ML20154B086

Summary of 871014-15 Meeting W/Util in King of Prussia,Pa Re Remaining Needs Associated W/Nrc Review of Util Inservice Testing Program for Pumps & Valves.Related Documents Encl

ML20154B086
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/09/1988
From:	Rooney V Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8805170060
Download: ML20154B086 (88)

Text

, -

4

't May 9,1988 i

Docket No.: 50-271 LICENSEE: Vermont Yankee Nuclear Power Corporation (VYNPC)

FACILITY: Vermont Yankee Nuclear Power Station

SUBJECT:

MEETING

SUMMARY

On October 14 and 15, 1987, the NRC staff met at the NRC Region I office in King of Prussia with representatives of VYNPC to discuss remaining informational needs associated with the staff's review of VYNPC's Inservice Testing (IST) program for pumps and valves. On October 28 and December 22, 1987 the staff also discussed by telephone with VYNPC representatives follow on items resulting from the meeting. Meeting minutes which include an attendance roster are enclosed.

The licensee has agreed in telephone discussion with the Project Manager to revise the IST program, based on these meeting minutes, and resubmit the revised program as soon as possible but no later than August 1, 1988.

Sincerely, Original signed by:

Vernon L. Rooney, Senior Project Manager Project Directorate I-3 Division of Reactor Projects I/II

Enclosures:

As stated cc: See next page DISTRIBUTION: Docket File, NRC & Loca PDRs, PDI-3 r/f, VRooney, RWessman, OGC, EJordan,tJPartlo'w, DCaphton, PEapen, LPrividy, JDurr, ACRS (10), HBClayton OFC :PDI-3 @ DIR/P  :  :  :  :  :

NAME :VRoo ey:mw :RWessm  :  :  :  :  :

DATE :04/ef/88 :04/c;' /88  :  :  :  :  :

i 0FFICIAL RECORD COPY 8805170060 880509 PDR ADOCK 05000271 p PDR

e Mr. R. W. Capstick Yemont Yankee Nuclear Power Corporation Vermont Yankee Nuclear Power Station cc:

Mr. J. Gary Weigand W. P. Murphy, Vice President President & Chief Executive Officer and Manager of Operations Vermont Yankee Nuclear Power Corp. Vermont Yankee Nuclear Power Corp.

R.D. 5, Box 169 R.D. 5, Box 169 Ferry Road Ferry Road Brattleboro, Vermont 05301 Brattleboro, Vermont 05301 Mr. John DeVincentis, Vice President Mr. Gerald Tarrant, Comissioner Yankee Atomic Electric Company Vermont Department of Public Service 1671 Worcester Poad 120 State Street Framingham, Massachusetts 01701 Montpelier, Vermont 05602 New England Coalition on Nuclear Public Service Board Pollution State of Vemont Hill and Dale Farm 120 State Street R.D. 2, Box 223 Montpelier, Vermont 05602 Putney, Yemont 05346 Vermont Public Interest Research Group, Inc. Mr. Walter Zaluzny 43 State Street Chairman, Board of Selectman Montpelier, Vemont 05602 Post Office Box 116 Vernon, Vermont 05354 William Russell, Regional Administrator Raymond N. McCandless Region I Office Vemnnt Division of Occupational U.S. Nuclear Regulatory Commission and Radiological Health 475 Allendale Road Administration Building King of Prussia, Pennsylvania 19406 Montpelier, Vermont 05602

Mr. R. W. Caostick Honorable John J. Easton l Vermont Yankee Nuclear Attorney General Power Corporation State of Vemont l 1671 Worcester Road 109 State Street l Framingham, Massachusetts 01701 Montpelier, Vermont 05602 i

John A. Ritscher, Esquire Mark J. Wetterhahn, Esq.

! Ropes & Gray Conner & Wetterhahn, P.C.

I 225 Franklin Street Suite 1050 l Boston, Massachusetts 02110 1747 Pennsylvania Avenue, N.W.

l Washington, D.C. 20006 l

l l

C Vermont Yankee Nuclear Power Vermont Yankee Nuclear Power Station Corporation cc:

Ellyn R. Weiss, Esq. Resident Inspector Harmon & Weiss U.S. Nuclear Regulatory Comission 2001 S Street, N.W. P.O. Box 176 Washington, D.C. 20009 Vernon, Vermont 05354 David J. Mullett Esq. Carol S. Sneider, Esq.

Special Assistant Attorney General Assistant Attorney General Vennont Depart, of Public Service Office of the Attorney General 120 State Street One Ashburton Place, 19th Floor Montpelier, VT 05602 Boston, MA 02108 Jay Gutierrez Geoffrey M. Huntington, Esquire Regional Counsel Office of the Attorney General USNRC, Region I Environmental Protection Bureau 475 Allendale Road State House Annex King of Prussia, PA 19406 25 Capitol Street Concord, NH 03301-6397 G. Dana Bisbee, Esq. Charles Bechhoefer, Esq.

Office of the Attorney General Administrative Judge Environmental Protection Bureau Atomic Safety and Licensing Board State House Annex U.S. Nuclear Regulatory Comission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-6397 Dr. James H. Carpenter Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, DC 20555 Mr. Glenn O. Bright Adjudicatory File (2)

Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Docket U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, DC 20555 Washington, D.C. 20555

L O

fleeting Minutes Fron The NRC Staff's Inservice Test Program Review Meeting With Representatives of the Vermont Yankee Nuclear Power Corporation Conducted October 14 and 15, 1987 A working meeting was held at the NRC Region I office in King of Prussia, Pennsylvania with representatives of the Vermont Yankee Nuclear Power Corporation er October 14 and 15, 1987. The purpose of the meeting was to discuss the staff's Request for Additienal Information (RAI) questions resulting from the staff's review of the Vernont Yankee's pump and valve inservice testirg (IST) progran. The staff's RAI questions were sent to the licensee by letter V. L. Rooney to R. W. Capstick on January 5,1987. The staff's questiens served as the meeting agenda. Each of the staff's RAI questiens were discussed during the meeting.

The staff's RAI questions are indicated by the letter Q. before the cuestion.

The meeting minutes are given under "Comments". Pertinent licensee and staff coments, explanations, understandings and clarfications are discussed in the minutes. For the najority of the RAI questions the discussions provided the staff with the needed clarifications and infornation to allow the staff to ecmplete the review expeditiously pending receipt of a revised program subnittal from the licensee. Where the licensee egreed to take specific action, for exampic, to revise er make changes to their IST program, en LAR (Licensee Action Required) follows the meeting minutes "Comments". Where the staff's RAI ouestion was resolved during the meeting discussion an R (Resolved) follows the meeting minute "Come nt s " . Several items that will require additional work to obtain resolutior by either the licensee or staff nre listed as 01-L (0 pen Item - Licensee) or -S (0 pen Item - Staff). Those open items were discussed in a conference ca- between the licensee and staff on October 28, 1987 and actin on Decembt' 22, 1987. Both the staff and the licensee agreed to work for timely resolution of the remaining Open Items. The open items are tabuleted in the table that follows.

The purpose of these minutes are to document the results of the above

discussions.

The participants were:

D. L. Caphton, NRC, Region I V. L. Rooney, flRC, NRR Headquarters i P. K. Eapen, NRC, Region I I

L. J. Prividy, NRC, Region I J. P. Durr, NRC, Region I J. Pelleticr, Vermont Yankee D. Reid, Vermont Yankee G. Cappuccio, Yorrent Yankee K. H. Bronson, Verront Yankee T. C. Trask, Verment Yankee l

O At the conclusion of the meeting the staff requested that the Vermcnt Yankee IST program be revised to incorporate the reeded program revisiers within 60 days from receipt of the meeting minutes. The staff stated that the revised licensee's IST program submittel will be used to base the staff's final review and safety evaluation of the licensee's IST program.

OPEN ITEMS Valves VY IST Program Page Nurber Question Nutter Responsible V-7 Q.8 OI-L V-11 Q.2 OI-S and 01-L Y 14 Q.8 OI-L Y-16 Q.2 OI-L Y-17 & 18 Q.1.b. OI-L V-17 & 18 Q.3 01-5 and O!-L Y-17 & 18 Q.9 OI-S and 01-L V 21 Q.7 OI-L NOTE: There were no Open Items for pumps.

PUMPS

1. Service Water Purps P7-1A-D G191159 Sh 1 Q. The WP appears to be measurable, however, the program's pump testing does not indicate this. The listing should be revised.

Comments: LAR The licensee stated that the river water level provides the inlet pressure for these deep well centrifugal pumps. The licensee uses the inlet head and discharge pressure to arrive at the functional equivalent of IIP. The licensee will provide an appropriate discussion in his revised program regarding WP and flow measurerent.

2. High Pressure Coolant Injection Pumps G191169 Sh 2 HPCI Gland Seal Exhauster HPCI Hot Well Condensate Pump l

O

0. Discuss the safety related functions (shutting down the reactor or ir nitigating the consecuences of an accident) of these pumps. Provide a detailed technical justification for not including the pumps in the program.

Conments: R The licensee stated that the gland seal exhauster and hot well condensate purp are non-safety related and do not have a reactor shutdown or accident nitigation function, therefore, were not included in the program. The licensee stated that proper operation of these pumps are denenstrated by HPCI system cperation.

3. Standby Liquid Control Pumps Q. Is lubricant temperature measured in the pump crankcase or another location?

Comments: LAR No. The licensee stated that e generic relief request te delete bearing temperature measurement will be placed in the IST program.

4 Core Spray Pupps Paf-1A/B

0. During outage testing, is the length of time of the purp run adequate to reasonably assure that no problems are beine experienced as a result of bearing heating? Note-this corrent is applicable to the other pumps in the program that similarly have bearing temperatures that cannot be directly measurad.

Corraer.t s: R The licensee is requesting generic relief from measurement of Pump Bearing Tcrperatures. The licensee stated:

"This P,elief Request Basis is consistant with the requirements of ANSI /ASME Standard OM-6. "In-Service Testing of Pumps", Draft 11, which does not require bearing temperature measurements.

ALTERNATIVE TESTING:

Pump mechanical condition can be determined much more accurately by measuring bearing vibration. Paragraph IWP-4500 requires at least ore displacement vibration level be read during each in-service test. The number of readings will be expanded to a mininum of two in orthogonal directions. These additional readings, in addition to the revised vibration measurement nethods and acceptance criteria given in Relief Request Basis GP-3, will provide a viable means of nonitoring pump rechanical condition."

5. RCIC Condensate and Vacuum Pumps G191174 Sh. 2 Q. Discuss the safety related functions of these purps. Provide a detailed technical justification for not including these pumps in your progran.

Comments: R The licensec stated that "these punps are non-safety related and provide ne reactor shutdown or accident mitigation function. Therefore, they are r..c included in the program."

6. RECCW Punps G191159 Sh. 3 Q. The progran listing for the reference drawine shows sheet 1, the pumps are on sheet 3.

Comments: R The licensee will correct the reference.

7. Emergency Diesel Generator Auxiliaries G191162

a. O. The diesel engine's fuel pump and cican oil return pumps are missing from the proaram.

Comments: R The licensee stated that the purps are not required for the safety related operation of the diesel. The staff agreed.

b. Q. In relief Request Basis P-12, Fuel Oil Transfer Pump Bearing Temperature measurement ser IWP-3300, regarding alternate testing, is it possible to check searing temperetures by pumping to the 5000 gallon Fuel Oil Day Tank 41-1A fer the heating boilers?

Comments: LAR The licensee will delete this relief request and provide a generic relief request as discussed under 4. above.

8. Pump RRV-18 and G191175 Sh. 1 Two check valves 16-19-101 (E-15) and 16-19-103 Q. What are the safety related functions of the pump and two check valves?

r

w Ccaments: R The licensee stated that:

"Pump RRU-18 and check valves V16-19-101 and V16-19-103 are components of the Torus to Drywell Pumpback System. This system is no longer la use and has been retired in place.

The lorus to Drywell Pumpback Systen was originally installed to maintain the 1.7 psid between the torus and the drywell. This differential pressure along with proper torus water level assure the integrity of the torus when subjected to post-LOCA suppression pool hydrodynamic forces.

The drywell-torus differential pressure is new maintainec' by use nf the Nitrogen Ir.crting Supply System.

Valves V16-19-102, 103, 105, 106 and 109 are norna11y closed, the breaker for PRU-18 is open and the discharge piping downstream of valve V16-19-101 has been cut and capped."

9. Q. What is the technical justification for not including the Torus to Drywell pumpback system in the IST program? (No drawings provided).

Coments: R The licensec included his response to this cuestion with question 8.

above.

10. Q. Describe ary functions that the Dryvell Floor Drain pumps P-11 A/B and the DryW 11 Equipment Drain pumps F-15-A/B have in shutting down the reactor or mitigating the consequences of an accident.

Coments: R The licersee stated that these pumps are isolated during accident conditions and serve no safety function or accident mitigation functicr..

Valves V-4* Service Water System Dwg. G191159 Sh. 1&2

1. Yalve V 70-1A-D and Relief Request Basis RRB-Y1 (B, H-3)

a. Q. The relief request lacks specificity regarding frequency of exercise testing. The time period shculd be specified.

Reference IWV-3521. (Note: 24 renths is normally the maximum relief that the staff will consider.)

• The V-4 numbir is the page nurber in the licensee's IST progran.

.c.

General tiete applicable to all relief requests: Relief recuests should clearly specify what specific relief is being requested including the detailed technical basis for the specific relief being requested. Revise relief requests accordingly.

Comments: LAR The licensee stated that at least two tests will be conducted annually on each of the check valves with at least three months between tests. The relief request will be revised to include the basis for this testing frecuency.

b. O. Is there a leakage recuirement established fer these valves in the closed positier? Is prompt closure verified?

Coments: LAR The licensee stated that no specific valve leakage requirement is necessary to meet syster performance criteria.

The minimum systen performance requirement for each pump is 2700 gpm against a TDH of 250 feet (TS 4.5.D.1) This will be incorporated into the IST program.

Prerpt closure of each check valve will be verified by visual observation of systen pressure indicators ord by observing that the non-operating pump is not wind milling.

2. Relief valves in Service Water System Q. Provide detailed justification for not including the service water system's relief valvet in the IST pregram and testing in accordance with IWV-3510.

Cements: R

The licensee stated that the subject relief valves serve as thermal reliefs and as such these valves do not perform a specific function l in shutting down the reactor or in nitigating the consequences of an

! accident.

3. RHR Motor Cooling Q. What is the technical bases for not including: check valves 181 XC (4 total, one for each motor) and Solenoid valves SE-70-4C (4 Total)?

l i

i

Corrents: LAR The licensee stated that the above valves will be put into the progran for testing as follows:

Check valves 181 XC will be designated Category C.

Solenoid valves SE-70-4C will be designated Category B.

f The licensee will submit a relief request on timirp for the solenoid valves.

4. Valves V 70-84A and 84 B Reference G191159 Sh. 2) (B and h-3).

Q. Uhat is the safety related function of these velves?

Comments: R The licensee stated that these valves have no safety related function.

These valycs provide an alternate cooling path to the station air compressors. ,

5. Emergency Diesel Generator Cooling L. Check Valve 70-1 (B-9)

Q. This check valve is not in the program, however, the pesition of the valve appears to be of safety related importance to assure a heat sink for the emergency diesels and as such should be tested as a Categcry C valve. ,

Comments: R The licensee stated that the valve is a marcally operated butterfly va'n and is not required to be cperated to assure a heat sink for the EDGs.

b. Fill Valves On Expansion Tanks SE-70-2A7 (Drawing has no numbers) (F-8)

SE-70-2B (C-5)

Q. These valves are not in the program, however, appear to have safety importance to assure cooling of the EDGs. The valves should be included in the program and tested.

Conments: R The licensee stated that these valves do not perform a safety function therefore are not included in the program. The tanks are equipped for nanual makeup and have a level alarm to alert operators if a level problem occurs.

6. Q. Line 24" SW 1B (Dwg. G191159, SS. 1) appears to connect to 8" SW 1FE (Dwg. G151159, Sh. 2) at match line A, however, there is no reducer shown.

Is there a missing drawing? Also there is no 24" SW 1B in the "Piping Line List". ,

Also the 18" SW 12 line gees to 20" SW-12? Same question?

Comment: LAR The licensee stated that the subject service water drawings are flow diagrans and were not intended to show the detail pipirg configurations.

The first entry in the Dwg G191159, sheets 1 and 2 is being corrected to show SW-1A-D vice SW-1AAD, otherwise the drawings fulfill their intended purpose.

V-5 Reactor Building Closed Cooling Water

1. Relief Valves G191159 Sh.3(A-4)

RECCW HX's s SR 70-1A/B Q. Previde detailed technical justification for excluding these two relief valves from the program.

Comments: R The licensee stated that these yhlves are therral relief valves and therefore are not required for safe shutdown or accident mitigation.

E. Air Operated Velve (D-8)

LCV-1 Q. Does this valve operate to make up systen losses of inventory?

Does the valve fail open upon loss of air?

Comments: R The licensee stated that the valve does operate to make up system losses 6f inventory as an operations aid. It fails closed upon loss of air. The valvo is not required to shutdown the reactor or to mitigate the consequences of an accident. The tank is equipped with a low level alarm which annunciates in the control room thus allowing for manual makeup if needed, r

t i l

,il

.g.

(7 Y-7 Service and Insirurent Air, Diesel Generator Starting Air System, y Dwg. G-191150 Ref. Sh. 7 1

' 1. PressureReliefYk1ves(unnumbered)onEDGAirReceiverTanks, creon each tank, four total. (Ref. Sheet 7 of 7)

Q. Provide your detailed technical justification for not including

< these valves in the IST program and testing per IWV-3510.

i

, 7 Comments: R f The licensee stated that these relief valves are not required to cperate in shutting the reactor down or in mitigating the consttuerets of an accident.

2. p Check valve unnumbered in line frer air receiver to motor pressure aswitch, one for each air receiver. (Ref. Sheet 7 of 7).

Q. ."rovide your detailed technical justification for not including these valves in the IST program and testing per IWY-3510.

t Comments: R The licensee stated that these instrument line valves do not perform a function in shutting down the reactor or in mitigating the consequerees of an accident.

3. Pressure Pelief Valves (unnumbered) on air compres. rs, two total.

Q. Provided your detailed technical justification for not including these valves in the IST progran and testing per IllV-3510.

i Connents: R

/

i The licensee stated these valves do not perform a function in j

i shutting down the reactor or it, mitigating the consequences of an accident.

r 4 1 EDG Air Start Solenoid Valves (Colt Industries Dwg. 1185383)

Q. Provide your detailed technical justification for not including these alves in the IST progran and testing per IWV-3400.

Cv hents: ,' LAR The ' licensee stated that these valves will be added to the program as Category B talves and full stroke erercised quarterly during diesel generator surveillance testing. A new relief request will be generated since the valves are fast acting valves and difficulty exist in the measuring and trending of stroke times, t

5. Valve V72-78 A-D and V72-80 A-D Dwg. G191160 Sh. 7

0. Do these valves have to meet a leakage criteria to protect againtt the loss of receiver redundancy?

Comments: R The licensee has not recuired these check valves to meet a leakage criteria. The proper closure of the check valves is determined by their capability to maintain normal receiver pressure without excessive running of the compressor.

6. Relief Request Bases V5 Q. Revise to show compliance with requirerent of IUY-3423 regarding adjusting to functional maximum pressure differential value.

Ccmments: LAR The valvos are currently tested at accident pressure of 44.0 nsig.

The licensee stated that a generic relief request bases wi' provided in the program te satisfy compliance with IWY 3426 IWV-3427.

7. Instrunent Air Systera Ref. G191100 Sh. 4 Q. Whet is the safety function of check valves:

Check valve next to V 72-154 and unnumbered (L-6)

V 72-51A Y 72-155 (Check valve is next to and unnumbered)

V 72-86A V 72-86B

, V 72-51B V 72-49A Y 72-49B Y 72-67A V 7?-67B Comments: LAR The licensee stated that the unnumbered valves are V72-1540 and V72-1550. The drawing is being corrected to incorporate the numbers.

The licensee stated that none of the listed valves perform safety functions required to shutdo,m the reactor or mitigate the consecuences of an accident.

8. Relief Request Basis V6 Dwg.G191160 Dh. 3 (K-12 and 15) for Valves V72-89 B/C Q. Relief request as written does not show compliance with exercise testing frequency under IWV-3522. Revise to neet Section XI.

Note: The leak test requirenent Ref. RRB-Y5 needs to be revised to comply with IWV-3426 and IWV-3427, Analysis of Leakage Rates and Corrective Action, respectively.

Conments: LAR and CI-L The licensee stated that the subject valve closure will be verifiec during Appendix J testing on a refueling frequency.

Rectrding Paragraph IWV-3426, Analysis of Leakage Rates:

The licensee stated that leakage rates for valves being tested under

/ppendix J are covered by Appendix 0 and the Technical Specification.

Regarding IUV-3427, Corrective Action:

The licensee stated that a new relief request will be included in the progran to cover Vermont Yankec's position for compliance with IWV-2427 (and IWY 3426).

The staff stated that the licensee's precram must be equivalent to or more conservative than IWV-3427 in order to be acceptable to the staff.

Note: The code IUV-3427, Corrective Action, requires for poor performers (leaking valves) that testing be at increased frequency, i.e., cold shutdown. The code stipulates repair or replace valves that will exceed the maximum permissible leakage rate by gretter than 10% on a cold shutdown frequency. Vernont Yankee's resper.se focus is refueling frequency as opposed to the Code. Open item for the licensee.

9. Check Valve V72-103 Dwg. G191160 Sh. 3 Q. What is the basis for specifying the valve to be passive? The valve is categorized as AC, however, the exercise requiremen+s are not specified.

Coments: R The licensee stated that the subject instrurent air system check valve is considered passive as it is not required to change positien to accerplish its safety function of containment isolation. A normally blanked off spectacle flange and other norrally closed valves isolate the instrurent nitregen subsystem from the instrument air systen.

10. Check valves Q. What is the safety related function of these valves?

V-72-70 A/B G191160 Sh. 3 (L-17)

V-72-26 A/B Gl91160 Sh. 3 (L-12)

V-72-26 G/H G191160 Sh. 3 (L-11)

V-72-68 A/B G191160 Sh. 3 (J-11)

Y-72-37 A/B G191160 Sh. 6 (L-7)

Cerrents: R The licensee ste.ted that none of the subject valves perform a safety function to shutdcwn the reactor or maintain the reacter in a safe shutdnwn condition er to miticcte the consequences of an accident.

V-8 Emergency Diesel Generator Fuel Oil System Dwg. G191162

1. Q. is valve LCV-3 (D-5) required to opcrate at anytir.o the EDCs are responding to an accident cordition?

Comments: R The licensee stated that the subject valve is normally closed ard fails, closed upon a less of instrument air. Pest surveillance testing has shown EDG operability not to be affected regardless of the valves position. The valve is not recuired to operate during accident conditions.

2. Relief Valves 3A and 3B (C-4)

Q. Provide detailed technical justification for not including these valves in the orcgram and testing per IWV-3510.

Ccmments: R The licensee stated that these valves do not perform a safety function to shutdown the reactor or mitigate the consequences of an accident.

3. Q. Two relief valves and four check valves are shown on the drawing at the EDG. Provide your detail technical justification for not listing the valves in the progrim.

Cennents: R The licensee stated that for these valves preper operation is verified during the current surveillance testing of the engines.

l l

i i

-g

f

4. Clean Oil Tank (D-10) ,

a. Q. How is the tank vented?

b. Q. Are there any check valves installed in the pump discharge piping?  !

Comnents: R The licensee provided a sketch of the cleer. oil tank and piping. The tank is vented to atmosphere from a standpipe placed at the top of the tanks.

There are no check valves. The tink cc11ec*s cletr cil leakage from arcund the diesel. The licensee stated that failure of the clean oil pump would not preclude the diesel from performing its safety related function.

5. EDG Lube Oil System Q. What are the drawing numbers that sFew this systen? (No drawings were provided.)

Conments: R The EDG lube cil system is shewn on drawing 5920-4150.

V-9&l0 Nuclear Boiler G191167

1. Relief Valves SR2-14E-L and RRR V7 (L-11)

0. Under "Alterrate Testing", RRB V7 sheuld also specify exercise testing during refueling outages.

Commeny: LAR The licensee stated that pregram definition will be provided to show that the cold shutdown definitier will include refueling outages.

2. Relief Valves SR2-14 A-D (L-11)

Q. Prtvide your technical fut:tification for not testing these relief valves.

Comments: R The licensee stated that Safety Relief Valve Discharge Line (SRVDL) vacuum breakers SR-14 A-D do not perform a safety function and need i not be included in the IST Progran.

F 5  !

d

_ _ _ ___._..__ _ .__ _ _ _ . - _ _ . ~ . . _ , _ _ , _ _ , . . _ _ _ _ _ . . , _ _ _ - . _ . _ _

In 1980, Vernent Yankee performed ncdifications to the torus and associated LOCA load nitigation equipment as a result of the Mark I Containment Long Term Program.

Analyses on the safety relief valve discharge lines indicated that the 2-inch vacuum breakers (SR2-14 A-D) did not have enough throat area to equalize SRV'JL-Drysell pressure without the occurrence of a very high water leg in the line. This water leg, in turn, would produce intolerable thrust and dynamic pressure loads on the piping.

To reduce these loads, two redundant 10-inch vacuum breakers were installed in each line to replace SR2-14 A D.

Vacuun breakers SR2-14 A-D were retired in place and need not functier to aid in shutting down the reactor or in mitig! ting the consequences of an accident. The eight new vacuum breakers, SR2-14 E-L, are included in the IST program.

3. Valves V2-37A (check) (B-7)

S1A (solenoid operated) (C-8)

Q. Provide your detciled technical justification for not including these valves (one set for each relief valve).

Comnents: LAR The licensee stated that these valves will be added to the progran and will be tested on a refueling frequency, a relief request will be provided to support the refueling frequency surveillance testing.

4 RRB V 11 For Safety and Relief Valves

0. The VY testing frequency of testing all valves every two refueling outages is more conservative than the Code freovency of testing all valves every five years. However, the relief reouest does not -

adequately address the IWV-3513 additional test aspects regarding corrective action to be taken in the event a failed valve is identified. The relief request states that additional testing is unreasonable per IWV 3513, however, provides no bases for handling the failure issue. Provide your technical bases for hanc' ling the valve failure issue and specify alternate requirements.

Coments : LAR The licensee stated that failure of the Main Stean Safety of Relief Valve to function within the required parameters on test would result in the analysis and reporting of such failures in accordance with the Licensee Event Report systen, 10 CFR 50.73. Per 10 CFR 50.73(b),

i each LER shall contain an assessment of the root cause, safety consequences and implications of the event and a description of any corrective actions plcnned as e result of the event, including the need for additional testing and steps to be taken to reduce the probability of similar events occurring in the future.

The licensee will revise the relief request bases to address the part of the code that is practical and not practical to be net.

5. Feedwater Valves V2-27A (F-3)

V2-96A (H-3) and RRB V8 Q. These valves :hould complete with the analysis of Leakage Rates and Corrective Action Requirements, Paragraphs (IWV-3426 and IWV-3427, respectively. The relief request should be revised accordingly.

Coments: LAR The licensee respcnded to thic item subsequent to the meeting in a telephone discussion between the staff and Don Reid ar.d others on October 28, 1987.

The subject two outboard feedwater check valves will be local leek tested under Appendix J on a refueling frecuercy. The valves will be full stroke exercise tested to the open and closed positions on a refueling frequency. An appropriate relief request will be provided.

A generic relief request will be provided to cover Vermont Yankee's position for compliance with IUV-3426 and IWV-3427.

The steff stated that the licer. sees program would need to be equivalent to or more stringent than IWY-3426 and IWV-3427 in order to be acceptable to the staff.

6. Feedrater check valves V2-28 A/B (F-4)(H 4) and RRB V9 Q. Note: Valves have a safety related function to close at an isolation valve and a safety function to epen upon HPCI & RCIC injections. No relief from quarterly exercise testiop was included.

Do you intend to exercise quarterly?

The valves should comply with the analysis of Leakage Rates and i

Corrective Action Requirements, Paragraphs IWV-3426 and IWV-3427, respectively. The relief reauest should be revised accordingly.

Coments: LAR The licensee provided an additional response to this item subsequent to the meeting in a telephone discussion between the staff and Don Reid and others on October 28, 1987.

The licensee stated that the subject two inbeard feedwater check valves had received an exemption from leak rate testina under Appendix J. (Reference SER by letter D. G. Eisenhut, NRR, to J. B.

Sinclair, VYPC dated August 19, 1983). The licensee stated that the motor operated feedwater heater valves would be closed as backup in the event containment isolation is required. Closure of the motor operated heater valves is also reouired under Appendix J whenever containment isolation is recuired (reference the August 19, 1983, SER).

The licensee stated that the subject valves will be exercised to the full cpen position at startup and an ALARA bases for not full closure exercising would be provided. The licensee also stated that the valves have a hard seat and require a high pressure to seal ther:

closed. The piping configuration further makes it impractical to cerduct a pressure test te verify closure.

7. Process Sampling Valves V?-39 (L-4)

V2-40 (L-3)

RRB-V8 Q. These valves should comply with the analysis of Leakage Rates and Corrective Action Recuirements, Paragraphs IWV-3426 and IWY 3427, respectively. The relief request should be revised accordingly.

Coments: LAR The licensee stated that these Code requircrents would be covered by a gercric reitef request.

8. Stean Drain Valves:

V2-74 (D-10)

V2-77 (D-13)

a. Q. Provide your detailed technical justification for not exer-cising and stroke time testino these Category A valves,

b. C. The valves rust comply with the Analysis of Leakage Rates ard Corrective Action Requirement, Paragraphs IWV-3426 and 3427, respectively.

c. Q. The relief request RRB-V8 needs revising accordingly.

Comments: LAR The licensee stated:

a. The valves are presently exercised and stroke tined. The progran valve listing will be revised to reflect this testing.

b. These code paragraphs will be covered by a generic relief request.

c. The relief request RRB-V8 will be deleted.

9. MSIVs V2-80 A-D (D F, G, H-10)

V2-86 A-D (D, F, G, H-13)

a. Q. The valves rust corply with the Analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and 3427, respectively. Revise the relief reouest RRV-V6 accordingly.

Conments: R The licensee stated that a generic relief request will be provided to cover Vernont Yankee's position regarding cenplianen with IWV-3a?6 and IWV-3427.

10. Excess Flow Check Valves G191167 SL-23 (C-3)

SL-301F (D-3)

SL-201B (D-3)

SL-301A (0-3)

SL-301E (D-3)

SL-97B (M-12) s Describe the safety related function of each of these check valves.

Q vents: R The licensee stated:

SL-23 This valve is not required for reactor shutdown er accident mitigation.

SL301 A, B, E, F and SL-97B These valves were previously used ,

on reactor coolant pressure indicating lines and the indications and connections to the reactor coolant systen has been deleted by a design change. They are not required to be operable and now perforn ne safety function. Valve SL 078 has a closed ranual isolation valve (RV-988) upstream of it and is therefore also not required.  !

11. MSIV Supply Check Vcives IA 87 A-D (B-12)

CA 87 A-D (B-10)

Q. Provide detailed technical justification for not including these valves in the program. ,

These valves appear to assure that the HSIV accurulators remain at pressure in the event of a loss of header pressure. They appear to be Category C valves.

Cor. cents : LAR The 18.ensee stated that these check valves are not needed to fu .clon for the MSIVs to perform their safety function since the

.iSIVs are spring loaded "fail safe" to close. Based upon this, the valves are net required to be in the 15T progran.

The licensee also stated that the raain Steam relief valve air supply accumulator check valves, Y2-37A-D, do aerform a safety function, are presently tested and will be added to t1e IST program. The licensee will request relief from IWV-3426, analysis of Leakage Rates, for these vcives based upon a previcus staff safety evaluation letter, Vassallo, fiRC, to Capstick, VYtiPC, dated March 4, 1985. The licensee intends to meet IWV-3421 to derenstrate seat leak tightness.

V-11 Core Spray Systen Reference Drawing C191168

1. SR 20 A and B Safety Relief Valves Q. Provide a detailed technical basis for not including these valver in the program ar.d testing per IWV 3510?

Coments: R The licensee stated that the subject relief valvos are not required to perform a specific ferction la shutting down the reactor to the cold shutdown condition or in mitigating the consequences of an I accident.

2. MOV 12 A and 12 B (Outside containment) l l Check Valves V13A and V138 (Inside containment)

( Q. These valves provide the redundant barrier between high and low l pressure piping. Provide detailed technical justification for not designating as Category A and leak testing.

i

Comments: OI-S and LAR The licersee stated that the sub!cet valves will be designated Category A for the motor operated valves and Category AC for the checks valves.

The licersee does not individually leak test these valves. The 12A and 12B valves have continuous pressure monitoring downstream which '

is an acceptable method to the staff fer determining their leak tight condition. However, the leak tight condition of the check valves 13A and 13B is not assessed via leak testing. These check valves provide redundancy for protection of the low pressure piping.

The hRC Committee to Review Generic Reouirements (CRGR) currently has under gereric review requirements for pressure isolation valves that ccmprise the berrier between high pressure and low pressure piping.

Pending the findings from the CRGR regarding this natter a staff position regarding leak rate testing of check valves 13A and 13B can be made.

This is an open iten for the staff and licensee.

3. MOV - V 7A and 7B (CS Pump Suction) t Q. What functien(s) do the valves serve to mitigate the consequences of an accident. (The valves are not in the IST program).

Comments: R The licensee stated that these valves do not perform a safety function. The valves receive no automatic initiation signals and are open during post accident conditions for eperation of the system.

4. Excess flow check valve SL-25 Q. Why is this valve not tested similarly to SL 31 A&B7 (The valve is not or relief request RRB-V16).

Connents: R The licensee stated that the valve is included in the program as valve 2-3-25 under V-26 Nuclear Boiler Vessel Instrumentation. The valve is covered by RRB-40.

5. Check Valves 33A and 33B (CS pressurizing lines)

Q. Dc these valves close to mitigate an eccident? Discuss their function.

Comments: LAR The licensee stated that these check valves must close to assure that core spray flow does not bypass the core. The valves must open to permit flow into the core spray piping. The licensee will add the valves to the IST program to verify their proper operatien. A relief request will be incorporated into the IST program to cover what testing is/is not practical for these check valves.

V-12-14 ,High Pressure Coolant Infection System (HPCI) G191169, Sh. 1 1 Steen Valves and RRB-V17:

YP3-15 (E-5)

V23-16 (F-7)

0. The valves rust comply with the Analysis of Leakage Rates ard corrective Action Requirements paragraphs IWV-3426 and 3427, respectively. Revise the relief request RRB-V17 accordingly.

Comments: LAR The licensee stated that a new relief recuest will be included in the IST program to cover valves being leak tested under Appendix J.

The staff wili consider the relief request to be acceptabic provided the licensee's program is equivaler.t to or more stringent thar.

IWV-3426 and 3427.

2. Excess Flow Check Valves:

SL 23-37 A-D cr A-L (F, G-5)

Q. Which is correct? The "Valve No." listing appears to have a typo.

The drawing reflects A-D.

Comments: R  :

The licensee stated that SL 23-37 A-D is correct and the listing has been corrected.

3. Check Valves and RRB-VPO: (N-7)

V 23-61 Q. The relief request basis wording is unclear regarding assuring that the valve's exercise test assures the exercising of the valves to the full open position.

Coments: LAR The licensee stated that the relief request RRB-V20 will be revised to specify full stroke exercising.

4 Check Valves (K-5)

V 23-12 and V 23-65 Q. These valves need to open to drain condensate and the exhaust steam drain pot. Provide a technical justification as to why the valves aren't exercise tested?

These valves also appear to perform a containment isolation function; if so, shculd be Category AC and comply with IWV-3426 and IWV-3427.

Coment s: LAR The licenste stated that both valves are in the IST program and are exercised tested during the monthly technical specification required HPCI test at full flow.

The check valves will be designated AC. The licensee will leak test in accordence with Appendix J and will provide a generie relief reauest regarding corrpliance with IWV-3426 and IWV-3427.

The staff will consider the relief request to be acceptable provided the licensee's program is equivalent to or more strincent than IWV-3426 and 3427.

The licensee stated that valves SSC-23-13 and V23-36 will also be added tc the IST progran and be designatec Category AC.

5 Check Valves N-3)

V 23-842 and V 23-843 Q. These valves appear to be needed to open during HPCI operation, if so, they should be exercised tested. These valves also appear to perform a containment isolation function, if so, should be Category AC and comply with IWV-3426 and IWV-3427.

Conments: LAR The licensee stated that the subject valves will be added to the IST progran and designated Category AC. The valves will be full stroke exercised during HPCI operation.

The licensee will incorporate a generic relief request relative to neeting IWY-3426 and IWV-3427.

6. Relief Valves G191169 Sh. 2 Y 23-34 (D-9)

Y 23-66 (J-12)

Q. Provide detailed technical justification for not having these valves in the IST prcgram, and testing the valves as required by IVY 3510.

Comments: R The licensee f.tated that the subject valves are not required to operate for safe shutdown or to nitigate the consequences of an accident.

7. Air Operated Valve V 23-54 (K-12)

0. Provide detailed technical justification for not having the valve in the IST program and designating Category B.

Comments: R The licensee stated that operation cf V23-54 is net required and has

. no inpact on HPCI operation. It is not required to operate for te.fe reactor shutdown or to mitigate and accident.

O. Check Valves (L-11)

V 23-130 and V 23-131 Q. Provide detailed technical justification for not having these valves in the IST program and designatine es Category C valves.

Cemeents: OI-L The licensee stated that edditional review will be required to resolve the staff concern. Open iten for the licensee.

9. Air Operated Valves G191169 Sh. 2 V 23-39 and 40 (M-11)

Q. What is the safety related function of these valves?

Coments: R The licensee stated that these level control valves are not necessary for oroper HPCI operation. The valves function during HPCI standby conditions therefore are non-safety related.

+

10. Drain Yalves G191169 Sh. 1 (H-17 & J-1)

V 23-53 (Air Operated) (H-17)

Y 23-42 (Air Operated) (J-16)

V P3-43 (Air Operated) (0-16)

Y 23-149 (Check Valve) (I-16)

Q. Provide detailed technical justification for not having these valves in the IST progren.

- Comments: R The licensee stated that the subject valves are not required for HPCI operation. The valves serve to drain condensate from the HPCI turbine steam supply line, however, if a high level occurs in the steam supply line drain pot a high level alarm is annunciated in the control roon.

V-15 ,Cnntrol Red Drive Hydraulic System G191170

1. Valve V3-181 and RRB-V22 J-21

0. The relief request ne ds to incorporate testirp at refueling '

frequercy in addition to cold shutdown.

The program's velve listing drawing cccrdinates should be J-21, not I-21.

Comments: LAR The licensee stated that definition will be rade in the program to reflect testing during refueling in addition to cold shutdown.

The cccrdinates in the IST Program will be corrected to show J-21.

2. Valves V13-115 (B-16)

Q. The charging header check valves are active during reactor scrams to aid in control rod inserting and safe reactor shutdowr. Provide detailed technical justification for not including these valves in the orogram.

Cerrents: LAR The licensee stated that the check valves will be put into the IST progran as Category C and tested to assure that they will ce to the full open position.

-24 V-16 Standby Liquid control System Drawing No. G191171

1. Relief Valves SR-39A and 395 (G,K-7)

Q. These valves should be designeted Category C and tested per IWV-3510.

Cements: R The licensee stated that these valves do not operate to shutdown the reactor or mitigate the consecuences of an accident. The valves are required to be tested under the technical specification 4.4 A.2. to verify that their set point is between 1400 and 1490 psig.

2. Check Valves Y 11-16 and 17 (G and H-2)

Q. Relief Request Basis V24 refers to TS Table 4.7.2.b applicable to centainment isolation velves as opposed to component operational readiness testing under Section XI, IWV-3400. Provide detailed technical justification for not testing in accordance with Section XI.

Coments: LAR and 01-L The licensee stated that the valves are exempt free local leak rate testing under Appendix J. These check valves (Category AC) are 1cceted at the primary containment boundary, one located inride and one located outside. The SBLC explosive valves, located outside containment, seal the lines normally.

Powever, the staff's ccreern is that once the explosive valves are fired and the SBLC system has exhausted its supply or is shutdown for any reason, the subject valves wculd be needed to close and seal actinst an event where reactor pressure remains elevated. None of the remaining SBLC valves are leak tested under the IST program.

There is low pressure piping upstream including tanks that are vented to the atmosphere. Leak testing of the subject two check valves is an open item for the licensee.

V-17 &l8 Residual Heat Removal System G191172

1. 110 tor Operated Yalves: Y 10-17 and RRB Y26 (G-8)

V 10-18 (F-8)

a. Q. The relief request needs to clearly ste.te the detailed technical basis for the specific relief requested. The relief request basis states that the valves are presently exempted, per Tech. Spec. Section 4.7.2 from leak testing, however, a basis for this statenwnt has not bcon found.

t i

l 25-Comments: LAR  :

l The subject valves are reactor coolant systen high to low pressure piping isolation valves. Valve V10-17 has pressure nonitoring dcwn stream which is acceptable t the staff for determining the leak tight integrity for this valve.

The licensee stated that valve V10-18 does not receive a leak test.

During the meeting the staff discussed using an existing 3/4 ir.ch line, below valve VIO-18 as a possible way to monitor icek tightness of the valve.

During a followup telephone discussion on December 22, 190 , the l licensee comitted to runnir.g a leak test on MOV V10-18 by monitoring leakage through the 3/4 inch lire when the vessel hydro is conducted at a refueling frequency. This, will provide resolutien to this

! staff's concern,

b. O. These valves must ccrply with the Analysis cf Leakago Rates and Cctrective Action Reevirements of the Code paragraphs  ;

IWV-3426 and IWV 3427.  ;

Coments: 01-L The licensee needs to reevaluate their response to IWV-3426 and IFV-342i for the subject valves. Open item for the licensee. ,

t

2. Yalves: Y 10-26A/B (C-7)(C-11)

O. Same coment as 1.a. and b. above.

Coments: LAR The icek rate testing requirerents of Appendix J apply. The staff '

notes that the subject drywell spray valves have been exenpt from Appendix J type C leak rate test.

! 3. Valves V10-27A/B (D-6)(D-12)

0. These valves are the first closed gate valves off of the reactor -

coolant loeps to protect low pressure piping. Provide detailed technical justification for not designating as category A and leak testing. (Reference GDC-54) i I

Comment s: 01-S and CI-L This valve is the normally closed high pressure noter operated globe valve protecting low pressure piping downstream and as such should be designated Category A. There is one normally closed check valve between the reactor coolant system and the subject valves. The licensee does net leak rate test the subject valves ner has it been shown that pressure ronitoring downstream is capable of ascertaining the valves leak tight condition.

The NRC Connittee to Review Generic Requirenents (CRGR) currently has under review requirerents for pressure isolation valves thet ccmprise the barrier between high pressure and low pressure pipinc. Pending the firdings from the CRGR reearding this matter, a staff position on leak rate testire of the subject valves can be made.

Open item for the staff and licensee.

4. Valves V10-31A/B (C-B) (C-10)

Q. Sama comrert as 1.a. & b. above.

Commenti: LAR The leak rate testing requiremerts of Appendix J apr The staff nctes that the subject dry well spray valves have be. ampt from Appendix J type C leak rate test.

5. Valve Y 10-32 (C-9)

Q. Sar.e comment as 1.b. above.

Conment.e : LAR The licensee stated that a new relief request will be included in the IST program to cover valves being leak tested uncer Appencix J.

The staff will consider tbc relief request to be acceptable provided the licensee's program is equivalent to or mere stringent than IWV-3426 and 3427.

6. Valve Y 10-33 (A-7)

Q. Same comment as 1.b. above.

Comments:

LAR Sane response at item 5. above.

a

7. Valves V10-34 A/B (E-4) (E-14)

Valves V10-38 A/O (E-4) (-13)

Q. These valves are the first normally closed valves coning from the suppression charber (Reference GDC-54). Same coment as 1.a. and 1.b. above.

Comments: LAR The leak rate testing requirements of Appendis J apply. The staff notes that the subject torus spray and 1cvel supply valves have been exempt frern Appendix J type C leak rate test.

C. Valves V10-39 A/B (D-4) (D-14)

e. Q. Same comments as 1.a. and 1.b. above. (Note: this is the '

second valve frem containraent.)

Coments: LAR The leak rate testing requirement of Appendix J apply,

b. Q. Previde detailed justification fer not quarterly stroke testing these valves.

CormenM

LAR The licenste stated that the valves are quarterly stroke tested.

, The progran will be corrected to reflect quarterly stroke testing.

9. Check Valves V10-46 A/B (E-7) (E-11) i Q. These valves are listed as Category C, however3 they are the inside containment isolation valves and should be categcrized as AC and leak tested to assure protection of low pressure piping.

Ccreents: OI-S and 01-L The valve is a normally closed check valve serving as a pressure  ;

isolation valve protecting low pressure piping downstream. This is '

the first normally closed valve from the reactor coolant system.

The valve should be designated Category AC. The licensee does not leak rate test the subject valves neither is there continuous  :

pressure monitoring dcwnstream, i l

. , - - . , , , _ - - - -- - - ~ _ - - ~ . - ~- - -___-

t l

The NRC Comittee to Review Generic Requirerrents (CRCP) currently has under review reouirements for pressure isolation valves that cerprise the barrier between high pressure and 1cw pressure piping. Pending the findings fron CRGR regarding this matter a staff position regarding leak rate testing of the subject valves can be made.

Open item for staff and the licensee.

10. Valves V10-89A/B (F-1) (L-17)

O. Do the valves have a fail safe position and if se, are they exercised to this position?

Coments: R 1 The licensee stated that the valves have no fail safe position. They ere remote manually operated.

11. Valves V10-16 A/B (I-6) (I-12)

Q. These valves are the first isolation valves outside containment ord as such appear to be Category A as they serve an isolation functier, (Reference CDC-54). Provide detailed justification for r.ct designating Category A.

i Coments: R The leak testing recuirements of Appendix J apply. The staff nntes

, that the subject valves have been exempt from Aper. dix J 1eak rate testing.

1?, Check Valves V10-19 A-D (K-6 & 12)

(J-6 & 12)

. a. Q. These valves are the second isolation valves outside of

! centainment and as such it appears these valves should be Category AC and leak tested.

I Coments: R The leak testing requirements of Aptendix J spply. The staff nctes that the subject valves have seen exempt from Appendix J i leak rate testing.

1

b. Q. It is not clear (Reference Note 6) that the exercise testing verifies full opening of these valves.

Cc rents: LAR l

The licensee stated that Note 6 will be revised to reflect l proper opening of the valves.

l i  :

i

. , - - - - -------~n,- , , - . - , , - , ,,..--n. -

13. Relief Yalves V10-SR-35 A/B (D-2) (D-15)

V10-SR-40 (G-8)

V10-SR-72 A/B/C/D (K-7) (K-11) (J-7) (J-11)

V10-SR-80 A/B (K-3) (K-14)

V10-SR-86 A/B (K-3) (K-14)

V10-RV-210 A/B (D-12) (D-5)

Q. Provide detailed justification for not designating these valves Category C and testing per IWV-35107 Corrents: R The licer.see stated that the subject valves are not required to cperate for safe reactor shutdown are to mitigate the consequences of an accident. The valves serve a thermal relief function.

14 l'otor operated Valve V10-20 (H-4)

Q. This valve hcs a safety function as described in FSAR 4.8.5 "to supply either loop from the pumps in the other loop". Its operational readiness should be verified and, therefore, included in the program.

Ccrreeng: LAR This licensee stated that the subject valve does not perform a safety function. The motor leads have been disconnected. The licensee stated that the FSAR will be updated.

15. Valves V10-15A/B/C/D (K-7) (K-10) (J-7) (J-10)

O. Are these valves used to bring the reactor to a enld shutdown condition or in mitigating the consequences of an accident? If so they should be included in the program.

Corrents: LAR The licensee stated that the shutdown cooling suction valves are required to open to provide shutdown cooling. The valves will be included in the IST program as Category B valves.

16. Valves V-10-13A/B/C/D (K-8) (K-9) (J-9) (J-8)

t Q. Are these valves used to bring the reactor to a cold shutdown cendition or in nitigating the consequences of an accident? If so  :

they should be included in the program.

Coments : LAR The licensee stated that these valves are required to close when the RHR system is aligned for shutdown cooling and will be included in the IST program and designated as Category B valves.

V19-21 Reactor Core Isolation Cooling System (RCIC) G191174, Sh. 1

1. Motor Operated Valves and RRB-V30 V13-15 (0-7)

V13-16 (D-8)

Q. The staff position is that the Category A valve leak rate requirements are fulfilled by 10 CFR 50, Appendix J, requirerents for CIVs and that relief from the Section XI leak rate testing require-ments presents no safety problen. However, the licensee nust comply with the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs IWV-3426 and 3427 unless specific relief is requested from these paragraphs and subsequently granted by NRC. Revise the Relief Request.

Comments: LAR The licensee stated that a new relief request will be included in the IST progran to cover valves being leek tested under Appendix J.

The staff will consider the relief request to be acceptable provided the licensee's program is equivalent to or more stringent than IWV-3426 ar.d 3427.

2. Check Valve V13-22 and RRB-V31 (G-9)

Q. Frequency does not include refueling frequency or (24 month maximum).

Revise relief request and testing frequency.

Coments: LAR The licensee stated that their definition is that a refueling outage is a subset of cold shutdown. The licensee will provide definition in his program to clarify this intent.

l

! l 3

3. liotor Operated Valve V13-41 ( 14 - 1 0 )

Q. If this volve serves a containmer.t isolation function with a specified leak rate, it shculd comply with IWV 3426 and IWV-3427 (reference item 1.

above).

Comments: LAR The licensec stated that a new relief request will be included in the IST progran to cover valves being leak tested under Appendix J.

The staff will consider the relief request to be acceptable previded the licensee's progran is equivalent to or more stringent than IWV-3426 and 3427.

4 Check Valyc V13-40 and RRE Y-33 (it-11)

Q. Relief reouest basis does not clearly state words to indicate full stroke exercise testirig is required.

Comments: LAR The licensee stated that the subject relief request will te revised to state full stroke exercising is required and plant procedures will be revised acccrdingly.

5. Relief Valves G191174, Sh. 2 Q. Provies detailed technical justificatier for not including these valves in the program and testirC es Category C valves as required by IWV-3510.

SR-25 (B-7)

SR-26 (I-7)

SR-27 (J- 14 )

Comments: R The licensee stated that these valves arc not required to perform a specific function in shutting down the reactor or in mitigating the consequences of an accident.

6. liotor Operated Yalve V-1 (13-D)

Q. What is the safety related function of this valves?

Coments: R The licensec stated that this valve serves no safety related function. It is not required to function to allcw RCIC initiation for accident mitication,

• i

7. Check Valves (K 13 & 10)

V13-70 and V13-133 Q. Provide detailed technical justification for not including these valves ,

in the prcgram.

Comments: 01-L The licensee stated that the safety related functions of these valves would be revieutd.- This is an open item for the licensee.

8. Air Operatco Valycs V13-12 (L-10)

V13-13 (L-10)

Q. Provide detailed technical justification for not including these valves in the program.

Comments: R The licensee stated that the subject valves are not required to function for proper RCIC operation and were therefore net put into the IST program.

9. Air Operated Yalves G191174 Sh. 1 ,

V13-32 (H-17)

Y13-34 (K-17) <

V13-35 (K-17)

Check Valvc V13-140 (I-17)

Q. Provide detailed technical justification for not including these valves

in the program.

Comments: R The licensec stated that the subject valves were for operating convenience and were exempt (under IWY-1200) from the IST program. The valves are i not necessary for proper RCIC cperation.

10. Check Valves t

Q. Provide detailed technical justification for not including these valves

. in the progren.

V13-SSC-10 (K-8)

V13-29 (J-10)

V13-3e (K-11) i i

Comments: LAR The licensee stated that the subiect valves will be added to the IST program since they are required to open for proper operation of the systen. The subject valves and the following valves which are already in the program, SSC-13-9. V13-27, and V13-50, will all be designated as Category A. The licensee will provide a generic relief request for IW-?d26 and IWV-3427.

11. RRB-V33 for valve V13-40 Q. The alternate testir.c reeds to be revised to clearly assure that the valve is full strcke exercised.

Corrents: LAR The licensee stated that the subject relief request will be revised to specify full stroke exercising. 1 V-22 Primary Centainrent and Atrespheric Centrol

1. Or3vell te Torus Vacuen Breakers G191175 Sh. 1 (J-8)

Q. The prcgran list Yalves V16-19-5A-J, however, the drawing indicates A-F and G&H. Which is correct?

comments: R l The licensee stated that the progran was designated correctly.

2. Relief Request RRB V-36 Q. This relief ree,uest or another needs te address IWV-3420 regarding pressure differential testing at lower than functienal differential pressures IWV-3426 Analysis cf Leakage Rates and IWV-3427 Corrective Action.

Comments: R i

, The licensee stated that the relief request was being deleted since the testing was being done in accordance with Appendix J at the

< accident pressure Pa = 44 psig. The licensee will use a generic relief recuest to cover IWV-3426 and IWV-3427.

3. Valves V16-19-12 A/B and RRB V-33 G191175 Sh. 1 (K and M-16)

O. The relief request does not address testire at cold shutdown and refueling frequency. Quarterly exercise testing was not specified as a requirerent in the valve table.  ;

l

. . - . _ . _ . _ - , , - - - , , , , , _ . _ . _ - 7

Comments: LAR i The licensee stated that the rolief request would be revised to reference cold shutdown and refueling. The vacuum breakers cannet be exercised during power operation.

4. Check Valves G191175 Sh. 1 (I-11)

V16-19-51 and Y 16-19-52 Q. What is the safety related fu -+ an of these valves?

Cemments: LAR -

The subject valves are not used and do not perform a safety furttion.

The systera is isolated by closed manual valves: Y16-19-53 and V16-19-54. As added assurance, valve V16-19-34 will be locked closed.

V-23 Radwaste Systems G191177 Sh. 1

1. Valves V20-82, 83, 94, 95 and RRB-V39 I Q. The leak testing does net include requirements of IWV-3426 and IWV-3427 for ar.alysis of leakage and corrective action requirements i of the Cede. ,

Coment s: LAR The licensee stated that a new relief request will be ine'uded in the IST program to cover valves being leak tested urter Appencix J.

The staff will consider the relief request to be acceptable previded the licensee's program is equivalent to or nere stringent than IWV-3426 and 3427.

2. Dry Well Sump Check Valves' SOA (D-2)

BOB (D-3) -

90A (!-2) 90B (I-3)

Q. Previde detailed technical justification for not including these ,

valves in the program and categorizing as AC.

I

s .

i s Cotrents:

R

The licensee stated that the subject valves 3erforn no function in shutting d w the reactor or in citigating t;e consequences of an accident. it.e lines these valves are in are isolated by a Group 2 containrent isolation signal.

V-24 Reactor Water Clear Up System G191178 Sh.

1. Valves V12-15 (D-2)

V12 16 (D-3)

V12-60 (C-11)

Q. These valves are listed as Category B. The valves serve as prir.ary containrent isolation valvec erd have a safety functicn to protect the reacter core in case of a pipe break in :ne clean up syster. They isolate on a reactor water low level. These valves should be Category A ard leak tested.

Ccerents: LAR The licensee stated that the valves will be designated Category A.

Leak rate testing will be done under Appendix J. The licensee will have a generic relief request fcr IWY 3426 and IWY 3427.

2. Felief Valves

\12-SR-E2 (F-10)

V12-SR-85 (D-10)

V12-SR-04 (G-12)

0. These valves are not included in the program, hertever, appear to have a safety function to protect the systen against over pressuri-ratien. What is the basis for ret designating the valves as Category C and testing in accordance with IWY-35107 Cerrnents: ,

R The licensee stated that the subject"relief valves are thermal relief valves and do not operate to shutdown the reactor or citigate the consequences of an accident.

3. Check Valve .

Y12-62 (B-5)

[

\

Q. This valve appeart, to be a Category C valvt since it functions te close to assure thet RCIC ficw goes to the core, however, it is not in the program.

Cenn,ents :

R The licensee stated that the subject check valve is not required to operate since motor operated valve V12-68 would already be closed to isolate the subject line. V61ve V17-63 is in the IST program, t therefore, V12-62 is not included.

V-26 Nuclear Boiler Vessel Instrumentation

1. RRE-V40 Dwg. G191267 Q. The Code stipulates exercising the velves every 3 nonths or if the valves cannot be exercised every 3 months during plant operations, the velves shall be full stroke exercised during cold shutdown.

The relief request for testir5 dcas not address the Code required frequency of cold shutdown nor is technical justification provided

, for net meeting the cold shutdown frequency.

Comments: LAR The licensee stated that the testing of these excess flew check velves can only be done when the reactor vessel is at pressure but not operating. This tes: condition occurs during the reactor vesse' hydrostatic test perfop.ned during refueling outages. The relief request will be revised to include the required clarification information.

1 V-27828 Centainment Atmosphere Dilution Dwg. VY-E-75-002

1. General Comnent: Valves which are rcquired te cperate or function to bring the reactor to cold shutdown 'conditici s or in nitigating

- the consequences of an accident should be included in the IST program and tested in accordance with reouirenei ' of the Code (Reference IWV-1100). If the valve is required to operate under these cenditions, testing is reouired under the Coce and any relief

, requested from this testing must be.ve a technical basis previded .'ar the specific relief requested. (Alsc reference to the staff rete under item 2. of Prinary Containment and Atrespheric Control).

Further, the NRC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds or less. Relief frem the trending requirements of Section XI (Paragraph IWY-3417(4) will be i given for these valves since variations in stroke tines will be affected by slight varietions in the response time of the personnel performine this tests. However, the staff does require that the licensee arsign a maximum limiting stroke time of 2 seconds to these

valves in ordar to ebtain this Code relief.

Q. The relief reauest bascs in RRB 41, 42 and 43 lack specificity regarding the detailed technical bases for the relief requested.

These relief requests need revision.

Coments : LAR The licensce stated that revised relief request (s) would be submitted to cover IWV-3417(a). The licensee stated that they will ccmply with 3417(b) or provide an appropriate relief request. The RRB 41, 47 and 43 will be deleted and the new generic relief request will be referenced.

2. Q. The followine valves are designated as passive, however, they serve ar. active function with the Primary Cortainment Isolation Systen (PCIS), therefore, should be designated "Active" and exercised and stroke time tested:

VG-75A-3, -4 (J-14)

VG-9 A/B (G-12, I-13)

VG-22 A/B (B-16, E-16)

NG-11 A/B (G-9)

NG-12 A/B (I-8)

NG-13 A/B (I-9)

Comments: LAR The licensee stated that VG-75A-3, -4 PCIS signals were removed in crder to ensure continucus indication of containment hydrogen concentration. These valves do not receive any automatic isolation signals and are repositioned only by direct operator action. All of the va' .s will be designated as "active" in the valve listing based upon their PCIS function. All cf the valves with the exception of l

VG-72 A/B are "rapid acting" solenoic valves (VG 2P A/B are motor I operated). All will be stroked and timed. A relief request for the I

rapid action valve stroke time trending will be added to the program.

l 3. Q. The following valves are designated for alternate testing in

accordance with Appendix J. These valves need to cceply with l IWV-3426, Analysis of Leakage Rates and IWV-3427, Corrective l

Action of the Cede.

FS0-109-76A/B (L-14)

VG-23 (J-19)

VG-26 (J-19)

VG-9 A/B (G-12,I-13)

VG-22 A/B (B-16, E-16) l NG-11 A/B (G-9) '

l NG-12 A/B (I-8) f:G-13 A/B (I-9)

I

f Coments: LAR The licensee stated that a new relief request will be included in the IST program to cover valves being leak tested under Appendix J.

The staff will ccrsider tbc relief request to be acceptable provided the licensee's program is equivalent to or mere stringent than IWV-3426 and 3427.

4. Q. Technical Specification Table 4.7.2.b require the following valves to be operable, however, the prcgram does not operability test (exercise or stroke time) the valves. Provide detailed technical justification fer not inclu.itng this testing in the program.

Valves: VG-24 (L-11)

VG-25 (L-11)

VG-33 (L-11)

VG-34 (L-il)

VG-75 A, 1-4 (J-13, J-14)

Coments: LAR The licensee stated that the subject valves will be designated as "active." Each of these valves are "rapid actirg" solenoid valves.

The valves will be stroked and tined and included in a relief request for relief fron stroke time trending based upon rapid operatien of 2 seconds or less.

5. Pelief Valycs NG-34-A, B (A-2, G-2)

Q. Provide detailed technical justification for not testing these valves per requirements of IWV-3510.

Comments: R

~

The licensee stated that the subject valves do not have to operate or function to bring the reactor to cold shutdown conditions or in mitigating the consequences of an accident.

V-29 TIP

1. Ball Valves A-C and RRB V44 Q. The program "Test Requirements" should show "leak test".

RRB-V44 should show that the valves meet IWV-3426, analysis of Leakage Rates and IWV-3427, Corrective Action.

Quarterly testing of these valves was not stipulated as the test frequency.

Corrents: LAR The licensee stated that leak test in accordance with Appendix J will

9 Comments: LAR The licensee stated that a new relief request will be included in the IST progran to cover valves being leak tested under Appendix J.

The staff will consider the relief request to be acceptable provided the licenseo's program is equivalent to or more stringent thar IWV-3426 and 3427.

4 Q. Technical Specification Table 4.7.2.b require the following valves to be operable, however, the program does not operability test (exercise or stroke time) the valves. Provide detailed technical justification for not including this testing in the program.

Valves: VG-24 (L-11)

VG-25 (L-11)

VG-33 (L-11)

VG-34 (L-il)

VG-75 A, 1-4 (J-13, J-14)

Comments: LAR The liccrsee stated that the subject valves will be designated as "active." Each of these valves are "rapid acting" solenoid valves.

The valves will be stroked and timed and included in a relief request for relief from stroke time trending based upon rapid operation of 2 seconds or less. i

5. Aelief Valves NG-34-A, B (A-2, G-2)

Q. Provide detailed technical justification for not testing these valves per requirenents of IWV-3510.

Comments: R The licensee stated that the subject valves do not have to operate or function to bring the reactor to cold shutdown conditions or in mitigating the consecuences of an accident.

V-29 TIP

1. Ball Valves A-C and RRB V44 Q. The program "Test Requirenents" should show "leak test".

RRB-V44 should show that the valves neet IWV-3426, analysis of l Leakage Rates and IWV-3427, Corrective Action.

l Quarterly testing of these valves was not stipulated as the test frequency.

Coments: LAR The licensee stated that leak test in acco; dance with Appendix J will be added to the program under alternate testing. The TIP system solenoid valve will be removed from the program since it no longer receives a primary containrxtt isolation signal. The solenoid valve no longer performs a safety function.

The licensee will refer to a generic relief request for meeting IWV-3426 and IWV-3427.

2. Shear Valves A-C Q. The program legend stipulates testing 201, of the explosive charges every 2 years. This curulatively test all 4 valves within eight years, Does the manufacturer's guaranteed operating life for the explosive charges exceed the eight years?

Coments: R The licensee stated that they have a total of 3 T!F shear valves at Vermont Yankee. The explosive charges in all 3 valves are replaced at a maximum interval of 2 years. The required service life of the replacenent charges is verified prior to their installation.

3. Relief Request RRD-V45 Q. The relief request will be acceptable if a maximum stroke time of '

2 seccrds is assigned. (Reicrence coment under iterr 1. of V-27 &

28.)

Comments: LAR The subject relief request will be removed from the program per recent design changet to delete the valves centainment isolation sigr.al. The subject solenoid vsive no lenger performs a safety function.

Relief Request Basis

1. RRB GV-2 Q. This relief request needs better definition.

Coments: LAR The licensee stated that the relief request uculd be revised to provide better clarification.

~

I l

2. RRE. GV-4 Q. As previously discussed under V-27 & 28, the NRC staff has identi-fied rapid-acting power operated valves as those which stroke in ?

seccrds or less. Relief from trending requirements of IWV-3417(a) will be given for these valves, however, the staff does recuire that the licensee assign a maximum limiting stroke time of 2 seconds to these valves in order to obtain this Code relief.

Corrents: LAR The licensee stated that the subject relief request will be revised accordingly, i;iscellanecus Items / Comments

1. Q. Provido pump and valve prograr listing for sptint fuel pool cooling.

Comments: R The licensee stated that Vermont Yankee has no accident analysis that requires pueps and valves to operate for fuel pool cooling.

2. O. Provide the maximun value of limiting stroke tine for all power or.erated valves in the IST program.

Comments: R The licensee provided a tatle listing the quantitative values based upon the plants safety analysis.

3. Q. Provide the documentation that ensures that IWV-3300 is being ret.

(Renote position indication verification).

Comments: R The licensee provided for staff review a copy of the pertinent pages from procedure 4102.03, Revision 14, that provides for Local / Remote Valyc Position Indication Tes's.

l 4. Q. Provide latest revisions cf drawings for post accident hydrogen l control and the updated IST program listing for the pumps ard valves for post accident hydrogen control.

Conrnents: R The licensee stated that at Vermont Yankee post accident hydrogen control is previded by the Containment Atmosphere Dilution (CAD)

Systera. CAD is included in the IST program on pages V-27 and V-28.

t l

5. Q. Provide a listing of all valves that perform a pressure isolation beundary between the high pressure reactor coolant system and connected lower pressure piping systems.

Comments: R The licensee provided a listing of the subject pressure isolation valves for staff review.

6. Q. During the meeting the staff asked the licensee to provide drawings and inforration for staff review regarding pumps and valves that would be required to maintain contrci room habitability in the event of ar, accident.

Comments: R The licensee supplied drawings subsequent to the meeting and stated

.ut there were no pumps or valves within the control room HVAC system which are required to operate to maintain control room habitability.

l 1

o May 9,1988 Docket No.: 50-271 LICENSEE: Vermont Yankee Nuclear Power Corporation (VYNPC)

FACILITY: Vermont Yankee Nuclear Power Station

SUBJECT:

HEETING

SUMMARY

On October 14 and 15, 1987, the NRC staff met at the NRC Region I office in King of Prussia with representatives of VYNPC to discuss remaining informational needs associated with the staff's review of VYNPC's Inservice Testing (IST) prograu for pumps and valves. On October 28 and December 22, 1987 the staff also discussed by telephone with VYNPC representatives follow on items resulting from the meeting. Meeting minutes which include an attendance roster are enclosed.

The licensee has agreed in telephone discussion with the Project Manager to revise the IST program, based on these meeting minutes, and resubmit the revised program as soon as possible but no later than August 1,1988.

Sincerely, Griginal signed by:

Vernon L. Rooney, Senior Project Manager Project Directorate I-3 Division of Reactor Projects I/II

Enclosures:

As stated cc: See next page DISTRIBUTION: Docket File, NRC & Loca PDRs, PDI-3 r/f, VRooney, RWessman, OGC, Edordan, JPartlow, DCaphton, PEapen, LPrividy, JDurr, ACRS (10), HBClayton OFC :PDI-3 N IR/P  :  :  :  :  :

NAME :VRoo ey:mw :RWessm  :  :  :  :  :

DATE :04/1/88 :04/4 /88  :  :  :  :  :

(

OFFICIAL RECORD COPY

=

Mr. R. W. Capstick Vermont Yankee Nuclear Power Corporation Vermont Yankee Nuclear Power Station cc:

Mr. J. Gary Weigand W. P. Murphy, Vice President President & Chief Executive Officer and Manager of Operations Vermont Yankee Nuclear Power Corp. Vermont Yankee Nuclear Power Corp.

R.D. 5 Box 169 R.D. 5, Box 169 Ferry Road Ferry Road Brattleboro, Vermont 05301 Brattleboro, Vermont 05301 Mr. John DeVincentis, Vice President Mr. Gerald Tarrant, Commissioner Yankee Atomic Electric Company Vermont Department of Public Service 1671 Worcester Poad 120 State Street Framingham, Massachusetts 01701 Pontpelier, Vermont 05602 New England Coalition on Nuclear Public Service Board Pollution State of Vermont Hill and Dale Farm 120 State Street R.D. 2, Box 223 Montpelier, Vermont 05602 Putney, Vernont 05346 Vermont Public Interest Research Group, Inc. Mr. Walter Zaluzny 43 State Street Chairman, Board of Selectman Montpelier, Vermont 05602 Post Office Box 116 Vernon, Vermont 05354 William Pussell, Regional Administrator Raymond N. McCandless Region I Office Vermont Division of Occupational U.S. Nuclear Regulatory Commission and Radiological Health 475 Allendale Road Administration Building King of Prussia, Pennsylvania 19406 Montpelier, Vermont 05602 Mr. R. W. Capstick Honorable John J. Easton Vermont Yankee Nuclear Attorney General Power Corporation State of Vermont 1671 Worcester Road 109 State Street Framingham, Massachusetts 01701 Montpelier, Vermont 05602 John A. Ritscher, Esquire Mark J. Wetterhahn, Esq.

Ropes & Gray Conner & Wetterhahn, P.C.

225 Franklin Street Suite 1050 Boston, Massachusetts 02110 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20006

O Vermont Yankee Nuclear Power Vermont Yankee Nuclear Power Station Corporation cc:

Ellyn R. Weiss, Esq. Resident Inspector Harmon & Weiss U.S. Nuclear Regulatory Commission 2001 S Street, N.W. P.O. Box 176 Washington, D.C. 20009 Vernon, Vermont 05354 David J. Mullett, Esq. Carol S. Sneider, Esq.

Special Assistant Attorney General Assistant Attorney General Vermont Depart, of Public Service Office of the Attorney General 120 State Street One Ashburton Place, 19th Floor Montpelier, VT 05602 Boston, MA 02108 Jay Gutierrez Geoffrey M. Huntington, Esquire Regional Counsel Office of the Attorney General USNRC, Region I Environmental Protection Bureau 475 Allendale Road State House Annex King of Prussia, PA 19406 25 Capitol Street Concord, NH 03301-6397 G. Dana Bisbee, Esq. Charles Bechhoefer, Esq.

Office of the Attorney General Administrative Judge Environmental Protection Bureau Atomic Safety and Licensing Board State House Annex U.S. Nuclear Regulatory Commission 25 Capitol Street Washington, DC 20555 Concord, NH 03301-6397 Dr. James H. Carpenter Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 ,

Mr. Glenn 0. Bright Adjudicatory File (2)

Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Docket U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, D.C. 20555

l'eeting Minutes Fron The fiRC Staff's Inservice Test Program Review Meeting With Representatives of the Vermont Yankee fluclear Power Corporation Conducted October 14 and 15, 1987 A working meeting was held at the NRC Region I office in King of Prussia, Pennsylvania with representatives of the Vermont Yankee Nuclear Power Corporation er October 14 and 15, 1987. The purpose of the meeting was to discuss the staff's Request for Additienal Information (RAI) ques: ions resultinc from the staff's review of the Vermont Yankee's purp and valve inservice testirg (IST) progren. The staff's RAI questions were sent to the licensee by letter V. L. Rooney to R. W. Capstick on January 5, 1987. The staff's questiens served as the meeting agenda. Each of the staff's RAI questiens were discussed during the meeting.

The staff's RAI questions are indicated by the letter Q. before the cuestion.

The meeting minutes are given under "Comments". Pertinent licensee and staff contr.ents, explanations, understandings and clarfications are discussed in the minutes. For the najority of the RAI questiens the discussions provided the staff with the needed clarifications and infornation to allow the staff to cceplete the review expeditiously pending receipt of a revised program subnittal from the licensee. Where the licensee agreed to take specific action, for exampic, to revise er make changes to their IST program, en LAR (Licensee Action Required) follows the meeting minutes "Comments". Where the staff's RAI ouestion was resolved during the meeting discussion an R (Resolved) follows the meeting minute "Conuents". Several items that will require additional work to obtain resolution by either the licensee or staff nre listed as 01-L (0 pen Item - Licensee) or 01-5 (0 pen Item - Staff). These Open items were discussed in a conference call between the licensee and staff on October 28, 1987 and aerin on December 22, 1987 Both the staff and the licensee agreed to work for timely resolution of the remaining Open Items. The open items are tabuleted in the table that follows.

The purpose of these minutes are to document the results of the above tiscussions.

Tie participants were:

D. L. Caphton, NRC, Region I V. L. Rooney, fiRC, NRR Headquarters P. K. Eapen, NRC, Region I L. J. Prividy, NRC, Region 1 J. P. Durr, NRC, Region I J. Pelletier, Vermont Yankee D. Reid, Vermont Yankee G. Cappuccio, Verront Yankee K. H. Bronson, Verment Yankee T. C. Trask, Verment Yankee

At the conclusion of the meeting the staff requested that the Vermcnt Yankee IST program be revised to incorporate the reeded program revisiors within 60 days from receipt of the meeting minutes. The staff stated that the revised licensee's IST program submittal will be used to base the staff's final review and safety evaluaticn of the licensee's IST program.

OPEN ITEMS Valves YY IST Program Page Nurber Question Number Responsible V-7 Q.8 OI-L V-11 Q.2 OI S and 01-L V 14 Q.8 OI-L Y-16 Q.2 01-L Y-17 & 18 Q.1.b. 01-L Y-17 & 18 Q.3 OI-S and O!-L Y-17 & 18 Q.9 OI-5 and 01-L V 21 Q.7 OI-L NOTE: There were no Open Items for pumps.

PlH(2

1. Service Water Pumps P7-1A-D G191159 Sh 1 Q. The VP appears to be measurable, however, the program's pump testing does not indicate this. The listing should be revised.

Comments: LAR The licensee stated that the river water level provides the inlet pressure for these deep well centrifugal pumps. The licensee uses the inlet head and discharge pressure to arrive at the functional equivalent of UP. The licensee will provide an appropriate discussion in his revised program l

regarding WP and flow measurerent.

2. High Pressure Coolant Injection Pumps G191169 Sh 2

! HPCI Gland Seal Exhauster l HPCI Hot Well Condensate Pump l

j O. Discuss the safety related functions (shutting down the reactor or ir nitigating the consecuences of an accident) of these pumps. Provide a detailed technical justification for not including the pumps in the program.

Comments: R The licensee stated that the gland seal exhauster and hot well condensate pump are non-safety related and do not have a reactor shutdown or accident nitigation function, therefore, were not included in the program. The licensee stated that proper operation of these pumps are denenstrated by HPCI system cperation.

3. Standby Liquid Control Pumps Q. Is lubricant temperature measured in the pump crankcase or another location?

Comments: LAR No. The licensee stated that e generic relief request tc delete bearing temperature measurement will be placed in the IST program.

4 Core Spray Pumps Paf-1A/B

0. During outage testing, is the length of time of the pump run adequate to reasonably assure that no problems are beine experienced as a result of bearing heating? Note-this conment is applicable to the other pumps in the program that similarly have bearing temperatures that cannot be directly measured.

Commer.t s: R The licensee is requesting generic relief from measuremert of Pump Bearing Tcnperatures. The licensee stated:

"This P,elief Request Basis is consistent with the requirements of ANSI /ASME Standard OM-6. "In-Service Testing of Pumps", Draft 11, which does not require bearing temperature measurements.

ALTERNATIVE TESTING:

Pump mechanical condition can be determined much more accurately by neasuring bearing vibration. Para;>aph IWP-4500 requires at least one displacement vibration level be read during each in-service test. The number of readings will be expanded to a minimum of two in orthogonal directions. These additional readings, in addition to the revised vibration measurement nethods and acceptance criteria given in Relief Request Basis GP-3, will provide a viable means of nonitoring pump ncchanical condition."

5. RCIC Condensate and Vacuum Pumps Gl91174 Sh. 2 Q. Discuss the safety related functions of these purps. Provide a detailed technical justification for not including these pumps in your program.

Comments: R The licenrec stated that "these punps are non-safety related and provide no reactor shutdown or accident mitigation function. Therefore, they are not included in the program."

6. RECCW Punps Gl91159 Sh. 3 Q. The progran listing for the reference drawine shows sheet 1, the purps are on sheet 3.

Comments: R The licensee will correct the reference.

7. Emergency Diesel Generator Auxiliaries G191162

a. O. The diesel engine's fuel pump and clean oil return pumps are missing from the proaram.

Conments: R The licensee stated that the purps are not required for the safety related operation of the diesel. The staff agreed,

b. Q. In relief Request Basis P-12, Fuel Oil Transfer Pump Bearing Temperature measurement per IWP-3300, regarding alternate testing, l is it possible to check bearing temperetures by pumping to the 5000 gallon Fuel Oil Day Tank 41-1A for the heating boilers?

Comments: LAR The licensee will delete this relief request and provide a generic

relief request as discussed under 4. above.

8. Pump RRU-18 and G191175 Sh. 1 l Two check valves 16-19-101 (E-15) l and 16-19-103 l

l Q. What are the safety related functions of the purrp and two check valves?

l t

Cements: R The licensee stated that:

"Pump RRU-18 and check valves V16-19-101 and V16-19-103 are components of the Torus to Drywell Punpback System. This system is no longer in use and has been retired in place.

The lorus to Drywell Pumpback Systen was originally installed to maintain the 1.7 psid between the torus and the drywell. This differential pressure along with proper torus water level assure the integrity of the torus when st.t,jected to post-LOCA suppression pool hydred3nanic forces.

The drywell-torus differential pressure is now maintainec' by use ni the Nitrogen Ir.erting Supply System.

Valves V16-19-102, 103, 105, 106 and 109 are normally closed, the breaker for FPU-18 is open and the discharge piping downstream of valve V16-19-101 has been cut and capped."

9. Q. What is the technical justification for not including the Torus to Drywell pumpback system in the IST program? (No drawings provided).

Coments: R

'he licensec included his response to this cuestion with question 8.

above.

10. Q. Describe ary functions that the Dr.well Floor Drain pumps P-11 A/B and the Dryvril Equipment Drain pumps P-15-A/B have in shutting down the reactor or mitigating the consequences of an accident.

Coments: R The licersee stated that these pumps are isolated during accident conditions and serve no safety function or accident mitigation function.

Valves V-4* S_ervice Water System Dwg. G191159 Sh. 1&2

1. Valve V 70-1A-D and Relief Request Basis RRB-V1 (B, H-3)

a. Q. The relief request lacks specificity regarding frequency of exercise testing. The time period shculd be specified.

Reference IWV-3521. (Note: 24 renths is normally the maximum relief that the staff will consider.)

• The V-4 number is the page nurber in the licensee's IST progran.

. c. .

General tlcte applicable to all relief requests: Relief recuests should clearly specify what specific relief is being requested including the detailed technical basis for the specific relief being requested. Revise relief requests accordingly.

Comments: LAR The licensee stated that at least two tests will be conducted annually on each of the check valves with at least three ncnths between tests. Tbc relief request will be revised to include the basis for this testing frequency.

b. O. Is there a leakage requirement established fer these valves in the closed positior? Is prompt closure verified?

Coments: LAR The licensee stated that no specific valve leakage requirement is necessary to meet syster performance criteria.

The minimum systen performance requirement for each pump is 2700 gpm against a TDH of 250 feet (TS 4.5.D.1) This will be incorporated into the IST program.

Prerpt closure of each check valve will be verified by visual ooservation of system pressurc indicators end by observing that the non-operating pump is not wind milling.

2. Relief valves in Service l'ater System Q. Provide detailed justification for not including the service water system's relief valves in the IST prcgram and testing in accordance with IWV-3510e Cements: R The licensee stated that the subject relief valves serve as thermal reliefs and as such these valves do not perform a specific function in shutting down the reactor or in nitigating the consequences of an accident.

3. RHR Motor Cooling Q. What is the technical bases for not including: check valves 181 XC (4 total, one for each motor) and Solenoid valves SE-70-4C (4 Total)?

Comments: LAR The licensee stated that the above valves wili be put into the progran for testing as follows:

Check valves 181 XC will be designated Category C.

Solenoid valves SE-70-4C will be designated Category B.

The licensee will submit a relief request on timing for the solenoid valves.

4. Valves V 70-84A and 84 B Reference G191159 Sh. 2) (B and H-3).

Q. L' hat is the safety related function of these velves?

Comments: R The licenste stated tFat these valves have no safety related function.

These valycs crovide an alternate cooling path to the station air compressors.

5. Emergency Dierel Generator Cooling L. Check Valve 70-1 (B-9)

Q. This check valve is not in the program, however, the pesition of the valve appears to be of safety related importance to assure a heat sink for the emergency diesels and as such should be tested as a Categcry C valve.

Corrents: R The licensee stated that the valve is a marcally operated butterfly valve and is not required to be cperated to assure a heat sink for the EDGs.

b. Fill Valves On Expansion Tanks SE-70-2A? (Drawing has no numbers) (F-8)

SE-70-2B (C-5)

Q. These valves are not in the program, however, appear to have safety importance to assure cooling of the EDGs. The valves should be included in the program and tested.

Comments: R The licensee stated that these valves do not perform a safety function therefort are not included in the program. The tanks are equipped for nanual makeup and have a level alarm to alert operators if a level problem occurs.

6. Q. Line 24" SW 1B (Dwg. G191159, Sh. 1) appears to connect to 8" SV 1FE (Dwg. G151159, Sh. 2) at match line A, however, there is no reducer shown.

Is there a missing drawing? Also there is no 24" SW 1B in the "Piping Line List".

Also the 18" SW 12 line goes to 20" SW-127 Same question?

Comment: LAR The licensee stated that the subject service water drawings are flow diagrans and were not intended to show the detail pipirg configurations.

The first entry in the Dwg G191159, sheets 1 and 2 is being corrected to show SW-1A-D vice SW-1A&D, otherwise the drawings fulfill their intended purpose.

V-5 Reactor Building Closed Cooling Water

1. Relief Valves G191150 Sh.3(A-4)

RECCW HX's SR 70-1A/B Q. Previde detailed technical justification for excluding these two relief valves from the program.

Comments: R The licensee stated that these valves are thermal relief valves and therefore are not required for safe shutdown or accident mitigation.

2. Air Operated Valve (D-8)

LCV-1 Q. Does this valve operate to make up systen losses of inventory?

Does the valve fail open upon loss of air?

Comments: R The licensee stated that the valve does operate to make up system losses of inventory as an operations aid. It fails closed upon loss of air. The valve is not required to shutdown the reactor or to mitigate the consequences of an accident. The tank is equipped with a low level alarm which annuncietes in the control room thus allowing for manual makeup if needed.

i

~

i

\

.g.

l V-7 Service and Instrument Air, Diesel Generator Starting Air System, Dwg. G-191150 Ref. Sh. 7

1. Pressure Relief Yalves (unnumbered) on EDG Air Receiver Tanks, cre on each tank, four total. (Ref. Sheet 7 of 7)

Q. Provide your detailed technical justification for not including these valves in the IST program and testing per IWV-3510.

Comments: R The licensee stated that these relief valves are not required to operate in shutting the reactor down or in mitigating the consequerces of an accident.

2. Check valve unnumbered in line frer air receiver to motor pressure switch, one for each air receiver. (Ref. Sheet 7 of 7).

Q. Provide your detailed technical justification for not including these valves in the IST program and testing per IWV-3510.

Comments: R The licensee stated that these instrument line valves do not perform a function in shutting down the reactor or in mitigatirp the consequences of an accident.

3. Pressure Relief Valves (unnumbered) on air corrpressors, two total.

Q. Provided your detailed technical justificction for not including these valves in the IST program and testing per IllV-3510.

Coments: R The licensee stated these valves do not perform a function in shutting down the reactor or in mitigating the consequences of an accident.

4. EDG Air Start Solenoid Valves (Colt Industries Dwg. 1185383)

Q. Provide your detailed technical justification for not including these valves in the IST progran anc testing per IWY-3400.

Coments: LAR The licensee stated that these valves will be added to the program as Cateoory B valves and full stroke exercised quarterly during diesel generator surveillance testing. A new relief request will be generated since the valves are fast acting valves and difficulty exist in the measuring and trending of stroke times.

5. Yalve V72-78 A-D and V72-80 A-D Dwg. G191160 Sh. 7 Q. Do these valves have to meet a leakage criteria to protect against the loss of receiver redundancy?

Comments: R The licensee has not reauired these check valves to teet a leakage criteria. The proper closure of the check valves is determined by their capability to maintain normal receiver pressure without excessive running of the compressor.

6. Relief Request Bases V5 Q. Revise to show compliance with requirement of IUV-3423 regarding adjusting to functional maximum pressure differential value.

Comments: LAR The valves are currently tested at accident pressure of 44.0 psig.

The licensee stated that a generic relief request bases will be provided in the program te satisfy compliance with IWV 3426 and IWV-3427.

7. Instrunent Air Systeni Ref. G1911f0 Sh. 4 Q. Whet is the safety function of check valves:

Check valve next to V 72-154 and unnumbered (L-6)

V 72-51A V 72-155 (Check valve is next to and unnunbereo)

V 72-86A Y 72-868 V 72-51B V 72-49A V 72-49B V 72-67A V 7?-67B Comments: LAR The licensee stated that the unnumbered valves are V72-154C and V72-1550. The drawing is being corrected to incorporate the numbers.

The licensee stated that none of the listed valves perform safety functions required to shutdown the reactor or mitigate the consequences of an accident.

l

6. Relief R:cuest Basis V6 Dwg.G191160 Dh. 3 (V.-12 and 15) for Valves V72-89 B/C Q. Relief request as written does not show compliance with exercise testing frequency under IWV-3522. Revise to meet Section XI.

Note: The leak test requirenent Ref. RRB-V5 needs to be revised to comply with IWV-3426 and IWV-3427, Analysis o? Leakage Rates and Corrective Action, respectively.

Comments: LAR and CI-L The licensee stated that the subject valve closure will be verified during Appendix J testing on a refueling frequency.

Rectrding Paragraph IWV-3426, Analysis of Leakage Rates:

The licensee stated that leakage rates for valves beirg tested under

/ppendix J are covered by Appendix J and the Technical Specification.

Regarding IWV-3427, Corrective Action:

The licensee stated that a r,ew relief request will be included in the progran to cover Vermont Yankec's pcsition for compliance with IWV-3427 (and IWV 3426). ,

The staff stated that the licensee's prcoram must be equivalent to or more conservative than IWV-3427 in order to be acceptable to the staff.

Note: The code IUV-3427, Corrective Action, requires for poor performers (leaking valves) that testino bc at increased frequency, i.e., cold shutdown. The code stipulates repair or replace valves that will exceed the maximum permissible leakage rate by gretter than 10% on a cold shutdown frequency. Vernont Yankee's response focus is refueling frequency as opposed to the Code. Open item for the licensee.

9. Check Valve V72-103 Dwg. G191160 Sh. 3 Q. What is the basis for specifying the valve to be passive? The valve is categorized as AC, however, the exercise requirements are r,ct specified.

Comments: R The licensee stated that the subject instrument air system check valve is considered passive as it is not required to change positien to accomplish its safety function of containment isolation. A normally blanked off spectacle flange and other norna11y closed valves isolate the instrument nitregen subsystem from the instrument air systen.

10. Check valves

0. What is the safety related function of these valves?

V-72-70 A/B G191160 Sh. 3 (L-17)

V-72-26 A/B G191160 SS. 3 (L-12)

Y-72-26 G/H G191160 Sh. 3 (L-11)

V-72-68 A/B G191160 Sh. 3 (J-11)

V-72-37 A/B G191160 Sh. 6 (L-7)

Corrents: R The licensee stated that none of the subject valves perform a safety function to shutdown the reactor or maintain the reactor in a safe shutdown condition or to miticcte the consequences of an accident.

V-8 Emergency Diesel Generator Fuel Oil System Dwg. Gl9116E

1. Q. is valve LCV-3 (D-5) required to opcrate at anytir.e the EDCs are responding to an accident condition?

Comments: R The licensee stated that the subject valve is normally closed ard fails, closed upon a less of instrument air. Pest surveillance testing has shown EDG operability not to be affected regardless of the valves position. The valve is not required to operate during accident conditions.

2. Relief Valves 3A and 3B (C-4)

Q. Provide detailed technical justification for not includirg these valves in the program and testing per IWV-3510.

Ccmments: R The licensee stated that these valves do not perform a safety function to shutdown the reactor or mitigate the const JJences of an accident.

3. Q. Two relief valves and four check valves are shown on the drawing at the EDG. Provide your detail technical justification for not listing the valves in the progrtm.

Cennents: R The licensee stated that for these valves proper operation is verified during the current surveillance testing of the engines.

4. Clean Oil Tank (D-10)

a. Q. How is the tank vented?

b. Q. Are there any check valves installed in the pump discharge piping?

Comments: R The licensee provided a sketch of the cleen oil tank and piping. The l tank is vented to atmosphere from a standpipe placed at the top of the tanks.

l There are no check valves. The tank cc11ects cletr cil leakage from I

around the diesel. The licensee stated that failure of the clean oil pump would not preclude the diesel from performing its scfety related function.

5. EDG Lube Oil System Q. What are the drawing nutbers that shcw this system? (No drawings were provided.)

Conments: R The EDG lube oil system is shown on drawing 5920-4150.

V-9&l0 Nuclear Boiler G191167

1. Relief Valves SR2-14E-L and RRR V7 (L-11)

0. Under 'Alterrate Testing", RRB V7 shculd also specify exercise testing during refueling outages.

CommenM: LAR The licensee stated that program definition will be provided to show that the cold shutdown definitier will include refueling cutages.

2. Relief Valves SR2-14 A-D (L-11)

Q. Provide your technical fustification for not testing these relief valves.

Comments: R The licensee stated the.t Safety Relief Valve Discharge Line (SRVDL) vacuum breakers SR-14 A-D do not perform a safety function and need not be included in the IST Procran.

In 1980, Vernent Yankee nerformed codificaticns to the torus and P.ssociated LOCA load mitigation equipment as a result of the liark I Containment Long Term Program.

Analyses on the safety relief valve discharge lines indicated that the 2-inch vacuum breakers (SR2-14 A-D) did not have enough throat area to equalize SRVDL-Drywell pressure without the occurrence of a very high water leg in the line. This water leg, in turn, would produce intolerable thrust and dynamic pressure loads on the piping.

To reduce these loads, two redundant 10-inch vacuum breakers were installed in each line to replace SR2-14 A D.

Vicuun breakers SR2-14 A-D were retired in place and need not f urctier to aid in shutting dov:n the reacter or in mitigating the cor: sequences of an accident. The eight new vacuum breakers, SR2-14 E-L, are included in the IST program.

3. Valves V2-37A (check) (E-7)

SIA (solenoid operated) (C-8)

Q. Provide your dett.iled technical justification fer not including these valves (one set for each relief valve).

Comrients: LAR The licensee stated that these valves will be added to the progran and will be tested on a refueling frequency, a relief request will be provided to support the refueling frequency surveillance testing.

4 RRB V 11 For Safety and Relief Valves

0. The VY testing frequency of testing all valves every two refueling outages is more conservative than the Code frecuency of testing all valves every five years. However, the relief reauest does not adequately address the IWV-3513 additional test aspects regarding corrective action to be taken in the event a failed valve is identified. The relief request states that additional testing is unreasonable per !WV 3513, however, provides no bases for handling the failure issue. Provide your technical bases for hanc' ling the valve failure issue and specify alternate requirements.

Comments: LAR The licensee stated that failure of the Main Stean Safety of Relief Valve to function within the required parameters on test would result in the analysis and reporting of such failures in accordance with the Licensee Event Report systen. 10 CFR 50.73. Per 10 CFR 50.73(b),

each LER shall contain an assessment of the root cause, safety consequences and implications of the event and a description of any corrective actions planned as e result of the event, including the need for additional testirg and steps to be taken to reduce the probability of similar events occurring in the future.

The licensee will revise the relief request bases to address the part of the code that is practical and not practical to be met.

5. Feedwater Valves V2-27A (F-3)

V2-96A (H-3) and RRB V8 Q. These valves should complete with the analysis of Leakage Rates and Corrective Action Requirements, Paragraphs (IWV-3426 and IWV-3427, respectively. The relief request should be revised accordingly.

Comments: LAR The licensee respended to this item subsequent to the meeting in a telephone discussion between the staff and Don Reid and others on October 28, 1987.

The subject two outboard feedwater check valves will be local leek tested under Appendix J on a refueling frecuency. The valves will be full stroke exercise tested to the open and closed positions on a refueling frecuency. An appropriate relief request will be provided.

A generic relief request will be provided to cover Vermont Yankee's position for compliance with IWV-3426 and IWV-3427.

The staff stated that the licer. sees program would need to be equivalent to or nore stringent than IWV-3426 and IWV-3427 in order to be acceptable to the staff.

6. Feedrater check valves V2-28 A/B (F-4)(H-4) and RRE V9 Q. Note: Valves have a safety related function to close as an isolation valve ard a safety function to open upon HPCI & RCIC injections. No relief from quarterly exercise testing was included.

Do you intend to exercise quarterly?

The valves should comply with the analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and IWV-3427, respectively. The relief reouest should be revised accordingly.

Comments: LAR The licensee provided an additional response to this item subsequent to the meeting in a telephone discussion between the staff and Don Reid and others on October 28, 1987.

\

The licensee stated tFat the subject two inbeard feedwater check valves had received an exemption from leak rate testing under Appendix J. (Reference SER by letter D. G. Eisenhut, NRR, to J. B.

Sinclair, VYPC dated August 19, 1983). The licensee stated that the motor operated feedwater heater valves would be closed as backup in the event containment isolation is required. Closure of the motor operated heater valves is also recuired under Appendix J whenever containment isolation is required (reference the August 19, 1983, SER).

The licensee stated that the subject valves will be exercised to the full cpen position at startup and an ALARA bases for not full closure exercising would be provided. The licensee also stated that the valves have a hatd seat and require a high pressure to seal tFtr:

closed. The piping configuration further makes it impractical to cerduct a pressure test te verify closure.  ;

7. Process Sampling Valves V?-39 (L-4)

V2-40 (L-3)

RRB-VS Q. These valves should comply with the analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and IWV 3427, respectively. The relief request should be revised accordingly.

Coments : LAR The licensee stated that these Code requircrents would be covered by a gercric relief request.

8. Stean Drain Yalves:

V2-74 (D-10)

V2-77 (0-13)

a. Q. Provide your detailed technical justification for not exer-cising and stroke time testino these Category A valves.

b. C. The valves rust comply with the Analysis of leakage Rates ard Corrective Action Requirement, Paragraphs IWV-3426 and 3427, respectively.

c. Q. The relief request RRB-V8 needs revising accordingly.

t

i .

Comants: LAR The licensee stated:

a. The valves are presently exerciced and stroke tined. The progran valve listing will be revised tc reflect this testing.

b. These code paragraphs will be covered by a generic relief request.

c. The relief request RRB-V8 will be deleted.

9. ItSIVs VE-80 A-D (D, F, G, H-10)

V2-86 A-D (D, F, G, H-13)

a. Q. The valves must comply with the Analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and 3427, respectively~ Revise the relief reauest RRV-Y6 accordingly.

Corrents: R The licensee 3tated that a generic relief request will be provided to cover Verr.ent Yankee's position regarding ecmplianco with IWV-3426 and IWV-3427.

10. Excess Flow Check Valves G191167 SL-23 (C-3)

SL-301F (D-3)

SL-201B (D-3)

SL-301A (D-3)

SL-301E (D-3)

SL-97B (f t-12)

Q. Describe the safety related function of each of these check valves.

Coments: R The licensee stated:

SL-23 This valve is not required for reactor shutdown er accident mitigation.

SL301 A, B, E, F and SL-97B These valves were previously used on reactor coolant pressure indicating lines and the indications and connections to the reactor coolant systen has been deleted by a design change. They are not required to be operable and now perforn ne safety function. Yalve SL-97E has a closed manual isolation valve (RV-988) ,

upstream of it and is therefore also not required.

1 - _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

11. MSIV' Supply Check Valves IA 87 A-D (B-12)

CA 87 A-D (B-10)

Q. Provide detailed technical justification for not including those valves in the program. '

These valves appear to assure that the MSIV accumulators remain at pressure in the event of a loss of heador pressure. They appear to be Category C valves.

Cor1 cents : LAR The licensee stated that these check valves are not needed to function for the MSIVs to perform their safety function since the 11SIVs are spring loaded "fail safe" to close. Baced upon this, the valves are not required to be in the IST progran.

The licensee also stated that the raain Steam relief valve air supply accumulator check valves, V2-37A-D, do perform a safety function, are presently tested and will be added to the IST program. The licensee will request relief from IWV-3426, analysis of Leakage Rates, for these vcives based upon a previous staff safety evaluation letter, Vacca11o, NRC, to Capstick, VYNPC, dated March 4, 1985. The licensee intends to meet IWY-3421 to derenstrate seat leak tightness.

V-11 Core Spray System Reference Drawing G191168

1. SR 20 A and B Safety Relief Valves Q. Provide a detailed technical basis for not including these valves in the program and testing per IWV 3510?

Connents: R The licensee stated that the subject relief valvos are not required to perform a specific furetion in shutting down the reactor to the cold shutdown condition or in mitigating the consequences of an accident.

2. MOV 12 A and 12 B (Outside containment)

Check Valves V13A and V13B (Inside containment)

Q. These valves provide the redundant barrier between high and low pressure piping. Provide detailed technical justification for not designating as Category A and leak testing.

s Ccmments: 01-5 and LAR The licersee stated that the subject valves will be designated Category A for the motor cperated valves and Category AC for the checks valves.

The licersee does not individually leak test these valves. The 12A and 128 valves have continuous pressure monitoring downstream which is an acceptable method to the staff fer determinir.g their leak tight condition. However, the leak tight condition of the check valves 13A and 13B is not assessed via leak testing. These check valves provide redundancy for protection of the icw pressure piping.

The hRC Committee to Review Generic Recuirements (CRGR) currertly has under gereric review requirements for pressure isolaticn valves that ccmprise the berrier between high pressure and low pressure piping.

Pending the findings from the CRGR regarding this natter a staff position regarding leak rate testing of check valves 13A and 13B can be made.

This is an open iten for the staff and licensee.

3. MOV - V 7A and 78 (CS Pump Suction)

Q. What functien(s) do the valves serve to mitigate the consequences of an accident. (The valves are not in the IST program).

Comments:

R The licensee stated that these valves do not perform a safety function. The valves receive no automatic initiation signals and are open during post accident conditions for cperation of the system.

4. Excess flow check valve SL-25 Q. Why is this valve net tested similarly to SL 31 A&B7 (The valve is not or relief request RRB-V16).

Comeents: R The licensee stated that the valve is included in the program as valve 2-3-25 under V-26 Nuclear Boiler Vessel Instrumentation. The valve is covered by RRB-40.

5. Check Valves 33A and 33B (CS pressurizing lines)

Q. Do these valves close to mitigate an accident? Discuss their l function.

l

Conments: LAR The licensee stated that these check valves must c1 e 'o assure that core spray flow does not bypass the core. The valve.. must open to permit flow into the core spray piping. The licensee will add the valves to the IST program to verify their proper operatien. A relief request will be incorporated into the IST 3rogram to cover what testing is/is not practical for these chec( valves.

V-12-14 High Pressure Coolant Injection System (HPCI) G191169, Sh. 1 1 Steen Valves and RRB-V17:

YP3-15 (E-5)

! V23-16 (F-7)

O. The valve rust comply with the Analysis of Leakage Rates ard corrective Action Requirements paragraphs IWV-3426 and 3427, respectively. Revise the relief request RRB-V17 accordingly.

Comments: LAR The licensee stated that a new relief request will be included in the IS' program to cover valves being leak tested urder Appendix J.

The staf# will consider the relief request to be acceptable provided the licensee's program is equivalent to or more stringent than IWV-3426 and 3427,

2. Excess Flew Check Valves:

SL 23-37 A-D er A-L (F, G-5)

Q. Which is cor rect? The "Valve No." listing appears to have a typo.

The drawing reflects A-D.

Comments: R The licensee stated that SL 23-37 A-D is correct and the listing has been corrected.

3. Check Valve; and RRB-VPO: (N-7)

V 23-61 Q. The relief request basis wording is unclear regarding essuring that the valve's exercise test assures the exercising of the valves to the full open position.

.. . _ ~ -

l

, Comments: LAR The licensee stated that the relief request RRB-V20 will be revised to specify full stroke exercising.

4 Check Valves (K-5)

V 23-12 and V 23-65

-Q. These valves need to open to drain condensate and the exhaust steam drain pot. Provide a technical just!fication as to why the valves aren't exercise tested?

These valves also appear to perform a centainment isolation function; if so, should be Category AC and comply with IWV-3426 and IWV-3427.

Comments: LAR The licensee stated that both valves are in the IST program and are exercised tested during the monthly technical specification required HPCI test at full flow.

The check valves will be designated AC. The licensee will leak test in acenrdance with Appendix J and will provide a generic relief reauest regarding compliance with IWV-3426 and IWY-3427.

The staff will consider the relief request to be acceptable provided the licensee's program is ecuivalent to or more strineent than IWV-3426 and 3427.

The licensee stated that valves SSC-23-13 and V23-36 will also be added to the IST progran and be designatec Category AC.

5. Check Valves ( s'-3 )

V 23-842 and V 23-843

0. These valves appear to be needed to open during HPCI operation, if i so, they should be exercised tested. These valves also appear to perform a containment isolation function, if so, should be Category AC and comply with IWV-3426 and IWV-3427.

Comments,: LAR Tbc licensee stated that the subject valves will be added to the IST progran and dasignated Category AC. The valves will be full stroke exercised during HPCI operation.

The licensee will incorporate a generic relief request relative to ,

natting IWV-3426 and IWV-3427.

t

- , -n -

,x

6. Relief Valves G191169 Sh. 2 Y 23-34 (D-9)

V 23-66 (J-12)

Q. Provide detailed technical justification for not having these valves 'n the IST pregram, and testing tbc valves as required by IVY 3510.

Comments: R The licensee f.tated that the subject valves are not required to operate for safe shutdown or to nitigate the consequences of an accident.

7. Air Operated Valve V 23-54 (V.- 12 )

O. Provide detailed tecnnical justification for not having the salve in the I.*T program and designating Category B.

Ccaments: R The licensee stated that operation of V23-54 is net required and has no inpact on HPCI operation. It is not required to operate for rafe reactor shutdown or to mitigate and accident.

C. Check Valves (L-11)

V 23-130 and V 23-131 Q. Provide detailed technical justification for not having these valves in the IST program and designating es Category C valves.

Comments: OI-L The licenseo stated that edditional review will be required to retoive the staff concern. Open item for the licensee.

9. Air Operated Valves G191169 Sh. 2 V 23-39 and 40 (M-11)

Q. What is the safety related function of these valves?

Coninents: R The licensee stated that these level control valves are not necessary for proper HPCI operation. The valycs function during HPCI standby conditions therefore are non-safety related.

1 t

k a i

10. Drain Valves G191169 Sh. 1 (F-17 & J-1)

V 23-53 (Air Operated) (H-17)

Y 23-42 (Air Operated) (J-16)

V 23-43 (Air Operated) (J-16)

V 23-149 (Check Valve) (I-16)

Q Provide detailed technical justification for not having these valvet in the IST prcgram.

_ Comments: R The licensee stated that the subject. values are not required for HPCI cperation. The valves serve to drain condensate fron the HPCI turbir.e steam supply line, however, if a high level occurs in the steam supply line drain pot a high icvel alarm is annunciated in the control roon.

V-15 Control Rod Drive Hydraulic System G191170

1. Valve V3-101 and RRB-V22 J-21

0. The relief request needs to incorporate testing at refueling frequency in addition to cold shutdown.

The program's velve listing drawing cccrdinates should be J-21, not I-21 Comments: LAR The licensee stated that definition will be made in the program to reflect testing during refueling in addition to cold shutdown. ,

4 The cccrdinates in the IST Program will be corrected te show J-21.

2. Valves V13-115 (B-16)

Q. The charging header check valver are active during reactor scrams to aid in control rod inserting and safe reactor shutdown. Provide detailed technical justification for not including these valves in the program.

Comer 3's: LAR The licensee stated that the check valves will be put into the IST progran as Lategory C and tested to assure that they will ge to the full open rosition.

2

. V-16 Standby Liquid control System Drawing No. G191171

1. Relief Valves SR-39A and 39E (G, K-7)

Q. These valves should be designated Category C and tested per

!Wy-3510.

Ccreents: R The licensee stated that these valves do not operate to shutdown the reactor or mitigate the consequences of an accident. The valves are required to be tested under the technical specification 4.4 A.2. to verify that their set point is between 1400 and 1490 psig.

2. Check Valves Y 11-16 and 17 (G and H-2)

Q. Relief Request Basis V24 refer to TS Table 4.7.2.b applicable to centainment isolation velves as opposed to component operational readiness testing under Section XI, IWV-3400. Provide cetailed technical justification for not testing in accordance with Section XI.

Corrents: LAR and OI-L Tho licensee stated that the valves are exempt from local leak rate i testing ur. der Appendix J. These check valves (Category AC) are 1ccated at the primary containment boundary, one located inride and one located outside. The SBLC explosive valves, located outside containment, seal the lines normally.

Powever, the staff's cercern is that once the explosive valves are fired cnd the SBLC system has exhausted its supply or is shutdown for any reason, the subject valves wculd be needed to close and seal actinst an event where reactor p.aessure remains elevated. None of the remaining SBLC valves are leak tested under the IST program.

There is low pressure piping upstream including tanks that are vented to the atmosphere. Leak testing of the subject two check valves is an open item for the licensee.

V-17 &l8 Residual Heat Removal System G191172

1. tiotor Operated Valves: Y 10-17 and RRB Y26 (G-8)

V 10-18 (F-8)

a. Q. The relief request needs to clearly state the detailed technical basis for the specific relief requested. The relief request basis states that the valves are presently exempted, per Tech. Spec. Section 4.7.2 from leak testing, however, a basis for this staten4nt has not bcon found.

t Comments: LAR The subject valves are reactor coolant systen high to low pressure piping isolation valves. Valve V10-17 has pressure nonitoring down stream which is acceptable to the staff for determining the leak tight integrity for this valve.

The licensee stated that valve V10-18 does not receive a leak test.

During the mee;9,'J the staff discussed using an existing 3/4 inch line, below valve '<10-18 as a possible way to monitor icek tightness of the valve.

During a followup telephone discussion on December 22, 19E7, the licensee comnitted to running a leak test on MOV V10-18 by monitoring leakage through the 3/4 inch line when the vessel hydro is conducted at a refueling frequency. This will provide resolution to this staff's concern.

b. O. These valves must cerply with the Analysis of Leakage Rates and Cerrective Action Reevirements of the Code paregraphs IWV-3426 and IWV 3427. <

Comments: OI-L The licensee needs to reevaluate their response to IWV-3426 and IWV-3427 for the subject valves. Open item for the licensee.

2. Valves: Y 10-26A/B (C-7)(C-11)

Q. Same comment as 1.a. and b. above.

Comments: LAR The Icek rate testing requirrtents of Appendix J apply. The staff notes that the subject drywell spray valves have been exenpt from Appendix J type C leak rate test.

3. Valves V10-27A/B (D-6)(D-12)

0. These valves are the first closed gate valves off of the reactor coolant loeps to protect low pressure piping. Provide detailed technical justification for not designating as category A and leak j testing. (Reference GDC-54) l l

l p

Comment s: 01-S and 01-L This valve is the normally closed high pressure motor operated globe valve protecting low pressure piping downstream and as such should be designated Category A. There is one normally closed check valve between the reactor coolant system and the subject valves. The licensee does nct leak rate test the subject valves ner has it been shown that pressure ronitoring dcwnstream is capable of ascertaining the valves leak tight condition.

The NRC Connittee to Review Generic Pecuirenents (CRGR) currently has under review requirements for pressure isolation valves thet comprise the barrier between high pressure and low pressure pipinC. Pending the firdings from the CRGR reoarding this matter, a staff position on leak rate testire of the subject valves can be made.

Open item for the staff and licensee.

4. Valves V10-31A/B (C-B) (C-10)

Q. Same comment as 1.a. & b. above.

Comments: LAR The leak rate testing requiremerts of Appendix J apply. The staff nctes that the subject dry well spray valves have been exempt frem 4

Appendix J type C leak rate test. L

5. Yalve V 10-32 (C-9)

Q. Sar,e comment as 1.b. above.

Conmentf: LAR The licensee stated that a new relief request will be included in the IST program to cover valves being leak tested uncer Appendi.< J.

The staff will consider the relief request to be acceptable provided ,

the licensee's program is equivalent to or more stringent than IWV-3426 and 3427.

6. Valve V 10-33 (A-7)

Q. Same comment as 1.b. above.

Comments: LAR Same response at item 5. above.

s 4

t r . - - .

-?7-

7. Valves V10-34 A/B (E-4) (E-14)

Valves V10-38 A/B (E-4) (-13)

Q. These valves are the first normally closed valves cening from the suppression chamber (Reference GDC-54). Same comment as 1.a. and 1.b. above.

Comments: LAR The leak rate testing requirements of Appendis J apply. The staff notes that the subject torus spray and level supply valves have been exempt frem Appendix J type C leak rate test.

C. Valves V10-39 A/B (D-4) (D-14)

e. Q. Sare comments as 1.a. and 1.b. above. (Note: this is the second valve from containnant.)

Comments: LAR The Icek rate testing requirement of Appendix J apply,

b. Q. Provide deteiled justification for not quarterly stroke testing these valves.

Comments:

LAR The licensce stated that the valves are quarterly stroke tested.

The progran will be corrected to reflect quarterly stroke testing.

9. Check Valves V10-46 A/B (E-7) (E-11)

Q. These valves are listed as Category C, however, they are the inside containment isolation valves and should be categcrized as AC end leak tested to assure protection of low pressure piping.

Comments: 01-S and 01-L The valve is a normally closed check valve serving as a pressure isolation valve protecting low pressure pipirg downstream. This is the first normally closed valve from the reactor coolant system.

The valve should be designated Category AC. The licensee does not  ;

leak rate test the subject valves neither is there continuous l pressure ocnitoring dewnstream.

l t

t

l-The NRC Comittee to Review Generic Requirements (CRCR) currently has under review recuirements for pressure isolation valves that cerprise the barrier between high pressure and low pressure piping. Pending the findings froc CRGR regarding this matter a staff position ,

regarding leak rate testing of the subject valves can be made.

Open item for staff and the licensee.

10. Valves V10-89A/B (M-1) (L-17)

O. Do the valves have a fail safe positicn and if se, are they exercised to this position?

Comments: R The licensee stated that the valves have no fail safe position. They are remote manually operated.

11. Valves V10-16 A/B (I-5) (1-12)

Q. These valves are the first isolation valves outside containment ard as such appcor to be Category A as they serve an isolation function (Reference GDC-54). Provide detailed justification for net designsting Category A.

Coments: R The leak testing recuirements of Appendix J apply. The staff notes that the subject valves have been exenpt from Apendix J 1eak rate testing,

17. Check Valves V10-19 A-D (X-6 & 12)

(J-6 & 12)

c. Q. These valves are the second isolation valves outside of centainment and as such it appears these valves should be Category AC and leak tested.

! Coments: R The leak testing requirements of Appendix J apply. The staff notes that the subject valves have been exempt from Appendix J i l leak rate testing,

b. Q. It is not clear (Reference Note 6) that the exercise testing l verifies full opening of these valves.

Coments: LAR i

The licensee stated that Note 6 will be revised to reflec.

proper opening of the valves.  :

l

13. Relief Valves V10-SR-35 A/B (D-2) (D-15)

V10-SR-40 (G-8)

V10-SR-72 A/B/C/D (K-7) (K-11) (J-7) (J-11)

V10-SR-80 A/B (K-3) (K-14)

Y10-SR-86 A/B (K-3) (K-14)

V10-RV-210 A/B (D-12) (D-5)

Q. Provide detailed justification for not designating these valves Category C and testing per IWV-35107 Cenn:ents: R The licer.sen stated that the subject valves are not required to cpcrate for safe reactor shutdown are to mitigate the consequences of an accident. The valves serve a thermal relief function.

14 Itotor operated Valve V10-20 (H-4)

Q. This valve hcs a safety function as described in FSAR 4.8.5 "to supply either loop frem the pumps in the other loop". Its operational readiness should be verified and, therefore, included in the progran.

Ccaments: LAR This licensee stated that the subject valve does not perform a safety function. The motor leacs have been disconnected. The licensee stated that the FSAR will be updated.

15. Valves y 4

V10-15A/9/C/D (K-7) (K-10) (J-7) (J-10)

Q. Arc these valves used to bring the reactor to a cold shutdewn condition or in mitigating the consequences of an accident? If so they should be included in the program.

Contents: LAR The licensee stated that the shutdown cooling suction valves are required to open to provid? shutdown cooling. The valves will be included in the IST program as Category B valves.

16. Valves V-10-13A/B/C/D (K-8) (K-9) (J-9) (J-8)

Q. Are these valves used to bring the reactor to a cold shutdown cendition or in nitigating the consequences of an accident? If so they should be included in the program.

Conments: LAR The licensee stated that these valves are required to close when the  !

RHR systen is aligned for shutdown cooling and will be included in the IST program and designated as Category B valves.

V19-21 Reactor Core Isolation Cooling System (RCIC) G191174, Sh. 1

1. Motor Operated Valves and RRB-V30 V13-15 (D-7)

V13-16 (D-8)

Q. The staff position is that the Category A valve leak rate ,

requirements are fulfilled by 10 CFR 50, Appendix J, requirerents for CIVs and that relief from the Section XI leak rate testing require-ments presents no safety problen. Howevar, the licensee rmst comply with the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs IWV-3426 and 3427 unless specific relief is requested from these paragraphs and subsequently granted by NRC. Revise the Relief Request.

1 Comments: LAR The licensee stated that a new relief request will be included in the IST progran to cover valves being leak tested uno'er Appendix J.

The staff will consider the relief request to be acceptable provided the licensee's program is equivalent to or more stringent than IWV-3426 and 3427.

2. Check Valve V13-22 and RRB-V31 (G-9)

Q. Frequency does not include refueling frequency or (24 month maximum).

Revise relief request and testing frequency.

Comments: LAR The licensee stated that their definition is that a refueling outage is a subset of cold shutdown. The licensee will provide definition in his program to clarify this intent.

3. llotor Operated Yalve V13-41 (N-10)

Q. If this velve serves a containmer.t isolation function with a specified leak rate, it shculd comply with IWV 3426 and IWV-3427 (reference item 1.

above). ,

Comments: LAR The licensec stated that a new relief request will be included in the IST progran to cover valves being leak tested under Appendix J.

The staff will consider the relief request to be acceptable provided the licensee's progran is equivalent to or more stringent than IWV-3426 and 3427.

4. Check Valvc V13-40 and RRE V-33 (N-11)

Q. Relief reouest basis does not clear 1r . tate words to indicate full stroke exercise testing is required.

Coments: LAR The licensee stated that the subject relief request will tc revised to state full stroke exercising is required anc plant procedures will be revised acccrdingly.  ;

l 5. Relief Yalves G191174, Sh. 2 Q. Provide detailed technical justificatier for not including these valves in the program and testire es Category C valves as required by IWV-3510.

SR-25 (B-7)

SR-26 (I-7)

SR-27 (J-14 )

Coments: R The licensee stated that these valves are not required to perform a specific function in shutting down the reactor or in mitigating the consequences of an accident.

6. lictor Operated Valve V-1 (13-D)

Q. What is the safety related function of this valves?

Coments: R The licensee stated that this valve serves no safety related function. It is not required to function to allcw RCIC initiation for accident mitication.

7. Check Valves (K 13 & 10)

V13-70 and V13-133 Q. Provide detailed technical justification for not including these valves in the pregram.

Comments: 01-L The licensee stated that the safety related functions of these valves would be reviewed. This is an open item for the licensee.

8. Air Operatco Valves V13-12 (L-10)

V13-13 (L-10)

Q. Provide detailed technical justification for not including these valves in the progran.

Comments: R The licensee stated that the subject valves are not required to function for proper RCIC operation and were therefore net put into the IST program.

C. Air Operated Valves G191174 Sh. 1 V13-32 (H-17)

V13-34 (K-17)  ;

-Y13-35 (K-17)

Check Valve V13-140 (I-17)

Q. Provide detailed technical justification for not including these valves ,

in the program, f

Cemments: R The licensec stated that the subject valves were for operating convenience and were exempt (under, IWY-1200) from the IST program. The valves are not necessary for proper RCIC cperation.

10. Check Valves Q. Irovide detailed technical justification for not including these valves in the program. t V13-SSC-10 (K-8)  :

V13-29 (J-10)  !

V13-36 (K-11)

Comments: LAR The licensee stated that the subject valves will be added to the IST program since they are required to open for proper operation of the systen. The subject valves and the following valves which are already in the program, 55C-13-9, V13-27, and V13-50, will all be designated as Category A. The licensee will provide a generic relief request for Ill-?d26 and IllV-3427.

11. RRB-V33 for valve V13-40

0. The alternate testine reeds to be revised to clearly assure that the valve is full stroke exercised.

Convents: LAR The licensee stated that the subject relief recuest will be revised to specify full stroke exercising.

V-22 Primary Centainrent and Atmospheric Control

1. Orw ell te Torus Vacuer Breakers G191175 Sh. 1 (J-8)

Q. The prcgram list Yt.1ves V16-19-5A-J. however, the drawing indicates A-F and G&H. Which is correct?

Coments: R The licensee stated that the progran was designated correctly.

2. Relief Request RRB V-36

, O. This relief ree;uest or another needs tc address IllV-3420 regarding i

pressure differential testing at lower than functieral differential pressures, IWV-3426 Analysis of Leakage Rates and II:V-3427 Corrective Action.

Comments: R The licensee stated that the relief request was being deleted since the testing was being done in accordance with Appendix J at the accident pressure Pa = 44 psig. The licensee will use a generic relief recuest to cover IWV-3426 and IWV-3427.

3. Valves V16-19-12 A/B and RRB Y-38 G191175 Sh. 1 (K and M-16)

0. The relief request does not address testire at cold shutdown and refueling frecuency. Quarterly exercise testing was not specified I as a requirement in the valve table.

Commenta: LAR The licensee stated that the relief request would be revised to i reference cold shutdown and refueling. The vacuum breakers cant.:t be exercised during power operation.

4. Check Valves G191175 Sh. 1 (I-11)

V16-19-51 and V 16-19-52 Q. What is the safety related function of these valves?

Corrents : LAR The subject valves are noc used and de not perform a safety foretion.

The system is isolated by closed manual valves: V16-19-53 and V16-19-54. As added assurance, valve V16-19-34 will be locked closed.

V-23 Radwaste Systems G191177 Sh. 1

1. Valves V20-82, 83, 94, 95 and RRB-V39 Q. The leak testing does not include requirements of IWY-3426 and IWY-3427 for analysis of leakage and ccrrective action requirenents

! of the Cede.

l Coments: LAR The licensec stated that a new relief request will be included in the IST program to cover valves being leak tested under Appendix J.

The staff will consider the relief request to be acceptable previded the licensee's program is equivalent to or more stringent than IWV-3426 and 3427.

2. Dry Well Sump Check Valves

. 80A (D-2)

COB (0-3)

90A (I-2)

! 90B (I-3)

Q. Previde detailed technical justification for not including these valves in the pregram and categorizing as AC.

Coreent_s_: R The licensee stated that the subject valves )erforn no function in shutting dcwn the reactor or in mitigating tit consequences of an accident. The lines these valves are in are isolated by a Group 2 containment isolation signal.

V-24 Reactor Water Clear Up System G191178 Sh.

1. Valves V12-15 (0-2)

V12-18 (D-3)

V12-66 (C-11)

Q. These valves are listed as Category B. The valves serve as priniary contairrent isolation valves ard have a safety functicn to protect the reacter core in case of a pipe break in the clean up syster.. They isolate on a reactor water icw level. There valves should be Category A-ard leak tested.

Cements: LAR The licensee stated that the valves will be designated Category A.

Leak rate testir.g will be done under Appendix J. The licensee will have a generic relief request for IWV 3426 and IWV 3427.

2. Relief Valycs i12-SR-82 (F-10)

V12-SR-85 (D-10)

V12-SR-04 (G-12)

Q. These valves are not included in the program, however, appear to have a safety function to protect the systen against over pressuri-zatien. What is the basis for ret designating the valves as Category C and testing in accordance with IWV-35107

_Ccments : R The licensee stated that the subject relief valves are thermal relief vaives and do not operate to shutdown the reactor or mitigate the consequences of an accident.

3, Check Valve V12-62 (B-5)

Q. This valve appears to be a Category C valve since it functions te close to assure that RCIC ficw goes to the core, however, it is not in the program.

Cements: R The licensee stated that the subject check valve is not required to operate since motor operated valve V12-68 would already be closed to isolate the subject line. Yalve V17-68 is in the IST program, therefore, V12-62 is not included.

V-26 huelear Boiler Vessel Instrumentation

1. RRB-V40 Dwg. 0191267 Q. The Code stipulates exercising the velves every 3 months or if the valves cannot be exercised every 3 months during plant operations, the valves shall be full stroke exercised during cold shutdown.

The relief request for testing does not address the Code required frequency of cold shutdown nor is technical justification provided for net meeting the cold shutdown frequency.

Coments: LAR The licensee stated that the testing of these excess flow check velves can only be done when the reactor vessel is at pressure but not operating. This test condition occurs during the reactor vesse!

hydrostatic test performed during refueling outages. The relief request will be revised to include the required clarification information.

V-27&28 Centainment Atmosphere Dilution Dwg. VY-E-75-00?

1. General Comment: Valves which are required te cperate or function to bring the reactor to cold shutdown conditicrs or in nitigating the consequences of an accident should be included in the IST program and tested in accordance with reouirements of the Code (Reference IWY-1100). If the valve is required to operate under these conditions, testing is rcouired under the Code and any relief requested from this testing must have a technical basis previded for the specific relief requested. (Alsc reference to the staff rete under item 2. of Primary Containment and Atmespheric Control).

Further, the I:RC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds or less. Relief frem the trending requirements of Section XI (Paragraph IWV-3417(a) will be given for these valves since variations in stroke times will be affected by slight varietions in the respense time of the personnel perforning this tests. However, the staff does require that the licensee assign a maximum limiting stroke time of 2 seconds to these valves in order to cbtain this Code relief.

G. The relief reouest bascs in RRB 41, 42 and 43 lack specificity regardino the detailed technical bases for the relief requested.

Thesereliefrequestsneedrevision.

Corrnents: LAR The licensee stated that revised relief request (s) would be submitted to cover IWY-3417(a). The licensee stated that they will ccrply with 3417(b) or provide an ap3ropriate relief request. The RRB 41, 4? and 43 will be deleted and tie new generic relief request will be referenced.

2. O. The followine valves are designated as passive, however, they serve ar. active function with the Primary Cortainment Isolation System (PCIS), therefore, should be designated "Active" and exercised and stroke time tested:

VG-75A-3, -4 (J-14)

VG-9 A/B (G-17. I-13)

VG-22 A/B (B-16 E-16)

NG-11 A/B (G-9)

NG-12 A/B (I-8)

NG-13 A/B (I-9)

Commente: LAR The licensee stated that VG-75A-3, -4 PCIS signals were removed in crder to ensure continucus indication of containment hydrccen cencentraticn. These velves do not receive any automatic isolation signals and are repositioned only by direct operator action. All of the valves will be designated as "active" in the valve listing based upon their PCIS function. All cf the valves with the exception of VG-72 A/B are "rapid acting" solencia valves (VG-2? A/B are motor operatec). All will be stroked ano timed. A relief request for the rapid action valve stroke time trending will be added to the program.

3. Q. The following valves are designated for alternate testing in accerdance with Appendix J. These valves need to cerply with IWV-3426 Analysis of Leakage Rates and IWV-3427, Corrective Action of the Cede.

FS0-109-76A/B (L-14)

VG-23 (J-19)

VG-26 (J-19)

VG-9 A/B (G-12,1-13)

VG-22 A/B (B-16. E-16)

NG-11 A/B (G-9)

NG-12 A/B (I-8) t;G-13 A/B (I-9)

Coments: LAR The licensee stated that a new relief request will be included in the IST prograr to cover valves being leak tested uncer Appendix J.

The Otaff will ccrsider the relief request to be acceptable provided the licensee's program is equivalent to or more stringent than IWV-3426 and 3427.

4. Q. Technical Specification Table 4.7.2.b require the following valves to be operable, however, the pregram does not operability test (exercise or stroke time) the valves. Provide detailed technical justification fer not including this testing in the progran.

Valves: VG-24 (L-11)

VG-25 (L-11)

VG-33 (L-11) 3-34 (L-11)

VG-75 A, 1-4 (J-13, J-14)

Coments: LAR The licensee stated that the subject valves will be designated et "active." Each of these valves are "rapid actirg" solenoid valves.

The valves v111 be stroked and tined and included in a relief request fer relief fren stroke time trending based upon rapid operatien of 2 seconds or less.

5. Polief Valves NG-34-A, B (A-2, G-2)

Q. Providt detailed technical justificatien for not testing these valves per requirements of IWV-3510.

Coments: P.

The licensee stated that the subject valves do not have to operate or function to bring the reactor to cold shutdown conditions or in mitigating the consequences of an accident.

V-29 TIP

1. Ball Valves A-C and RRB V44 Q. The program "Test Requirements" should show "leak test".

RkB-V44 should show that thc valves rect IWV-3426, analysis of Leakage Rates and IWV-3427, Corrective Action.

Quarterly testing of these valves was not stipulated as the test frequency.

Corrents: LAR The licensee stated that leak test in accordance with Appendix J will

Cerments: LAR The licensee stated that a new relief request will be included in the IST program to cever valves being leak tested under Appendix J.

The staff will consider the relief request to be acceptable provided the licensee's program is equivalent to or more stringent ther IWV-3426 and 3427.

4. Q. Technical Specification Table 4.7.2.b require the following vC ves to be operable, however, the program does not operability test (exercise or stroke time) the valves. Provide detailed technical justification for not including this testing in the program.

Valves: VG-24 (L-11)

VG-25 (L-11)

VG-33 (L-11)

VG-34 (L-11)

VG-75 A, 1-4 (J-13, J-14)

Coments: LAR The liccrsee stated that the subject valves will be designated as "active." Each of these valves are "rapid acting" solenoid valves.

The valves will be stroked and timed and included in a relief request for relief from stroke time trending based upen rapid operation of 2 seconds or less.

5. Relief Valves tlG-34-A, B (A-2, G-2)

Q. Previde detailed technical justification for tot testing these valves per requirer.cnts of IWV-3510.

l Comments: R i

The licensee stated that the subject valves do not have to operate or function to bring the reactor to cold shutdown conditions or in mitigating the consecuences of an accident.

V-29 TIP

1. Ball Valves A-C and RRB V44 l

l Q. The p.ogram "Test Requirenents" should show "leak test".

l l RRB-Y44 sh uld show that the valvet neet IWY-3426, analysis of Leakage Rates and IWV 3427, Corrective Action.

Quarterly testir.g of these valves was not stipulated as the test frequercy.

[ . .

4 Conments: LAR The licensee stated that leak test in accordance with Appendix J will be added to the program under alternate testing. The TIP system solenoid valve will be removed from the program since it no longer receives a primary containmort isolation signal. The solenoid valve no longer performs a safety function.

The licensee will refer to a generic relief request for meeting IWV-3426 and IWV-3427.

2. Shear Valves A-C Q. The program legend stipulates testing 20% of the explosive charges every 2 years. This curulatively test all 4 valves within eight years. Does the manufacturer's guaranteed operating life for the explosive charges exceed the eight years?

Concents: R The licensee stated that they have a total of 3 TIF shear valves at Vermont Yankee. The explosive charges in all 3 valves are replaced at a maximum interval of 2 years. The required service life of the replacerent charges is verified prior to their installation.

3. Relief Pequest RRD-V45 Q. The relief request will be acceptable if a maxinun stroke tinc of 2 secerds is assigned. (Reference coment under iterr 1. of V-27 &

28.)

Comments: LAR The subject relief request will be removed from the program per recent design changes to delete the valves centainment isolation s ig r.al . The subject solenoid valve no longer performs a safety function.

Relief Request Basis

1. RRB GV-2

. Q. This relief request needs better definition.

Conments: LAR l The licensee stated that the relief request would be revised to

! provide better clarification.

l l

9

2. RRB GV-4 I Q. As previously discussed under V-27 & 28, the NRC staff has identi-fied rapid-acting power operated valves as those which stroke in 2 seccnds or less. Relief fror. trending requirements of IWV-3417(a) will be given for these valves, however, the staff does recuire that the licensee assign a maximum limiting stroke time of 2 seconds to these valves in order to obtain this Code relief.

Corments: LAR The licensee stated that the subject relief request will be revised accorcingly.

l'iscellanecus Items / Comments

1. Q. Provide pump and valve prograr listing for spent fuel pool cooling.

Connents: R The licensee stated that Vermont Yankee has no accident analysis that requires pueps and valves to operate for fuel pool cooling, ,

2. O. Provide the maximun value of limiting stroke tine for all power operated valves in the IST program.

Coments: R The licensee provided a table listing the quantitative values based upon the plants safety analysis.

3. Q. Provide the documentation that ensures that IWV-3300 is being ret.

(Renote position indication verification).

Comments: R The licensee provided for staff review a ccpy of the pertinent pages from procedure 4102.03, Revision 14, that provides for Local / Remote Valve Position Indication Tests.

4. Q. Provide latest revisions ef drawings for post accident hydrogen control and the updated IST program listing for the pumps ard valves for post accident hydrogen control.

Conments: R The licensee stated that at Vermont Yankee post accident hydrogen centrol is previded by the Containrent Atmosphere Dilution (CAD)

Systen. CAD is included in the IST program on pages V-27 and V-28.

m 4

4

5. Q. Provide a listing cf all valves that perform a pressure isolation beundary between the high pressure reactor coolant system and connected lower pressure piping systems.

Comments: R The licensee provided a listing of the subject pressure isolation valves for staff rev*ew.

6. Q. During the neeting the staff asked the licensee to provide drawings and inferration for staff review regarding pumps and valves that would be required to naintain contrc1 room habitability in the event of an accident.

Comments: R The licensee supplied drawings subsequent to the meeting and stated that there were no pumps or valves within the control room HVAC system which are required to operate to maintain control room habitability.

4 I

, , , - . - , , -