 and -V029 individually verified to full-stroke exercise closed quarterly?

3. What is the safety-related function of check valve 1-AP-V051 if the normal position of the manual valve downstream of it is closed as shown on the P&lD?

4. Can valve 1-FC-V003 be verified to full-stroke exercise during the quarterly pump test?

5. Would failure of valve 1-FC-HV-V007 in the closed position while testing render an entire safety system inoperable? Should this valve be full-stroke exercised during cold shutdowns?

G. Core Spray System P&!D M-52-1

1. Can check valves 1-BE-V028, -V030, -V032, and -V034 be verified to full-stroke exercise open using system flow?

2. Review the safety-related function of valves 1-BC-V309 and -V313 to determine if they should be included in the IST program.

3. What is the safety-related function of check valves 1-AP-040 and

-061 if the normal position of the manual valves downstream of each is closed as shown on the P&ID?

H. Control Rod Drive System P&ID M-47-1

1. Industry experience has shown that valve 1-BF-V138 is full-stroke exercised closed during normal control rod movement, therefore, this valve may be removed from Relief Request V-16.

2. What is the frequency of the control rod scram time testing proposed in Relief Request V-167

3. How is stroke time measured when testing valves 1-BF-V126 and

-V1277 l

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4. The NRC staff position is that check valve 1-BF-V115 is to be '

included in the IST program and tested to the requirements of l

Section XI to the extent practical. '

I. Standby Liquid Control System P&ID M-48-1

1. Provide a detailed technical justification for not full-stroke exercising valves 1-BH-V004 and -V005 quarterly.

o J. High pressure Coolant injection System P&lDs M-55-1 and M-56-1

1. What is the safety-related function of check valve 1-AP-V037 if the normal position of the manual valve downstream of it is closed as shown on the P&lD?

2. Provide a detailed technical justification for not full-stroke exercising closed check valve 1-BJ-V014 quarterly. How is check  ;

valve 1-BJ-V023 verified closed quarterly?

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3. Can check valve 1-BJ-V015 be verified to full-stroke open during l the quarterly pump testing?

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4. Provide a detailed technical justification for not full-stroke exercising check valve 1-BJ-V024 quarterly.

5. Can check valve 1-FD-V004 be verified to full-stroke exercise during the quarterly pump testing?

6. provide a detailed technical justification for not full-stroke exercising valves 1-FD-V032 and -V038 quarterly.

l 7. Would failure of valve 1-FD-HV-V002 in the closed position while testing render an entire safety system inoperable? Should this valve be tested at cold shutdowns? l l

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, - - - _ , y --n K. Safety Auxiliaries Cooling System P&ID M-11-1

1. Review the safety-related function of valves 1-EG-TV-2517A and

-2517B to determina if they should be included in the IST program.

L. Containment Atmospheric Control System P&ID M-57-1

. How are check valves 1-GS-V081, -V093, -V138, and -V139 individually verified te close?

2. Why are valves 1-GS-PSV-4946A through -4946H categorized A/C and then exempted from Section XI leak rate testing?

l M. Diesel Fuel Oil System P&ID M-30-1

1. The NRC staff position concerning the diesel fuel oil transfer system is,that those valves in the system from the diesel fuel oil storage tank to the day tank are considered to be safety-related and should be in the IST program. Relief Requests V-08 and V-13 appear to be unnecessary and may be deleted from the IST program.

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N. Containment Instrument Gas System P&ID M-59-1

1. The NRC staff position concerning skid mounted valves is that they are tested as a unit with the associated equipment and need not be included in the IST program separately. Relief Request V-11 may be affected by this staff position.

2. How is check valve 1-SE-V006 verified to close during cold shutdowns?

0. Service Water System P&ID M-10-1

1. How are check valves 1-BC-V423 and -V557 verified to full-stroke exercise open quarterly?

2. Provide a detailed technical justification for not full-stroke exercising valves 1-ED-HV-2357A and -23578 quarterly.

3. Review the safety-related function of valves 1-ED-HV-4647 and

-4648 to determine if they should be included in the IST program.

P. Reactor Auxiliaries Cooling System P&ID M-13-1

1. Why are valves 1-E0-HV-2598 and -2599 leak rate tested?

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Q. Main Steam Isolation Valve Sealing System P&ID M-72-1

1. How are valves 1-KP-V011 and -V017 through -V023 verified to full-stroke exercise during cold shutdowns?

2. Review the safety-related function of valves 1-KP-PCV-5825A and

-5825B to determine if they should be included in the IST program and tested in accordance with the requirements of Section XI.

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2. PUMP TESTING PROGRAM l i

1. The NRC staff position concerning skid mounted pumps is that they are tested as a unit with the associated equipment and need not be included in the IST program separately. Relief Request P-4 may be affected by this position.

2. The NRC staff requires that both flow and differential pressure be measured during quarterly pump testing. The Hope Creek IST program does not reflect this requirement.

3. How is flow and differential pressure measured during the quarterly testing of the service water screen wasF pumps?

4. How is differential pressure measured during the quarterly ,

testing of the service water pumps?

5. What is the safety-related function of the HPCI and RCIC system jockey pumps?

6. Provide a detailed technical justification for not testing the standby liquid control pumps quarterly in accordance with the requ'.ements of Section XI.

7. Provide a detailed technical justification for not ttsting the core spray pumps independently.

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