ML20149G966

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Discusses 880106-07 Meetings W/Licensee,Nrc & Eg&G Idaho on-site to Discuss Plant Pump & Valve Inservice Testing Program.List of Attendees,Questions & Responses Encl. Meetings Resulted in 2 Open Items
ML20149G966
Person / Time
Site: Rancho Seco
Issue date: 02/16/1988
From: Kalman G
Office of Nuclear Reactor Regulation
To: Andognini G
SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
TAC-65670, NUDOCS 8802190035
Download: ML20149G966 (27)


Text

1 February 16, 1988 Docket No.: 50-312 Mr. G. Carl Andognini Chief Executive Officer, Nuclear Rancho Seco Nuclear Generating Station 14440 Twin Cities Road Herald, California 95638-9799

Dear Mr. Andognini:

SUBJECT:

INSERVICETESTPROGRAM(IST)MEETINGMINUTES (TACN0.65670)

On January 6 and 7, 1988, a working meeting was held at the Rancho Seco Nuclear Generating Station with the Sacramento Municipal Utility District (SMUD), NRC, and EG8G Idaho representatives to discuss the questions and coirarents resulting from the review of the Rancho Seco Nuclear Generating Station pump andvalveinservicetesting(IST) program.

Attached is a list of meeting attendees, the questions that served as an agenda for the meeting, and the responses to those questions. The utility representativas were given a brief introduction outlining the agenda and the '

methods used for documentating of questions and responses. This was followed by detailed discussions concerning specific pumps and valves in the Rancho Seco Nuclear Generating Station IST program.

These discussions resulted in two (2) open items for the licensee which are specificelly identified in the body of this report.

If you have any questions regarding the content of this letter, please communicate with the NRC project manager assigned to your plant.

Sincerely, original signed by Ge o r g e Knighton for George Kalman, Project Manager Project Directorate V Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

As stated g2190035 880216 p ADOCK 0500031p cc: See next page PDR DISTRIBUTION _ .

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0FFICIAL RECORD COPY

s Mr. G. Carl Andognini Rancho Seco Nuclear Generating

. Chief Executive Officer, Nuclear Station Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95638-9799 cc:

Mr. David S. Kaplan, Secretary Mr. John Bartus  :

and General Counsel Ms. JoAnne Scott Sacramento Municipal Utility Federal Energy Regulatory Comission District 825 North Capitol Street, N. E.

6201 5 Street Washington, D.C. 20426 P. O. Box 15830 Sacramento, California 95813 Thomas A. Baxter, Esq. Mr. Barclay S. Lew Shaw, Pittman, Potts & Trowbridge Pacific Gas and Electric Company 2300 N Street, N.W. 77BealeStreet(333/A613)

Washington, D.C. 20037 San Francisco, CA 94106 Mr. John V. Vinguist i Acting Manager, Nuclear Licensing i Sacramento Municipal Utility District Rancho Seco Nuclear Generating Station '

14440 Twin Cities Road Herald, California 95638-9799 ,

1 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division 1700 Rockville Pike - Suite 525 Rockville, Maryland 20852 Resident Inspector / Rancho Seco l c/o V. S. N. R. C. I 14440 Twin Cities Road I Herald, California 95638 I Regional Administrator, Region V U.S. Nuclear Regulatory Comission 1450 Maria Lane, Suite 210 l

Walnut Creek, California 94596 '

Mr. Jack McGurk, Acting Chief Mr. Joseph 0. Ward, Chief Radiological Health Branch Radiological Health Branch State Department of Health Services State Dept of Health Services 714 P Street, Office Building f6 714 P Steet Office Bldg. #8 Sacramento, California 95814 Sacramento, California 95814 Sacramento County Board of Supervisors 700 H Street, Suite 2450 Sacramento, California 95814 Ns. Helen Hubbard P. O. Box 63 Sunol, California 94586

ATTENDANCE Rancho Seco Nuclear Generating Station Working Meeting January 6 and 7, 1988 G. Paptzun SMUD M. Dion SMUD R. Jacobstein 3 MUD H. Heckert SMUD ,

J. Uhl .SMUD' D. K. Satpathy SMUD j J. Walkin SMUD G. Cranston SMUD J. Delezenski SMUD J

M. Nakao Bechtel J. P. Flynn INPO i

A. Masciantonio NPC/NRR/EMEB J. Silber NRC/ ARM /BUDB M. Lee NRC/ ARM /PAB G. Kalman NRC/NP.A/PD5 W. P. Ang NRC/Rgr V C. Meyers NRC Reside 1t Inspector T. L. Cook EG&G Idaho R. Bonney EG&G Idaho

.' RANCHO SECO NUCLEAR GENERATING STATION PUMP AND VALVE INSERVICE TESTING PROGRAM COMMENTS, QUESTIONS, AND RESPONSES I. VALVE TESTING PROGRAM A. General Comments and Questions

1. Provide a listing of all valves that are Appendix J, Type C, leak tested but not included in the IST program and eategorized A or A/C.

Response

All valves that are Appendix J, type C leak tested are included in the IST program.

2. Cold shutdown testing of valves identified by the licensee is acceptable when the following conditions are met:
a. The licensee is to commence testing as soon as the cold shutdown condition is achieved, but not 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 continue until complete or the plant is ready to return to power.
b. Completion of all valve testing is not a prerequisite to return to power.
c. Any testing not completed during one cold ehutdown should be performed during any subsequent cold shutdowns starting from the last test performed at the previous cold shutdown.

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..' .d. For planned cold shutdowns, where ample time is available and testing all the valves identified for the cold shutdown test frisquency in the IST p ogram will be accomplished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.

The Rancho Seco IST program should comply with these guidelines.

Response

The IST program will be revised to reflect the above guidelines.

3. Provide the limiting values of full-stroke times for the power operated valves in the IST program for our review. Provide the bases used to assign the limiting values of full-stroke time for these valves.

Response

The limiting values of full-stroke time for power operated valves have been provided. A discussion of stroke times will be added to the IST program.

4. Solenoid operated valves are not exempted from the stroke time measurement requirements of Section XI; their stroke times must be measured and c.,,rrective action taken if these times exceed the limiting value of full-stroke time. The NRC 4taff will grant relief from the trending requirements of Section XI, Paragraph IWV-3417(a) for these rapid-acting valves; however, in order to obtain this relief, the licensee must assign a maximum limiting stroke time of two seconds to these valves.

Response

The licensee will comply with the NRC staff's position concerning rapid-acting solenoid valves that stroke in 2 seconds or less.

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,- 5. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50, Appendix J. Relief from paragraphs IWV-3421 through 3425 for containment isolation valves presents no safety probleni'since the intent of IWV-3421 through 3425 is met by

( Appendix J requirements, however, the licensee shall comply with Paragraphs IWV-3426 and 3427.

l l Response:

The licensee will comply with IWV-3426 and 3427.

6. Relief Request No. VR-2 requests relief from the increused test frequency requirements of Section XI, paragraph IWV-3417(a) for i_ those valves that are specifically identified for testing only

} during cold shutdowns. The Code requires an increased frequency of tests to assure continued operability of the degraded valves l to demonstrate valve operability. Valves that are specifically identified for testing only during cold shutdowns that are found l to have exceeded the allowable change in stroke time and cannot

! Le tested at the increased frequency should be repaired and

! demonstrated ooerable prior to being required for plarit power operation.

Response

The licensee will modify valve relief request VA-2 such that cold shutdown exercised valves will be demonstrated operable prior to the plant being returned to power.

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

the IST program.

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. Response:

The-spent fuel pool ecoling system need not be. included in the IST program because a seismic category 1 makeup system is' utilized.

8. Concerning stop-check valves, does the valve position indicated in the program valve listing, Appendix B, reflect the normal position of the handwheel?

Response

1 Position reflects normal disc position. I l

9. The NRC position is that the emergency diesel generators perform a safety-related function and that the appropriate valves in the emergency diesel air start, cooling water, and fuel oil transfer i

systems should be included in the IST program and be tested in I accordance with the Code. Engine driven pumps are considered to be part of the diesel and need not be tested separately. Provide the P& IDS that show these emergency diesel generator subsystems for our review. i l

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Response

Open Item for licensee to provide a written response.

10. Does the control room ventilation system perform any safety-related function? If so, the appropriate support system pumps and valves should be included in the IST program.

Response

The control room HVAC system does perform a safety function, -

however, it does not fall within the scope of IWV-1100 as pertaining to pumps and valves and need not be included in the IST program.

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.' 11. A general relief from Code requirements cannot be granted for as yet unspecified valves (Refer to Relief Request No. VR-3). .If r problem does arise with testing any particular valves, then a specific request for relief should be submitted for those valves giving the detailed technical' justification which should include a discussion of possible equipment damage, reactor trip, or personnel hazards, and any other pertinent-information that should be considered when evaluating the request.

Response

Valve relief request VR-3 will be deleted, as relief is not

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required as per IWV-3522.

12. All containment isolation valves that cannot be individually leak tested and trended should be identified in the alternate testing of Relief Request No. VR-4.

Response

Containment isolation valves that cannot be individually leak tested and trended will be identified in valve relief request VR-4.

13. Concerning Relief Request No. VR-19, identify the affected valves that will require this relief. How will testing a valve with-pressure in the reverse direction with the valve body vented ensure the effective seating surface is subjected to the full differential pressure.?

Response

Valve relief request VR-19 will be revised to address only valves SFV-60001 and SFV-60003. The alternative testing of these valves is acceptable.

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. B. Reactor Coolant System-Q 5

1. Concerning safety valves PSV-21506 and PSV-21507, what is the basis for possibly extending the test interval to 10 years?

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Response

These valves will be tested on a 5 year frequency per OM-1.

2. Pressurizer power operated relief valve (PORV) PSV-21511 should be included in the IST program as a cattgory B valve and tested to the requirements of Section XI. However,'since PORVs have shewn a high probability of sticking open and are not needed for overpressure protection during power operation, the NRC has concluded that routine exercising during power operation is "not practical" and, therefore, not required by IWV-3410.

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The PORV's function during reactor startup and shutdown is to h I s

protect the reactor vessel and coolant system from low temperature overpresst.rization conditions and should be exercised

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prior to initiation of system conditions for which vessel /

protection is needed. The following test schedule is required: ,

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a. Full-stroke exercisirig should be performed at each cold .

shutdown or, as a minimum, ence each refueling cycle, ::ut not to exceed once per each t)1ee months.

b. Stroke timing should be performed'at each cold shutdown, or as a minimum, once each refueling cycle, bu't not to excoed once per each three months.
c. Fail-safe actuation testing should be performed at each cold shutdown.

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. Response: '

s Open Item for licensae to provide written response. The NRC requirements for the p0RV are an augmented requirement beyond the scope of IWV-1100.

- 3. Review the safety related function of valves HV-21515 and HV-215I7(PSID520, sheet 1,co-ordinatesF-7and0-8)to determine if they should be included in the IST program and ,

tested to the Code requirements.

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Response

These valves are not safety related and need not be included in the IST program.

C. Makeup and purificatien System

1. If failure of valves SFV-23645 and SFV-23646 during quarterly testing would render an entire safety related system inoperable, then testing these valves during cold shutdowns should be considered.

Response

Failure of these valves in the closed position during quarterly testing does not render any safety related system inoperable.

2. What are the consequences of failure in the shut position while full-stroke exercising valve SFV-23604 quarterly during power operation?

Response

Failure of this valve in the closed position could result in a reactor trip due to loss of pressurizer level control.

This valve may be exercised during cold shutdown.

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Describe the flowpath utilized when partial-stroke exercising valves SIM-045 and SIM-058 during quarterly pump testing.

Response

The flowpath utilized is into the reactor coolant system.

4. Can stop check-valves SIM-019, SIM-020, SIM-021, and SIM-022 be exercised closed with'the valve handwheel-during cold shutdown?

Response

These valves will be verified closed during cold shutdown.

A cold shutdown justification will be provided.

5. Can stop-check valves SIM-036, SIM-040, and SIM-047 be verified closed with the valve handwheel during cold shutdown?

Response

Yes, but these valves will be closure verified during refueling outages via leak testirg, l

6. Does valve LV-21503 (P&lD M-521, sheet 2, location C-8) have a required fail-safe position? .

Response

This valve does not have a required fail-safe position and need not be included in the IST program.

7. Review the safety-related function of valve SIM-119 (P&ID M-521, sheet 2, locatia, C-6) to determine if it should be included in the IST program and tested to the Code requirements.

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.' Response:

This valve does not have a safety function and need not be included in the IST program.

8 Provide P&ID M-521, sheet 3 of 3, for our review.

Response

The P&ID has been provided.~ There are no further questions.

D. Decay Heat Removal System

1. How are valves BWS-003 and BWS-004 full-stroke exercised open quarterly?-

Response

The decay heat removal and reactor building spray pumps are operated in parallel to achieve required design basis accident flow during exercising.

2. Provide a more aetailed technical justification for not full-stroke exercising valve BWS-045 quarterly.

Response

This valve cannot be exercised quarterly due to possible i boron builaup and crystallization, and subsequent pipe blockage. During cold shutdown an increased boron concentration during exercising could delay plant startup.

Valve relief request VR-10 will be augmented with this information.

3. What are the consequences of sodium hydroxide injection li:to the decay heat removal system (see Relief Request No. VR-13)?

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. Responsei Consequences include caustic stress cracking, sodium 1 activation, and chloride contaminatien as a result of sodium hy'droxide injection into the decay teat removal system. j Valve relief request VR-13 will be augmented with this information. l

4. The NRC has concluded that a valve sampling disassembly / inspection utilizing a manual full-stroke of.the disk is an acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in I the group must be of the same design (manufacturer, size, model number, and materials of construction) and must have tha 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).

A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entira group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, then the remainder of the valves in that group must also be  !

disassembled, inspected, and manually full-stroked at the same outage.  !

l Relief Request No's. VR-11 and VR-14 will be affected by this NRC position.

Response

Valve relief request VR-14 will be revised to reflect a l sample disassembly / inspection full-stroke exercising method, l

Valve relief request VR-11 may bJ revised with additional information. l I

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,- 5. How'are valves OHS-003 and DHS-004-verified to full-stroke open I quarterly?

Response

The decay heat removal and reactor building spray pumps are operated in parallel to achieve required design basis accident flow during exercising.

6. Provide a more detailed technical justification for not verifying the closure of valves OHS-017 and DHS-018 during cold shutdown.

Can these valves be verified to close utilizing the valve handwheel?

Response

These valves can be verified to close utilizing the valve handwheel during cold shutdown. A cold shutdown justification will be provided and valve relief request VR-18 deleted.

7. Review the safety-related function of valves HV-20001, HV-20002, .

HV-26105, and HV-26106 to determine if they should be categorized I A. Does quarterly exercising of valves HV-26105 and HV-26106

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result in back leakage into the reactor building emergency sump?

Response

'falves jV-26105 and HV-26106 will be categorized A. Valves HV-20001 and HV-20002 are correctly categorized B. Valves  !

HV-26105 and HV-2010G when exercised quarterly do allow back l

, leakage 'into the reactor building emergency sump and if

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failed open, would render an ECCS train (i.e. low pressure injection, high pressure injection, and reactor building spray) inoperable. These valves will be exercised during i cold shutdown.  !

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, 8. What is the safety-related function of valve HV-200037

Response

Th'is valve functions as a decay heat removal system dump to the reactor building sump for long term cooling and prevents boron crystallization.

9. What is the safety-related functiSn of valves HV-26037 and HV-26038 since they are categorized B, passive?

Response

These valves are categorized as B passive and may be deleted from the IST program as they perform no safety related function.

10. How are valves RCS-001 and RCS 002 full-stroke exercised open dur'ng cold shutdown?

Response

i These valves are full-stroke exercised during cold shutdown utilizing flow and differential pressure measurements. '

E. Reactor Building Spray System

1. How are valves CBS-001, CBS-002, CBS-005, and CBS-006 verified to full-stroke open quarterly?

Response

These valves are full-stroke exercised with reactor buildir.g i spray pump flow.  ;

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2. Provide a more detailed technical justification for not full-stroke exercising valves CBS-021, CBS-022, CBS-027, CBS-028, SFV-29015, and SFV-29016 quarterly.

Respons'e:

t These valves are not full-stroke exercised quarterly due to the possible caustic stress cracking and chloride contamination from the sodium hydroxide environment. Valve relief request VR-15 will be augmenteo with this information.

3. How are valves CBS-504 and CBS-505 verified to full-stroke open quarterly?

Response

These vacuum breakers are full-stroke exercised quarterly  !

utilizing a mechanical exerciser.

F. HP and Auxiliary Turbines System

1. The cold snutdown justification for main turbine throttle vanes TV-1, TV-2, TV-3, and TV-4 indicates that these valves will not be stroke timed quarterly. A relief request will be necessary if these valves are not stroke timed in accordance with the Code.

Response

These valves are stroke timed during cold shutdown.

2. What is the safety-related function (s) of valves HV-20597, l

HV-20598, HV-32243. HV-35069, and HV-350707 i i

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. Response:

These valves function to prevent uncontrolled blowdown of the steam generators during a branch steam line break, i

3. Provide the P&IO that shows valves HV-20517, HV20518. HV-20521, and HV-20522.

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Response

The P&ID has been provided. There are no further questions.

4. How are valves MSS-051 and MSS-052 individually verified to '

full-stroke open quarterly?

Response: l l

These valves are verified to full-stroke open monthly by

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utilizing the steam driven auxiliary feedwater pump full  !

flow recirculation path, i

5. What is the safety-related function (s) of valves HV-20570 and '

HV-205717

Response

These main steam branch line isolation valves serve to preclude excessive heat loss if a branch steam line fails.

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6. Why is the full-stroke exercising frequency different for atmospheric steam dump valves PV-20562A, PV-20562B, PV-20562C,  !

PV-20571A, PV-20571B, and PV-20571C?

1 l Response.

These valves will be full-stroke exercised at cold shutdown and the valve table revised.

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. 7. How is valve' MSS-068 verified to full-stroke open_ quarterly?

Response

l Th'ese valves are verified to full-stroke open monthly by utilizing the steam driven auxiliary feedwater pump full flow recirculation path, i

., 8. Is the Rancho Seco nuclear steam. supply system equipped with main .j steam tsolation valves? If so, provide the P&lO(s) that shows.

these valves.

Response

Rancho Seco does not have main steam isolation valves.  !

G. Steam Generator System ,

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1. Provide the P&ID that shows valves FV-20531, FV20532, HV-20581, HV-20582, HV-20515, and HV-20516. '

! Response:

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, TheP&IDhasbeenprovided. There are no further questions. I 1

2. Review the safety-related function of valves FWS-013 and FWS'-014 (P&IO M-53E, sheet 1, locations 0-12 and H-12) to determine if ,

they should be included in the IST program and tested to the Code i 1 requirements. l

Response

These valves do not perform a safety related function and need not be included in the IST program, f

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H. High Pressure Feedwater Heater System l

1. How are valves FWS-047 and FWS-048 verified to full-stroke open l quarterly?

Response

Auxiliary feedwater pumps flow during full flow recirculation full-stroke exercises these valves.

I. Condenser System

1. How are valves MCM-059 and MCM-060 verified to full-stroke open quarterly?

Response

Auxiliary feedwater pumps flow during full flow recirculation full-stroke exercises these valves.

J. Nuclear Service Cooling Water System

1. Should valves PSV-50013, PSV-50014, PSV-50015, and PSV-50016 (P&ID 545) be leak tested in the reverse direction because their  !

discharge lines communicate directly with containment atmosphere?

Response

These va,1ves need not be leak tested in the reverse direction, i

II. PUMP TESTING PROGRAM l

1. Provide the documentation that assures that vibration l instrumentation meets the accuracy requirements of the Code I (refer to Relief Request No. PR-3). j

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. Response:

Pump relief request PR-3 will be_ revised to reflect utilization of current instrumentation, concerning scale ra'nge requirements. Current instrumentation does meet Code required accuracy.

2. Provide the documentation that demonstrates that continued pump operability is assured after elimination of the Required-Action Range (high) limits for differential pressure and flowrate (refer to Relief Request No. PR-4). t

Response

rump relief request PR-4 will be revised to raise the Required Action Range (high) limits for differential pressure and flowrate to 110% of reference value.

3. Lack of installed instrumentation is not a suitable long term justification for not measuring the Code required parameters during pump tests. Relief Request No. PR-7 may be affected by this NRC position.

Response

Pump relief request PR-7 will be revised to explain why flow measurement cannot be taken during cold shutdown (LTOP concerns).

4. Calculation of inlet pressure is acceptable provided that it is dene for each quarterly pump test. This will affect Relief Request No. PR-8.

Response

Pump relief request PR-8 will be revised to reflect calculation of suction pressure for each pump test.

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. 5. What is the frequency of testing the dual drive auxiliary l feedwater-pump when-it is operating in the turt'9e-drive mode (refer to Relief Request No.'PR-9)? l 1

= Response.

Both the turbine driven and motor driven modes of operation are tested at least quarterly for the dual drive auxiliary-feedwater pump. Pump relief request PR-9 will be-deleted.

<- and an explanatory note added to the pump list.

6. In reference to Relief Request No. PR-10, have system modifications been completed to allow for measurement of flowrate?

, Response:

4 No, system modifications have not been completed, f

7. Identify those pumps where suction pressure instruments do not J

meet the requirements of IWP-4120 (refer to Relief Request No.

2 PR-11).

} Response:

i Affected pumps include P-236 makeup pump, P-238A and P-2388 high pressure injection pumps, P-261A and P-2618 decay heat '

removal pumps, and P-291A and P-2918 reactor building spray pumps. Pump relief request PR-11 will be revised to identify the above pumps and any other pumps that may

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require this relief. 6 t

2 8. When will instrumentation that meets the Code requirements be installed for measuring boric acid pump flowrate?

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  • Response:
  • I This instrumentation has been installed and pump relief i request PR-12 will be deleted.

I III. ADDITIONAL COMMENTS

1. Rancho Se:o has requested that the following Appendix J Program 1

information be included in the meeting minutes as an i attachment 1.

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2. Pump relief request PR-2 may be modified to include the DM-6, table 6100-1 limits. Pump relief request PR-2 is acceptable in its present form, excluding typographical errors. l I

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. i ATTACHMENT 1 l l

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RANCH) SECO APPENDIX J PROGRAM ALTERNATE TEST METHODS l

i JANUARY 1988 l 1

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Penetration Nisaber Descri pt lose Test MeJiism Test Methad JesstifIcation 3 Component Cooling Air Test Reverse Test Stop CW-O's is closed usion a measured Wat er Inlet Oseck Valve handwheel torque s. hit h is calculated to give a disc net seating lorre not-more t han t hat gener at ed by IJM:A pres-sure act ing on the inboaad side of the disc. Draining of the syhten to allow testing in the correct dire <3 tion

' would require disposal of a large'quan-tity of chemically and radiologically contaminated water.

4 Component Cooling Air Test Reverse Test Reverse testing l>ntterfly valves is Water Outlet Butterfly Valve equivalent, ASMF, (EPV c xte, Sec. XI IWV.3420 concurs.

14 Rx lluilding Water Test Penetration Tested The normal' sump is water filleil post Normal Sump Drain with Water IDCA.

16, 's, 58, RCP Seal Water Air Test Reverse Testing Stop dieck valves (Sim-020,021,022. 019) 68 Supply Oseck Valves closed by hand using t he installed hand wheels. 'lhe configurat son does _l not allow for t est ing valves pneumat- i ically. RCP seals are in dire <t commun- l ications with subject (beck valve.

Oneck valves are exer cised at cat h refueling.

19 R.B. Nitrogen Air Test Reverse Test Stop NCS-Ol8 is a locked closed stop (lieck Supply lleader Check Valve valve and is treat ed as a globe valve.

ASMF.IEPV co.le, See. XI, IWV.3420 justi-fles equivalent testing.

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Penetraties Number Description Test Medium Test Method Justificatina 20, 21, 22, liigh Pressure Water Test Penet rat ions Test ed %ese valves are required to operate-23 injection with Water and Ston (open) post 1/)CA. %is syst em is Check Valves are closed outside containnent with

, Reverse Tested integrity verified by rout ine surveil-l eonc e. %ese penet ra iuns as e t est ed during the II.RT. Valve lealdsge rat es not required to be measured per tHe definition of IOCFR.SO, App. J, If.II.

Consideration is being given to removing these penetrat ions f rom Tech Specs.

24 Pressurizer Relief Air Test Reverse Test Inboard S1 % 72501 is a small dian.eter (3/4")

Tank Cas Sample Gate Valve gate valve. When suh i ccted to 52 psi, minimal wedge del lect ion oc< ur s.

Seating surface is maintained during reverse or accident direction testing.

25, 26 Rx Building Water Test Penetrations Tested  % ese valves are required to operate Spray with Water and Stop. (open) post 11)CA. Tleis system is Check Valves are closed outside containment wi t h Reverse Tested integrit y verif ied by rout ine surveil-lance. %ese penet rat ions are tested during the ll.RT. Valve leakage rates.

not required to be measured per the

def inition of IOCFR.SO, App. J, 11,11.

Consideration is leeing given to removing these valves froan Tech Specs.

27, 28 Decay lleat Water Test Penetrations Tested h e DilS valves are required to operate Removal Inlet with Water and Stop (open) post ifX'A. % is system is closed Check Valves are outside ce,nt a ssument with int a grity Reverse Teuted verifled by routine sunweiitantc.

Valve leakage sates are not r espai red to be sneasured per t he def i ni t s on of 10CFR.SO, App. J, I I .11.

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Penetration Ilumber Ik scriyt ion Test Edium Test Methad Jesst i ficat ion 30, 31 Ex ituilding Water Test l'enet rat ions Test ed These valves are required to operate Emergency S.3p wit h Water (open) post IDCA. 'th i s syst em is Recirculation closed out side cont a s ument wi t h int egr it y veril ied I.y r unt ine survei l-lance. Valve leakage rates suit required to be measured per tiu del init ion of '

10CFR.50, App. J, i 1 .11 . Considerdtion is leeing given to removing these valves

. f rom Tec h Specs.

32 NCS Vent lleader Air Test Reverse Test inboard ikxly vent plug r emoved on SFv-60001.

Cate Valve This provides assus ance t hat the IDCA seat is tested during tl.c 1.lXT.

34, 35 Reactor fluilding Air Test Reverse Test Reverse test ing but terily valves is Purge Inlet and Butterfly Valves equivalent to accident direction testing Outlet ASME li&PV code, Sec. XI, IWV-3420 concurs.

47 Core Flood Tank Air Test Reverse Test inboard ilV-26515 and ilV-2651(> cannot be tested Drain and Sample Cate Valse When in the correct directinn without CFT is not Drained draining the CFTs. 'the CFTs ar e not drained during an outage as this requires disposal of a large quantity of liquid radwaste. IIV-26515 and HV-26516 are small (1/2") gate valves designed for high differential pressure.

The low differential pressure inposed by an IJDCA and 1.IKT result s in minimal wedge def lect ion.

Reference:

CCA 87-219 dated June 25, 1987 -

Subject:

Inservire Test ing (IST) Program lipdate..

Relief request VR.20.

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Penetrattan Number Desecript ion Test Ediese Test Metinod Jesst i fication t

l 57 Auxiliary Steam Air Test Reverse Test Stop ASC-049 is a Im ked closed stop check l Chet L Lelve valve and is t reat eil .ss a globe valve. .

! ASME li&PV code. Sec. .XI IWV-3420 just i-l fles equivalent t est ing.

73 RCS Drain lleader Air Test Reverse Test Inisoard flody vent. plug is renioved oa SIV-MMXrl.

Cate Valve 'llais provides assuraure Iliat time I5X:A seat is t ested during time I.lKl'.

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