ML20149M893

From kanterella
Jump to navigation Jump to search
Forwards Responses to NRC 870708 Request for Addl Info Re Development of Inservice Testing Program.Responses Finalized Following 871027 & 28 Onsite Meetings W/Nrc Reviewers. Revised Second Interval Program to Be Submitted in 2 Wks
ML20149M893
Person / Time
Site: Beaver Valley
Issue date: 02/19/1988
From: Sieber J
DUQUESNE LIGHT CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8802290220
Download: ML20149M893 (22)


Text

-

i f

  • 4,,

7fA ouquesne uct 1._. -

c nowamo

[ p, % ,px ,3o77eco4 February 19, 1988

{

~

U. S. Nuclear Regulatory Commission 1 Attn: Document Control Desk Washington, DC 20555 y -

Reference:

Beaver Valley Power Station, Unit No. 1 L

~

Docket No. 50-334, License No. DPR-66 Response to RAI on Innervice Testing n -

=

Gentlemen:

(

This submittal contains our responses to the NRC's request for additional information dated July 8, 1987, on the development of the

[ Beaver Valley Unit No. 1 Inservice Test (IST) Program.

F o- These responses were finalized following an on-site meeting on

$ October 27 and 28, 1987 with the NRC reviewers. The comments and

=

concerns from those meetings have been incorporated into a new

$ revision of the second interval IST program. We expect to submit the re"',cd second interval program within two weeks.

r  : If you have any questions regarding this submittal, please E contact me or members of my staff.

Very truly yours, k = ..

hr

( bD.>Sieber W]

" Vice President, Nuclear F

r Attachment

= +

=

cc: Mr. J. Beall, Sr. Resident Inspector

Mr. W. T. Russell, NRC Region I Administrator Mr. P. Tam, Project Manager

"  : Director, Safety Evaluation & Control (VEPCO)

E r

f0 20 800219 hak2fj{CK05000334 l l P j PDR (

" E m

A'ITACHMEhT BVPS Unit 1 Response to NRC Request for Additional Information on IST Program Submittal i

l I. VALVE TEST PROGRAM A. General Questions and Comments Question 1: Provide a list of all valves that are Appendix J, type C, leax rate tested but not included in the IST program and categorized A or A/C.

Response 1: Every valve that is Appendix J, Type C, leak rate tested is  ;

included in the IST program as a category A or A/C valve.

Those valves further classified as passive are listed below.

The category A - passive valves. are: j

1) RC-277 7) CV-36 13) PC-38 .
2) RC-278 8) CV-151 14) SA 14 i
3) RH-14 9) CV-151-1 15) IA-90 i
4) RH-15 10) PC-9 16) MOV-SI-890A
5) RH-16 11) PC-10 17) MOV-SI-890B
6) CV-35 12) PC-37 18) TV-CC-110F1 g The category A/C - passive valves are:
1) SI-41 4) IA 91
2) SI-42 5) SI-13
3) SA-15 6) SI-14  !

Question 2: Provide the limiting values of full-stroke time for all power operated valves in the IST program for our review.

Response 2: A table of limiting values of full-stroke times for all power-operated valves in the IST program was provided at the 10/27-28 NRC IST Program Review Meeting.  ;

Question 3: Provide a list of the valves in the Beaver Valley Unit 1 IST t program that have fail-safe actuators but are not tested in ,

accordance with IW-3415 to verify proper fail-safe  !

operation.

Response 3: All valves at Beaver Valley Unit 1 in the IST program with (

, fail-safe actuators are tested in accordance with IW-3415.

For example, placing the control switch on air-operated TVs [

i to the closed position for normally open valves de-energizes the control power as required by IW 3415. This in turn allows air to vent off the valve actuator positioning the  ;

value in its fail-safe position.

t 1- l

Question 4: The NRC has . concluded that the applicable leak test pro;edures and requirements for containment isolation valves-are determined by 10CFR50 Appendix J, however, the licensee '

must comply with the Analysis of Leakage Rates and Corrective Action Requirements paragraphs of Section XI, IWV-3426 and 3427.

Response 4: BVPS will comply with ASME XI paragraphs IWV-3426 and IWV-3427 except where the configuration of the penetration is '

such that individual leakage rates for each valve cannot be determined using the test method of 10CFR50, Appendix J.

BVPS has identified seven penetrations where individual valve leakage rates cannot be determined. Relief Requests have been written and included 11.0o the latest revision of the IST O program. For the alternate test, BVPS is proposing that a maximum permissable leakage rate be assigned for the whole penetration. Corrective action will be taken in accordance with IWV-3427 based on the penetration leak rate.

Question 5: Page 1, paragraph 4, of the Beaver Valley Unit i valve I testing program appears to request relief from the [

requirement of the Code "subarticle IWV-3410.c.3"; this -

requirement is included in the ASME Boiler and Pressure Vessel Code.Section XI, 1983 Edition through summer 1983 addenda, as IWV-3417(a). A general relief from Code requirements cannot be granted for as yet unspecified valvss.

If a problem does arise with testing any particular v alves ., '

then a specific request for relief providing the detailed technical justification should be submitted for'those valves.

Response 5: The paragraph being referred to ir.volves a general relief request from the stroke time acceptance criteria for t solenoid-controlled, air-operated valves. This paragraph has '

been deleted from Issue 2 Revision 2 to the IST program.

The requirements of IWV-3417(a) will be followed for these valves, ,

Question 6: Solenoid operated valves are not egempted from the stroke time measurement requirements of Section XI. Their stroke i 4 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 ,

Saction 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 2 seconds to ,

these valves and perform corrective action as required by  :

IWV-3417(5) if the measured stroke times exceed the 2 second '

limit.

Response 6: BVPS Unit 1 is planning on trending the stroke times of the 22 SOVs included in the IST program. No relief request is planned.

I i  !

t

)

L .,

Question 7: Why is the proposed alternate test frequency different for relief requests RR8, RR10, and RR27 when it appears that the plant conditions should be the same for testing all of these valves?

Response 7: The alternate test frequency for the valves included in these ,

RRs will be both cold shutdowns and refueling outages. For the valves included in RR 8 and RR 10, cold shutdown testing will be limited to when RCS pressure has been reduced to f under 100 psig since isolating seal injection at higher  !

pressures could result in seal damage. For the vs1ves included in RR 27, cold shutdown testing will be limited to when the RCPs have been shutdown since a loss of cooling water with a pump running could result in equipment damage to the pump and/or mator. The RRs have been revised to clarify the test frequencies which have been proposed.

B. Reactor Coolant System Question 1: Reevaluate the function of valves 1RC68 and 72 to determine if they should be identified as active valves and exercised to the Code requirements, t

Response 1: Check valves RC-68 and RC-72 have been reclassified as active valves. Relief from quarterly stroke testing has been ,

requested in revised versions of RR 2 and RR 3. The basis  ;

for relief is that the safety position for these valves is closed for containment isolation and the only method for -

verifying the valves closed is by a leak test. The refueling frequency is consistent with ASME paragraph IVV 3422 for leak tests.

Question 2: Provide a detailed technical justification for not full-stroke exercising valves IRC455C, 455D, and 456, j quarterly during plant operation.

Response 2: Technical justification has been provided in CSJ 2. The basis for not stroking quarterly is the potential of a PORY  !

sticking open at power when it is not needed for overpressure protection. PORVs PCV-RC-455C & D will be stroked every cold ,

shutdown, while PCV-RC-456 will be stroked at the normal cold  ;

shutdown frequency since it is not used for cold shutdown overpressure protection. ,

Question 3: What is the safety related function of valves IRC455A and B?

Response 3: Pzr. spray valves PCV-RC-455A & B have no safety-related function with respect to ASME Section XI. They will be deleted from the IST program, i

3

l l

Question 4: Provide a more detailed technical justification for not

. full-stroke exercising valves 1RC102A and B, 103A and B, 104, and 105, quarterly during plant operation (see valve relief request RRI).

Response 4: These valves are closed during normal plant operation and are designed to vent the RCS in an emergency to assure that core cooling during natural circulation will not be inhibited by a buildup of noncondensible gases. Petiudic stroking of these valves at power could degrade this system by repeatedly challenging the downstream valves due to a phenomenon known as "burping". This phenomenon has been previously described-in ASME report "Spurious Opening of Hydraulic Assisted, Pilot-Operated Valves - An Investigation of the Phenomenon".

The phenomenon involves a rapid pressure surge buildup at the valve inlet caused by opening the upstream valve in a series double isolation arrangement or closing a valve in a parallel redundant flow path isolation arrangement. The pressure surge is sufficient enough to lift the valve plug until a corresponding pressure increase in a control chamber above the pilot and disc can create enough downward differential pressure to close the valve. RR 1 has been rewritten as a CSJ. The valves will be stroked at cold shutdowns.

C. Chemical and Volume Control System Question 1: Provide a more detailed technical justification for not full-stroke exercising valves ICH22, 23, and 24, during cold shutdowns (see valve relief request RR2).

Response 1: RR 2 has been rewritten as RR 4 with additional technical justification added for not full-stroke exercising the charging pump discharge checks during cold shutdowns. The justification as stated in the relief request involves t' c potential for a low temperature overpressurization of the RCS that a full flow test could cause. Because of a similar concern, T.S. 3.5.4.1.2 requires that the BIT be isolated with the RCS temperature below 275'F. Additionally, passing design flow through these valves at cold shutdown would result in exceeding the design flow of the regenerative heat exchanger.

Question 2: How is valve ICH32 verified to close quarterly during plant operation?

Response 2: Regenerative heat exchanger downstream cheer. valve, CH-32, has no safety-relattd function with respect to ASME Section XI. A closure test has never been performed on this valve.

CH-31, which is the upstream CIV, is leak tested every refueling outage. CH-32 will be deleted from the IST program.

4

A Question 3: What is the safety related function of valve 1CH1377-Response 3: Excess Letdown H/X downstream isolation valve, MOV-CH-137, has no safety-related function. The valve has been deleted from the program.

Question 4: Provide a more detailed technical justification for not full-stroke exercising valve ICH141 quarterly during power operation (see valve relief request RR6).

Response 4: RR 6 has been rewritten as CSJ 5 since the proposed test for stroking the emergency boration non-return check valve, CH-141, is performed at cold shutdowns. The justification for not performing this test quarterly during power operation is that it would be necessary to initiate flow through the emergency boration path to stroke this- valve. Testing in this manner would cause an undesired reactivity transient through the direct injection of 7,000 ppm borated water to the suction of the charging pumps. The resultant over boration of the RCS could cause a plant shutdown. This justification should be sufficient to satisfy ASME XI, paragraph IWV-3412 which states in part that valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.

Question 5: Provide a more detailed technical justification for not full-stroke exercising valves CH181, 182, and 183 during cold shutdown (see valve relief request RR7).

Response 5: The refueling test frequency proposed for stroke testing the RCP seal injection inside containment check valves, CH-181, 184 6 183 is consistent with that specified in T.S.

4.6.3.1.2.e for spring loaded check valves. Also, the frequency proposed for the leak test, which is the only method available for closure verification is consistent with ASME paragraph IVV-3422.

Question 6: What are the consequences of failure of either valve ICH204 or 289 in the closed position during quarterly testing?

Response 6: The consequences of either valve CH-204 or 289 failing in the closed position during quarterly stroke testing would be the introduction of an undesirable transient in the reactor makeup or letdown system which could lead to a loss of pressurizer level control and require a plant shutdown. As a result, a CSJ has been included in the IST program for full-stroke exercising these valves during cold shutdowns.

5-

F~

\ l a,

Question 7: How is valve ICH222 verified to full-stroke quarterly?

Response 7: Auxiliary . Spray Check Valve, CH-222, is neither required to mitigate the consequences-of an accident or normally used to bring the plant to a cold shutdown. It has no safety-related function with respect to'ASME Section XI. It will be deleted from the IST program.

Question 8: Provide a more detailed technical justification for not full-stroke exercising valves ICH308A, B, and C during cold shutdown (see valve relief request RRS).

Response 8: As stated in RR 8, RCP seal injection outside containment isolation valves, MOV-CH-308A, 308B & 308C will be stroked during cold shutdowns but only after the RC pumps are shutdown and RCS pressure is reduced below 100 psig to prevent seal damage. It is not the intent to test these valves at only a refueling outage test frequency.

Question 9: What are the consequences of valve failure during quarterly full-stroke exercising of either valve ICH310, 460A, or 460B7 Response 9: The consequences of either MOV-CH-310 LCV-CH-460A or LCV-CH-460B failing closed would be the introduction of an undesirable transient in the reactor makeup or letdown system which could lead to a loss of pressurizer level control and require a plant shutdown. As a result, a CSJ has been included in the IST program for full-stroke exercising these valves during cold shutdowns.

Question 10: Reevaluate the function of valve ICH311 to determine if it should be identified as an active valve and exercised to the Code requirements.

Response 10: Aux. spray valve, MOV-CH-311, is not required to change position to mitigate the consequences of an accident or to bring the plant to a cold shutdown. It has no safety-related function with respect to ASME Sectin XI. It will be deleted from the IST program.

Question 11: Provide a more detailed technical justification for not full-stroke exercising valve ICH350 during cold shutdown (see valve relief request RR9).

Response 11: RR 9 has been withdrawn. Emergency boration path isolation valve, MOV-CH-350 is stroked weekly by OST 1.11.10 and at cold shutdown per OST 1.1.10.

6-

=..

Question 12: Provide a detailed technical justifiestion for not full-stroke exercising valve 1CH370 quarterly during plant operation.

Response 12: Charging supply header isolation to RCS seal injection valve, MOV-CH-370, is normally open at power. Closing the valve at power would secure seal injection water to the RCP seals which could result in seal damage. A new Relief Request has been included in the IST program for stroking this valve during cold shutdowns but only after the RC pumps have been secured and RCS pressure- has been reduced below 100 psig. ,

Under these conditions, damage to the pump. seals is not a concern.

Question 13: Review the safety related function of valve 1CH373-(fig. 7-1, coordinates D-7) to determine if it should be included in the IST program and tested to the Code requirements.

Response 13: CH Pump dischargo to VCT miniflow valve, MOV-CH-373, will be included in the program. Quarterly stroke testing is considered impractical; however, due to the potential for damaging the CH pumps if the valve would fail closed.

Quarterly stroking at power would also cause undesirable charging and letdown flow perturbations; therfore, the valve will only be stroked during cold shutdowns. A CSJ has been t added to the program.

D. Residual Heat Removal System l-Question 1: What testing is performed on valves 1RH605 and 7587 Response 1: These valves perform no safety function with respect to ASME Section XI. Both valves are used only to control RCS temperature when the Unit is shutdown. ASME Section XI, l paragraph IVV-1200 exempts those valves used for system l control. Both MOVs will be deleted from the IST program.

Question 2: Provide a more datailed technical justification for not i full-stroke exercising valves 1RH700, 701, 720A, and 720B during cold shutdown (see valve relief request RR11).

Response 2: RR 11 was withdrawn and rewritten as a CSJ. RHR inlet and i outlet isolation valves, MOV-RH-700, 701, 720A & 720B will be stroked and timed at the normal cold shutdown frequency per OST 1.10.1 when the RHR pumps are tested, t

e

}

~1

t Question 3: . Review the safety related function of valves 1RH3 and 4 (fig.

10 1, coordinates E 2 and E-3) to determine if they should be included in the IST program and tested to the Code requirements.

Response 3: RHR pump discharge checks RH-3 & 4 have been included in the latest revision of the IST program. Per CSJ 9 the valves will be exorcised during cold shutdowns per OST 1.10.1. when the RHR pumps are tested. (Both valves and pumps are located inside the containment.)

E. Safety Injection System Question 1: Provide a more detailed technical justification for not full-stroke exercising valves ISI1 and 2 during cold shutdowns (see valve relief request RR12).

Response 1: The basis for RR 12 is the impracticality of simulating actual SI long-term cooling in order to stroke the containment sump to SI pump checks, SI-1 6 2, during cold shutdowns. This refers to the fact that a temporary dike must be constructed around the containment sump prior to testing any pump taking suction from the sump to ensure l adequate NPSH. Presently the valves are inspected by_the {

Maintenance Dept per CMP 1-75-86. i Question 2: Provide a more detailed technical justification for not full-stroke exercising valve ISIS during cold shutdowns (see valve relief request RR 13).

Response 2: The RR has been rewritten to include additional justification for not exercising RVST to LHSI pump supply check, SI-5 during cold shutdowns. The RR adds that the valve cannot be full-stroke exercised during power operations or cold shutdowns since the only full flow path is into the RCS for which insufficient expansion volume exists to accept the required flow except during refueling outages. More specifically at a design flon "ate of 3,000 gpm for the LHSI pumps it would take only two minutes to fill the Pressurizer i starting from a no-load level of 22*. The proposed alternate tests will partial-stroke the valve quarterly and full-stroke exercise the valve during each refueling outage.

Question 3: Provide a more detailed technical justification for not full-stroke exercising valves ISI6 and 7 during cold shutdowns (see valve relief request RR14). What alternate test method is proposed for these valves?

Response 3: RR 14 was rewritten to include the same justi'ication for not full-stroke exercising LHSI pump discharge checks, SI 6 & 7, that was added to the RR for SI-5. These valves are part-stroked open and reverse flow checked quarterly per OST 1.11.1 and 1.11.2. Per OST 1.11.14, the valves are full-stroked at refuelings.

.g.

l l

. - _ _ _ _ _ _ _ _ _ _ _ __.I

p Question 4: Pravide a more detailed technical justification for not full-stroke exercisang valve 1SI27 during cold shutdowns (see valve relief request RR17).

Response 4: RR 17 was rewritten to include additional justification for not full-stroke exercising RWST to HHSI Pump suction check, SI-27, during cold shutdowns. The new RR is based on the possibility of low temperature overpressurization of the RCS that a full-flow test could cause during cold shutdowns. As an alternate test, Unit I has proposed quarterly part-stroking per OST 1.7.4, 1.7.5 & 1.7.6 and full-stroke exercising per OST 1.11.14 at refueling.

Question 5: Provide a more detailed technical justification for full-stroke exere!. sing valves ISIS 67C and D quarterly (see valve relief reqtost RR22).

Response 5: RR 22 was rewritten to include additional technical justification for not performing a quarterly stroke test.

The concern in stroking open either MOV-SI-867C or 867D at power involves the possibility of rendering the BIT flow path inoperable by boron coming out of solution, solidifying and blocking the injection line due to boron migration downstream of the MOVs Linto non heat-traced piping. This is not a concern during refueling outage testing since the non beat-traced portion of the BIT flow path can be flushed by the HPSI pumps and flow verified through the injection line prict to plant start-up in conjunction with the SI full flow test.

Question 6: Provide a more detailed technical justification for not full-stroke exercising valves IS890A and B quarterly (see valve relief request RR24). During which accident scenario, if any, are valves ISI890A and B every required to change position?

Response 6: RR 24 was rewritten as a CSJ because of the alternate test frequency proposed; however, upon further investigation into the function of these valves it was determined that LHSI to RCS hot leg containment isolation valves, MOV-SI-890A & 890B, are not required to change position during design basis accidents. The proper classification of these valves should be as passive Category A valves. Stroking of passive valves is not required.

-9 L- __ _ _.

Question 7.a: Provide a more detailed technical justification for not full-or partial-stroka exercising the following valves quarterly and during cold shutdowns (see valve relief request RR15).

IS!10 ISI11 1S112 ISI15 1S116 ISI17 ISI20 ISI21 ISI22 IS123 1S124 ISI25 1S1100 ISIl01 ISIl02 Response 7.a: RR 15 has been rewritten as three separate Relief Ecquests.

These reliefs include the same justification for not full-stroke exercising these SI check valves that was added to the RR for SI 5. More specifically, they add that insufficient expansion volume is available in the RCS to receive the additional water inventory from a LHSI pump full flow test during cold shutdowns.

Question 7.b: How are valves 1SIl0, 11, 12 15, 16, and 17 individually verified to full-stroke during refueling outage testing?

Response 7.b: LHSI to RCS cold and hot leg check valves SI-10, 11, 12, 15, 16 & 17 are stroked via OST 1.11.14 which verifies total flow through all 3 cold leg valves and all 3 hot leg valves. Leak tests OST 1.11.16 & 1.11.19, provide additional information regarding the integrity of the individual valves. A method will be developed for individually verifying the forward stroke for these valves.

Question 8: Provide a more detailed technical justification for not full-stroke exercising valves ISI13, 14, 83, and 84 during cold shutdowns (see valve relief request RR16).

Response 8: LHSI to RCS hot leg containmer.t isclation check valves, SI-13

& 14, have no safety function in the open position since the LHSI to RCS hot leg injection lines are not utilized in any analyzed accident condition. They do continue to have a safety function in the closed position since they act as CIVs. Therefore, the RR previously submitted for these valves has been revised to exclude them. SI-13 & 14 have been reclassified as category A/C passive in the IST program.

Full-stroke exercising to the open position for HHSI to RCS hot leg containment isolation check valves, SI-83 & 84, will still be required. Cold shutdown testing cannot be performed; however, due to the potential for a low temperature overpressurization of the RCS, Part-stroke testing at power was also ruled out due to the potential for a premature failure of the injection nozzles caused by the thermal shock from a cold water injection. SI-83 & 84 will continue to be tested at a refueling outage frequency.

,1-Question 9: How are valves 1SI48, 49, 50, 51, 52, and 53 verified to full-stroke during refueling outage testing? ,

Response 9: The method used dua'.ng the 5th refueling outage was to verify a flo. in excess of the minimum required to open the accumulator check valves while measuring the dP across the  ;

entire system. This was done by comparing the actual pressure vs. time curves from the accumulator blowdown with  :

calculated theoretical curves. A summary of this test method and the results obtained to date was presented at the IST Review Meeting held on 10/27 & 28.

Question 10: Provide a more detailed technical justification for not full-stroke exercising valves 1SI94 and 95 during cold shutdowns'(see valve relief request RR19).

Response 10: RR 19 was rewritten to include the same justification for not -

full-stroke exercising the BIT injection and RCS fill header inside CIVs, SI-94 & 95, during cold shvadowns that was added to the RR for SI-5. More specifically, it adds that insufficient expansion volume is avatlable in the RCS to receive the additional water inventory from a LHSI pump full flow test during cold shutdowns.  ;

F. Containment Depressurization System Question 1: Provide a more detailed technical justification for not full-stroke exercising valves 1QS3 and 4 and 1RS100 and 101 '

quarterly (see valve relief request RR26). How are thesa valves verified to full-stroke. L Response 1: QS and RS spray header inside containment isolation check valves QS-3 & 4 and RS-100 & 101, are all physically located l in the sub atmospheric containment building. The valves cannot be full stroked open with flow since any test t, at would require injecting water through the spray nozzles would ,

cause damage to elsctrical equipment and result in a significant contamination cleanup effort in the containment ,

building. These check valves will be futl-stroke exercised '

during cold shutdowns utilizing their weighted swing arms.

RR 26 will be resubmitted as a CSJ.

l' ,

l Question 2: What is the safety related function of valves 1RS145 and 1467 i Response 2: Outside RS pump seal water fill check valves, RS-145 & 146, ,

l have no safety-related function. They will be deleted from the IST program, i

?

i l

l l I i

G. Component Cooling Water System Question 1: What are the consequences of failure of either valve ICC130 or 132 in the closed position during quarterly full-stroke exercising?

Response 1: The failure of TV-CC-130 or TV-CC-132 in the closed position would cause the -loss- of cooling' water to either the non-regenerative or seal water H/X resulting in an undesirable temperature transient with the potential for damaging the demineralizers and; the RCP radial bearings.

Using this as a basis, quarterly testing at power is considered to be impractical. A CSJ has been written for testing only during cold shutdowns.

Question 2: What are the consequences of failure of either valve ICC111A,

  • 3, or C in the closed position during quarterly full-stroke exercising?

Response 2: CRDM shroud cooling coils inlet isolation valves, MOV-CC-111A, 111B & 111C, have no safety functions with respect to ASME Section XI. They will be deleted from the IST program.

Question 3: Provide a more detailed technical justification for not full-strone exercising valve ICC 10F1 quarterly (see valve relief request RR28).

Response 3: The normal system arrangement for containment air recirculation cooling RW return cucside CIV, TV-CC-110F1, is shut. Its normal position during a DBA is shut. RR 28 will be withdrawn and the valve will be reclassified as Category A, passive.

Additional Co,nment:

A CSJ is being prepared .tr the stroke testing of the other containment air recirculation cooling coil CIVs, TV-CC-110E2, TV-CC-110E3, TV-CC-110D & 110F2. The NSA for these valves is open. Thc failure of any one of these valves in the closed position would result in the loss of containment cooling and instrument air and would require a plant shutdown.

H. Main Steam System Question 1: Provide Figure No. RM137A for our review.

Response 1: A copy of Figure RM-137A was provideJ at the IST Program Review Meeting held on 10/27 & 28.

, o

.O ' '

- s 0 7 , ., ,

.I. .Feedwater System Question 1: . Review-7 t he safety-related- function ~of FCV-FW-102; 103A &'

?^ 103B, FW-619,- 620 6. 621 :.to determine if 'they..should' be gy ' included - i n --

1 requirements.

the IST' program and; tested to- the Code-Response 1: Prior to an accident,.the normal system arrangement _for these.

.2 < valves is closed. During anL' accident when. auxiliary Efeed-L ' flow :is -required, the' function of.these valvestis to remaini closed to maintain the steam generators 'as .a1 heat sink.

Later during ;the recovery period when the. demand for flow decreases, .the function ,of the- valves is' to.open . maintaining'.

a minimum recirculation flow path for. long-term- pump-protection. 'If the valves would fail. to open, ,the pumps could be shutdown. In the case'of the flow control. valves,. ,

they could be manually operated. .Also, ASME Section l<I ,

paragraph IWV-1206(a). excludes valves used in sytem control from the IST program. Therefore, BVPS does not- consider these. valves to be' safety related with respect to ASME Section XI and does not plan on including them in .the IST.

program.

J. Auxiliary Steam System Question 1: How _is valve AS-278 verified to full-stroke exercise during quarterly testing?

Response 1: Condenser air eje'ctor to containment check valve, AS-278, is verified when stroking TV-SV-100A and . watching for an e increase in containment pressure.

K. River Water System Question 1: If valves 1RW104A, B, C, and D, and 1RW105A, B, C, and D are required to be leak rate' tested as containment isolation valves, they should be categorized A.

4 Response 1: Per Technical Specification 3.6.3.1, these RW valves which ,

supply and return cooling water from the RS H/Xs are not required to be leak rate tested as containment isolation valves. That is why they have been listed as Category B valves. During an accident their normal position is open.

Question 2: How and at what frequency is reverse flow closure verified for valves 1RW106 and 107?

Response 2: RW header checks RW-106 & 107, at present are verified closed

, either by valve disassembly and inspection done in conjunction with the RW buried line hydrn or by a leak testing method. The frequency of testing for each valve is every other refueling as committed to in our response to NRC

'IE Bulletin 83-03.

c.

u; :

Question.3: . Review 7.the.1 safety related ' function:of valves-1RW133, 134, 135,'and 136 (fig. '30-1, coordinates A-8 and B-10) to determine if they should be included in the ISTLprogram and-

-tested to the Code requirements.

~

Response 3: :RW- 133,' 134, 135l & 136 are RW supply checks to.the Unit.1.

l Control. Room air. conditioner'candensers and redundant cooling.

coils. Based on FSAR Section 9.13.7., which s ates-that the I redundant cooling coils are'a-fully capable backup to the' air l conditioning units,.only cheG. valves RW-135 and RW-136'will-be added to the IST program.

Question 4: If' valves 1RW101A 'and B and 1RV107B and C (TGV's) (fig. 30-1, coordinates A-8, B-8, B-5, and:C-5) have required ~ fail-safe positions,- they should be. included in-the IST program and tested to the Code requirements.

Response 4: DCP' .311 deleted TGV-RW-107B & 107C. The. addition- ofL TCV-RW-101A & 101B is not necessary with the addition of. the RW supply check valves to the Control Room redundant cooling coils.

Question 5:

~

Review the safety related function of valves 1RW158 and 159 (fig. 30-1, coordinates B-6 and C-6) to determine if they ,

should Lbe-included in the IST program and tested to the code requirements.

_ Response 5: After reviewing e safety-related function of the charging pump A & B header cooler supply check valves, RW-158 &. 159, these valves will be added to the IST program as category C check valves. They will be exercised open quarterly. in conjunction with the charging pump surveillance tests.

Question 6: How are_ valves 1RW486, 487, and 488 verified to full-stroke open?

Response 6: The' normal position for RW pump vacuum break check valves, RW-486, 487 & 488 'is , closed. 'The valves .only- open temporarily after pump shutdown. This is verified via their present monthly pump surveillance tests. The mathods used involve monitoring pump discharge pressure and listening for air flow at the opening upstream of the valve.

i 0

tJ _ <*

. Question'7: Review the safety related functionLof valves 1RW95, 96,.97, ~

and;676.'(fig.;30-2,' coordinates F-1, F-2, F-3,_ and .F-2) to determinet if they should be included in the IST program and '

tested to the Code requirements.

Response-7:  : After reviewing the safety-related function of the seal water to RW.pumpccheck valves, RW-95,:96, 97, 675, 676 6 677, these

~

valves will be added to the IST program. The only, method for-testing cRW-675, 676 6 677. however. involves putting unfiltered RW . through . -the . ssals , which is damaging to the ~

seals. To: minimize degiadation of.the pump seals and reduce-maintenance, a - RR has been prepared for an' exemption.from quarterly stroke testing. As an alternative,.BVPS Unit 1 is proposing that testing be performed only.during refueling outages.

L. Compressed Air System Question 1: Provide the Figure (s) for this system for our review, Response 1: Copies were provided at the IST Progrr.m Review Meeting held on 10/27 & 28.

Question 2: What testing is performed for valve 1SA147 h Response 2: Station air outside CIV, SA-14, has been classified as a Category A - passive valve. For this classification only leak testing is required. A RR has been submitted'to use the Type C leak test as the alternate test method.

M. D/G System Question 1: Provide the Figure (s) that shows the diesel generator air start solenoid valves for our review.

. Response 1: A copy of Figure R!!-151A was provided at the IST Program Review Meeting held on '9/27 & 28.

N. Control Air Vent System i Question 1: Provide Figure No. RB2B for our review.

Response 1: A copy of Figure RB-2B was provided at the IST Program Review Meeting held on 10/27 & 28.

O. Post DBA H2 Control System I

Question 1: At what frequency are valves 1HY101, 102, 103, 104, 110, 111, 196, and 197 full-stroke exercised?

Response 1: These vaives will be categorized as A, active in the IST program and exercised quarterly in accordance with ASME Section XI.

_ _ _ _ = _ _ _ _ _ _ _ _ _ - _ _ -

Question 2: Provide the Figure that shows valves 1HY196 and 197.

Response 2: A copy of Figure RM-150B was provided at the IST Program Review Meeting held on 10/27 & 28.

P. Containment System Question 1: Provide Figure 47-5 for our review.

Response 1: A copy of 0.M. Figure 47-5 was provided at the IST Program Review Meeting held on 10/27 & 28.

t ll p; ,

,a, *;

II. PUMP TEST PROGRAM: ..

.A. -General Questions and Comments'

-Question.1: How is flow . measured' in the charging pump miniflow line?

.What is:the accuracy of quartarly flow measurements taken'for the charging pumps?.

Response-1: Flow is- assumed constant through .the.miniflow line. The actual flow was last measured by BVT 1;1.- 4.7.1 during the

. pre-operational test program..back in 1975 by measuring the change in VCT level over time -with each : pump _ run 'on recirculation. The miniflow lines themselves are orificed.

No flow instrumentation is installed.

~ Question 2: The 1974 edition of the Code did not require the measurement of both pump differential pressure and flow to determine pumpL operability, however,-all subsequent editions of the Code do require the measurement of both of these variables. How does Beaver . Valley Unit 1 propose to measure the flowrate through-

.the following pumps (see pump relief request.no. RR4)?

CH-P-2A -RH-P-1A QS-P-1A FC-P-1A CH-P-2B RH-P-1B QS-P-1B FC-P-1B FW-P-2 FW-P-3B- VS-P-3B FW-P-3A VS-P-3A Response 2: Tne flowrate for QS-P-1A & IB will be measured quarterly-using the installed instrumentation in the recirculation line. The flow rate -for RH-P-1A & IB will be measured at cold shutdowns when'the pumps are tested. The flow rates for CH-P-2A & 2B' and FW-P-2, 3A & 3B will be measured during refueling outages. Quarterly pump tests will also be performed ~ comparing pump delta P to a reference value.

FC-P-1A & 1B and VS-P-3A & 3B are not considered

. safety-related; therefore, these pumps have been deleted from the IST Program.

f c .

L'

[' '3; V ,.

Ln; e f -Question-3: Section.XI, paragraph'IWV-31'10Irequires thatfreference values; be established at points .of reference readily ~ duplicated during subsequent inservice testing. A . family af such values

. may be utilized for a pump ifLit is' difficult to return to ~a certain1 value ~during inservice testing. How are the~ pump curves derived for the following pumps. (see pump' relief request no. RR2)?

CH-P-1A CC-P-1A WR-P-1A CH-P-1B CC-P-1B WR-P-1B CH-P-1C ~ CC-P-1C WR-P-1C

' The pump curves for CH-P-1A,.1B & IC have'been supplied by-

~

Response 3:

the manufacturer of the pumps. Plant procedure BVT 1.2 -

2.15.1 ootains points.for CC-P-1A,.1B &'1C pump curves by

~

throttling the corresponding discharge valve. Pump curves for WR-P-1A, 1B & IC have been derived from~BVPS procedures BVT 1.2 .2.30.1, 2 & 3 respectively.

. Question 4: What. is the combined accuracy of the flow instrumentation utilized to calculate flow rate for the safety injection

_ pumps, SI-P-1A and B7.

Response 4: The flow rate for the LHSI pumps is measured locally by a dp cell mounted 'across an orifice plate in . the common!

recirculation line. The instrument mark number is FI-SI-941.

The instrument has an accuracy of i .5%,

Question 5: What is the combined accuracy of the' flow instrumentation -

utilized to calculate flow rate for the quench spray pumps, QS-P-1A and.B?

Response 5: The flow rate for the QS pumps is measured by two dp cells in parallel flow paths back to the RWST. The instruments, FI-QS-103 and FI-QS-104, each have an accuracy of i .5%.

Question 6: How can pump degradation be monitored for the containment depressurization chemical injection pumps, QS-P-4A, B, C, and D, utilizing only the measurement of pump flow rate and not differential pressure (see pump relief request RR5)?

Response 6: For positive displacement pumps, pump differential pressure can vary significantly independent of flow. The Chemical Injection Pumps, QS-P-4A, B, C & D, are tested through a fixed resistance recirculation line; therefore, changes in flow should indicate degradation.

P5 y > ,

H>- c.. 1

^^

r -

' Question.7: Provide; a more detailed technical justification for not- i performing- pump testing  ; quarterly for the inside' 1 recirculation spray pumps, RS-P-1A and 1B,,in eccordance with.

the Code requirements (see pump relief request RR6)'.

~

Response 7: .In order to : test the- Inside1 Recirculation Spray Pumps, RS-P-1A & IB, a' temporary. dike ;must .be installed in the containment around the. safeguards sump to ensure adequate NPSH. Installing this dike at power for . quarterly testing would be extremely impracticalLand also a safety concern since it would effectively.. block off the sump._from' the containment in the event of an accident. It.also would require multiple containment entries under a vacuum. which goes against the. practice of keeping radiation exposure ALARA . Pump testing during cold shutdowns, while not involving the -same safety concern, would increase personnel radiation exposure, create over 2,000 gallons of additional radioactive waste, divert maintenance from higher priority items and could extend the length of a plant shutdown due- to the extensive preparatory work required to properly install the dike, Question 8: Provide = a more detailed technical justification for not performing pump testing quarterly for the outside recirculation spray pumps, RS-P-2A and 2B, in accordance with the Code requirements (see pump relief request RR7).

Response 8: The pumps are designed with a recirculation flow path for testing; however, the piping arrangement and required valve lineup for post-test system restoration prevents draining the pump casing and suction lines without returning some water to the containment safeguards sump. As a result, a containment entry would be required to pump out the sump. Performing this test also creates additional radioactive waste and increases personnel radiation exposure. Frequent testing could also increase the maintenance required on the pump suction and discharge MOVs which must be cycled closed placing a differential pressure across these valves not normally seen under either normal or accident conditions.

Question 9: The NRC Staff agrees that pump vibration monitoring utilizing pump vibration velocity rather than vibration displacement can provide more useful information for evaluation of pump degradation. The acceptance criteria as defined in ASME OM-6, draft 8, "An American National Standard In-Service Testing of Pumps" provides one acceptance criteria for vibration velocity testing which is acceptable to the staff.

Please provide a copy of "ASME technical paper 78-WA/NE-5" for our review (see pump relief requests RR13 and RR15).

Response 9: These reliefs have been rewritten to use the criteria defined in ASME OM-6 for vibration measurements.

m o

Question 10: How is flow individually measured for each river water pump, WR-P-1A, B, und C7 Response 10: Flow is individually measured for each river water pump using FI-RW-102A for pumps run through the "A" RW header and FI-RW-102B for pumps run through the "B" RW header.

~

Question 11: Explain the method used to determine the flow rate of the diesel fuel oil transfer pumps, EE-P-1A, 1B, 1C, and 1D.

What is the accuracy of this measurement (see pump relief request RR14)?

Response 11: The flow rate of the diesel fuel oil transfer pumps is determined by dividing the indicated change in day tank level using the tank sight glass by the time measured between readings (generally 15 minutes). This method meets the accuracy requirements of ASME Section XI.

Question ?2: Provide a more detailed technical justification for not measuring the suction and differential pressure for the diesel fuel oil transfer pumps, EE-P-1A, 1B, 1C, and ID, in accordance with the Code requirements (see pump relief request RR11).

Response 12: As stated in the response to Question 6, pump differential pressure for positive displacement pumps can vary significantly independent of flow. Changes in flow from some reference value should be sufficient to detect pump degradation for the diesel fuel oil transfer pumps.

Discharge pressure is also trended as a further indication of pump performance.

Question 13: Provide a more detailed technical justification for not testing the residual heat removal system pumps, RH-P-1A and IB, quarterly as required by the Code (see pump relief request RR8).

Response 13: The RHR pumps are not required to be operable at power by technical specifications. Also, the RHR system is not an ESF system and the pumps are not required to mitigate the consequences of a DBA. To run these pumps quarterly would also require making a containment entry at power. A CSJ has been prepared for pump testing at a cold shutdown frequency.

Question 14: What safety related function, if any, do the raw water pumps, WR-P-6A and 6B, perform?

Response 14: The raw water pumps have no safety-related function. They only provide cooling water for the turbine plant.

L

g.- -

z o

~

Question 15: IWP-4400 states that. rotative shaft speed need not be measured for pumps directly coupled to motor drives of either the synchronous or the induction type. Therefore, relief from the Code requirement need not be requested for pumps meeting these conditions (see pump relief request RR1).

Response 15: The RR for not measuring pump shaft speed has been deleted.

Question 16: Observation of lubricant level or pressure applies.only to those pumps that have a lubrication system with level or pressure indication (see pump relief request RR9).

Response 16: The RR for not observing lubricant level or pressure has been deleted.

l l

l