ML20149M095

Comments & Questions Re Pump & Valve Inservice Testing Program at Facility

ML20149M095
Person / Time
Site:	Rancho Seco
Issue date:	02/19/1988
From:	NRC
To:
Shared Package
ML20149L838	List: ML20149L836 ML20149M095
References
FOIA-88-89 NUDOCS 8802250313
Download: ML20149M095 (10)

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RANCHO SECO NUCLEAR GENERATING STATION POMP AND VALVE INSERVICE TESTING PROGRAM COPNENTS AND QUESTIONS I. VALVE TESTING PROGRAM t

A. General Consnents and Questions

1. provide a listing of all valves that are Appendix J, Type C, leak tested but not included in the IST progrart and categorized A or A/C. '

2. Cold shutdown testing of valves identified by the licensee is acceptable when the following conditions are met:

a. The licensee is to comence 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 shutdown should be performed during any subsequent cold shutdowns starting from the last test performed at the previous cold shutdown,

d. For planned cold shutdowns, where ample time is available and testing all the valves identified for the cold shutdown test frequency in the IST program 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 Ranch'o Seco !$T program should comply with these guidelines.

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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 tjme for these valves.

4 Solenoid operated valves are not exempted from the stroke time measurement requirements of Section XI; their stroke times must be measured and corrective action taken if these times exceed the

. limiting value of full-stroke time. The NRC staff 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.

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 !WV-3421 through 3425 for containment isolation valves presents no safety problem 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.

6. Relief Request No. VR-2 requests relief from the increased test frequency requirements of Section XI, Paragraph IWV-3417(a) for 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 to demonstrate valve operability. Valvet that a e specifically identified for testing only during cold f.hutdowns that are found to have exceeded the allowable change in stroke time and cannot be tested at the increased frequency should be repaired and demonstrated operable prior to being required for plant power operation.

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7. If the spent fuel cool cooling system performs a safety-related ,

function, the appropriate pumps and valves should be included in the !$T program.

8. Concerning stop-check valves, does the valve position indicated in the pt,Jram valve listing Appendi A B, reflect the normal position of the handwheel?

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

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.

11. A general relief from Code requirements cannot be granted for as yet unspecified valves (Refer to Relief Request No. VR-3). If a 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.

12. All containment isolation valves that cannot be individually leak tested and trended should be identified in the riternate testing of Relief Request No. VR-4, 3

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13. Concerning Relief Request No. VR-19, identify the affected valves ,

thatyill, require .th.is_ relief,.. How will testing a valve with >

pressure in the reverse direction with the valve body vested ensure 'the effective seating surf ace is subjected to the full differential pressure.7 B. Reactor Coolant System

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

2. Pres.surizer power operated relief valve (PORV) PSV-21511 should be included in the IST program as a category B valve and tested '

to the requirements of Section XI. However, since PORVs have shown a high probability of sticking open and are not needed for overpressure protection during power operation, the NRC has 4

concludei that reJtine exercising during power operation is "not practical" and, therehre, not required by IWV-3410. '

The PORV's fu..usion during reactor startup and shutdown is to protect the reactor vessel and coolant system from low

• temperature overpressurization conditions and should be exercised I i

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 exercising should be performed at each cold 1

shutdown or, as a minimum, once each refueling cycle, but not to exceed once per each three months.

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! b. Stroke timing should be performed at each cold shutdown, or I

as a minimum, once each refueling cycle, but not to exceed  ;

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once per each three months.

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c. Fail-safe actuation testing should be performed at each cold l

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3. Review the safety related function of valves HV-21515 and "

HV-21517 (P&l0 520, sheet 1, co-ordirates F-7 and D-8) to determine if they should be included in the IST program.and

, tested _ to the Code recuirernents.

C. Makeup and purification System i

1. If f ailure 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.

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

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3. Describe the flowpath utilized when partial-stroke exercising i valves SIM-045 and $1M-058 during quarterly'; ump testing.

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4. Can stop check-valves $1M-019, $1M-020, SIM-021, and $1M-022 be l1 1

exercised closed with the valve handwheel during cold shutdown?

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

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) 6. Does valve LV-21503 (PalD M-521, sheet. 2, location C-8) have a  !

{ required fail-safe position? t

) 7. Review the safety-related function of vdve SIM-119 (pl!D M-521, j l sheet 2, location C-6) to determine if it should be included in

the IST program and tested to the Code requirements.

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

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D. Oecay Heat Removal System

1. How are valves BWS-003 and BWS-004 full-stroke exercised ppen cuarterly?

2. Provide a more detailed technical justificatter. for not full-stroke exe: "sing valve BWS-045 quarterly.

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

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

q A different valve of each group is required to be disassembled.

• 1 inspected, and manually full-stroked at each refueling until the i entire group has been tested. If it is found that the disassembled valve's ful.> stroke capability is in question, then l

the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.

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

5. How are valves DHS-003 and DHS-004 verified to full-stroke open 1

quarterly?

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6. Provide a more detailed technical justification for.nct' verifying the closure of valve.s ch5-017-(nd OHS-018 during cold shutdown.

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

7. Review the safety-related function of valves HV .20001, HV-20002, HV-26105, and HV-26106 to determine if they should be categorized A. Does quarterly exercising cY val,es 'iiV 26105 and HV-26106 result in back leakage into the reactor building n.mergency senp?

8. What is the safety-related function of valve HV-200C3?

9. What is the safety related function of valves HV-26037 and' HV-26038 since they are categori.ted B, passive?

10. How are valves RCS-001 and RCS-002 full-ctroke exercisad opcn during cold snutdown?

E. Reactor Buildino spre.y System

1. How are valves CBS'UO1, CBS-002, CES-005, and CBS-006 verified to full-stroke open quarteriy?

2. Provide a more datailed technical justification for not full-stroke exercising valves CBS-021, CBS-022, CBS-027, CBS-028, SFV-29015, and SFV-T.9016 quarterly.

3. How are valves C55-504 and 035-505 verified to ful't-stroke open quarterly?

F. HP and Auxi,liary Turbines System i 1. The cold shutdown justification for main turbine throttle valves l 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 accordancis with the Code.

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2. What is the safety-related function (s) of valves HV-20597, HV-20598, HV-32243, HV-35069, and HV-35070?

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

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

, full-stroke open cuarterly?

5. What is the safety-related function (s) of valves HV-20570 and HV-20571?

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?

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

8. Is the Rancho Seco nuclear steam supply system equipped with main steam isolation valves? If so, provide the P&ID(s) that shows these valves, i

G. Steam Generator System

1. Provide the P&l0 that shows valves FV-20531, FV20532, HV-20581, HV-20582, HV-20515, and HV-20516.

2. Review the safety-related fun: tion of valves FWS-013 and FWS-014 (PalD M-532, sheet 1, locations D-12 and H-12) to determine if they should be included in the IST program and tested to the Code requirements.

H. High Pressure Feedwater Heater System 1 1. How are valves FWS-047 and FWS-048 verified to full-stroke open quarterly?

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I. Condenser System l

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

• J. Nuclear Service Cooling Water System

1. Should valves PSV-50013, FSV-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?

II, pVMP TESTING PROGRAM

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

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).

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.

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

5. What is the frequency of testing the dual drive auxiliary <

1 feedwater pump when it is operating in the turbine-drive mode (refer to Relief Request No. PR-9)?

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

.flowrate?

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

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

PR-11).

8. When will instrumentation that meets the Code requirements be 1 installed for measuring boric acid pump flowrate?

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