ML20154D301

Summarizes 880816 Meeting Near Cornelius,Nc Re Questions Resulting from Review of Plant Pump & Valve Inservice Testing Program.Meeting Resulted in 14 Open Items Identified in Encl 2.Resolution by Oct 1988 Needed

ML20154D301
Person / Time
Site:	Mcguire, McGuire
Issue date:	09/08/1988
From:	Hood D Office of Nuclear Reactor Regulation
To:	Tucker H DUKE POWER CO.
References
NUDOCS 8809150228
Download: ML20154D301 (32)

Text

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Sept:mber 8, 1988 Docket Nos.: 50-369 50-370 Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte, North Carolina 28242

SUBJECT:

HEETING

SUMMARY

REGARDING HCGUIRE NUCLEAR STATION, UNITS 1 AND 2 i

On August 16, 1988, a >:orking meeting was held among representatives of Duke Power Company, NRC, and EG&G Idaho, Inc., at the McGuire Nuclear Station, near Cornelius, Mrth Carolina. The purpose of the meeting was to discuss the questions resulting from the review of the McGuire Nuclear Station, Units 1 and 2, pump and valve inservice testing (IST) program.

Enclosure 1 is a list of meeting attendees. Enclosure 2 records the questions that served as an agenda for the meeting, and the responses to those questions by Duke personnel during the meeting. Duke representatives were given a brief introduction outlining the agenda and the methods used for the docurentation of questions and responses. This was followed by detailed discussions concerning specific pumps and valves in the McGuire Nuclear Station, Units 1 and 2, IST program. The attached responses are as recorded by EG&G and acknowledged by Duke personnel at the conclusion of the meeting, except for minor changes primarily of an editorial nature.

The meeting resulted in 14 open items which are identifed in enclosure 2.

There are several additional items where the Duke representatives agreed to make corrections or changes to the IST program as indicated in the responses to the questions. The questions and ccnnents on the systems and components apply to both units unless otherwise noted.

The NRC Project Manager noted that a timely resolution of the open items and submital of the IST program revisions in October of 1988 is needed tu maintain the existing schedule for completion of the review this calendar year.

Duke indicated that most, if not all, of the open items could be addressed in abcut 60 days.

Sincerely, 8009150 Original Signed By:

P PDR ADOC 000900 000Q9 Darl S. Hood, Project Manager Project Directorate !!-3 Division of Reactor Projects - I/II

Enclosures:

As statec cc w/ encl:

, See next page

> stihu .b stl '

PDII- PDII-3 PDII-3 MRoodg#n l DHood DMatthews i

09/9 /88 09/p/88 09/9./88 h{Q((

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• Mr. H. B. Tucker .

Duke Power Company McGuire Nuclear Station ec:

Mr. A.V. Carr, Esq. Dr. John M. Barry Duke Power Company Department of Environmental Health P. O. Box 33189 Mecklenburg County 422 South Church Street 1200 Blythe Boulevard

, Charlotte, North Carolina 28242 Charlotte, North Carolina 28203 County Manager of Mecklenburg County Mr. Dayne H. Brown, Chief 720 East Fourth Street Radiation Protection Branch Charlotte, North Carolina 28202 Division of Facility Services Department of Human Resources 701 Barbour Drive Mr. Robert Gill Raleigh, North Carolinc 27603-2008 Duke Power Con.pany Nuclear Production Department P. O. Box 33189 Charlotte, North Carolina 28242 J. Michael McGarry, III, Esq.

Bishop, Liberman, Cook, Purcell and Reynolds 1200 Seventeenth Street, N.W.

Washington, D. C. 20036 Senior Resident Inspector c/o U.S. Nuclear Regulatory Commission Route 4, Box 529 Hunterville, North Carolina 28078 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 S. S. Kilborn Area Manager, Hid-South Area L 3 ESSD Projects Westinghouse Electric Corporation ,

MNC West Tower - Bay 239  :

P. O. Box 355 t Pittsburgh, Pennsylvania 15230  ;

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ENCLOSURE 1 McGUIRE NUCLEAR STATION. UNITS I AND 2 IST PROGRAM WORKING MEETING Auaust 16 and 17. 1988 HAME REPRESENTING Steve Kirksey Duke Power Rick Smith Duke Power Garry Galbreath Duke Power Todd Oswald Duke Power David N. Smith Duke Power M. K. Nazar Duke Power Stephan K. Morales Duke Power Ken Rohde Duke Power Mark Hutcheson Duke Power P. B. "r doci Duke Power J. E. snyder Duke Power R. W. Revels Duke Power Darl Hood NRC/NRR Ed Girard NRC/ Region !!

Toa McLellan NRC/EMEB T. L. Cook INEL/EG&G Idaho Brad Stockton INEL/EG&G Idaho l

ENCLOSURE 2 McGUIRE NUCLEAR STATION, UNITS 1 ANO 2 PUMP AND VALVE INSERVICE TESTING PROGRAM MEETING MINUTFS I. VALVE TESTING PROGRAM A. General Questions and Connants

1. Provide the documentation that ensures that IWV-3300 is being met (remote position indication verification).

t

Response

Remote position verification is being performed. This will be documented in the McGuire Nuclear Station IST program.

2. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by  ;

10CFR50, Appendix J. General Relief Request !!! does not state that it applies to only Category A containment isolation valves.

Additionally, the licensee must comply with the Analysis of Leakage Rates and Corrective Action Requirements paragraphs of Section XI, i IWV-3426 and 3427, when leak testing containment isolation valves in accordance with the requirements of Appendix J.

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Response

General relief request !!! will be modified to cover only  ;

containment isolation valves. McGuire Nuclear Station is not in compliance with IW-3426 and 3427. Presently, engineering judgement is used to determine which valves are leaking l l exceat tely and are in need of repair. The licensee

] understands the NRC Staff's position on compliance with IW 3426 and 3427. THIS IS AN OPEN ITEM FOR THE LICENSEE.

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. 3.' Provide a listing of all v&lves that are Appendix J, Type C, leak

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rate tested which are not included in taa IST program and j Categorized A or AC7  !

l Response; j l

There are no Appendix J, Type C, leak rate tested valves which I are not included in the IST program and categorized A or AC.

Additional consent:

Manua! vents and drains in capped lines are not regt. ired to be included in the IST program.

4. The NRC staff has identified rapid acting power operated valves as those which stro!.s in 2 seconds or less. Relief may be obtained from the trending requirements of Section XI, Paragraph IW-3417(a), however, in order to obtain this Code relief the staff does require that the licensee assign a maximum limiting stroke ,

time of 2 seconds to these valves and comply with the requirements of IW 3417(b) when the 2 sece-d linit is exceeded. General Relief Raquest I does not comply with this staff position.

(

Response

McGuire Nuclear Station will evaluate the NRC Staff position on rapid-acting valves, fHIS IS.AN OPEN ITEM FOR THE LICENSFE'S EVALUATION.

Additional comment:

, The licensee may designate which valves will be considered rapid acting and have thir, NRC Staff position applied to them.

5. Provide the limiting values of full-stroke times for the power operated valves in the McGuire Nuclear Station, Units 1 and 2, IST programs for our review. What are the bases used to assign the i

limiting values of full-stroke time for these valves? 1 1

2

+

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. Response:

The limiting values for full-stroke time for all power operated valves in the McGuire Nuclear station, Units 1 and 2 IST submittal are identified in the remarks column of the valve table for nach system. The response times for the l Individual valves are set such that each component will complete its required fen tion in time to permit the system to meet the response time limitations stated in the Finai Safety AnalysisReport(FSAR). Note that this questien was the subject of unresolved ites No. 369(370)/87-16 02 in NRC/0!E Inspection Regirt No. 369(370)/8716.

6. When flow through a check valve is used to indicate a full-stroke exercise of the valve disk, the NRC staff position is that verification of the maximum flow rate identified in any of the plant's safety analyses through ths valvo would be an adequate demonstration of the full-stroke requirenant. Any flow rate less than this will be considered partial streke exercising unless it can be shown (by some means such as msvrement of the differential pressure across the valve), that the chsck valve's disk position at the lower flow rate would permit maximum required flow through the valve. Does the test designated 'MT' satisfy this NRC Staff position?

Responsa: l McGuire Nuclear Station will revise their IST program tr St**

the required safety position and the valve test positi  ;. a.e l

licensee is aware of the NRC Staff position on verificat.:* 9 full stroke exercising of check valves. Current testing l methods will be evaluated to determine if they are in ceropliance I

with the Staff position. THIS IS AN OPEH ITEM FOR THE LICENSEE,.

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7. Provide the documentation that ensures that IWV 3415 is being met (failsafetestingofvalves). 1 I

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Response

Fail-safe testing is being performed. This will be documented in the McGoire Nuclear Station I!T program.

8.Section XI specifically makes provisions for testing valves during I

cold shutdowns when it is impractical to exercise these walves quarterly during power operation. A formal relief request is not required, however, the licensee should include a cold shutdor justification in the IST progrue. The cold shutdown justifica non bases should indicate the negative consequences that make quart W ,

testing during operation inpractical such as endangering perse',iel, l damaging equipment, or resulting in a plant shutdown.

Response

l Justification is provided for cold shutdown valves in , . 'erm of a relief request. McGuire will make these justificatuns in the form of a cold shutdown justification and remove the relief requests for the IST pregia submittal. Cold shutdown justifications will be includ e in the respective system sections of the submittal. These program revisions will be included in the scheduled October 1988 IST program revision incorporating the comitments of the August 1988 meeting.

10. The valve testing frequency should be indicated in the valve tables. Only a portion of the valves in the McGuire IST program currently have the testing frequency ideneified in the valve

. tables.

Response

The McGuire Nuclear Station IST program valve tables will be changed to clarify the valve testing frequencies.

11. Does the fuel pool cooling system perform a safety function at the McGuire Nuclear Station? If so, the appropriate pumos and valves 4 l

should be included in the IST program and tested in accordance with the requirements of Section XI to the extent practical, t

j Response:

The nuclear service water system provides safety grade makeup, and the refueling water storage tank is the safety grade makeup water source. See additional coauwnts in Section R (Nuclear Service Wster) of this report.

12. What is the frequency of the testing designated SP in the valve test program?

Response

.)

The SP testing method will be clarified in the McGuire Nuclear f Stt.tica IST program.  !

13. The HRC staff position is that valves that serve both a pressure boundary isolation function and a containment isolation function must be leak tested to both the Appendix J and the Section XI  ;

requirements. Identify the val W ), if any, at McGuire Nuclear  !

I Station that serve both a pressure boundary isolation function and

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a containment isolation ' unction. What leak rate testing is performed on thesa vaiv A l

Response: l l

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{ . There are no valves at the McGuire Nuclear Station which are l

) leak rate tested for a pressure boundary isolation function l l and a containment isolation funcston, j i  !

8. Annulus Ventilation Systes  !

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1, Why are valves 1(2)VE 10A identified as passive valves? l 5

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,,,-.4 , ,-- ,e-c- .,e,,,-my -

--_wg.-+.-,--man-, ,----en,n,~n.

, _-..,--a,g- -,g y--e e.-,, - , - . ,-----w.,.. - - - - - -- -- -- , - -, , -- - - . -

Response

VE-10A is the hydrogen purge inlet blower discharge valve. It provides a class break and receives a Phase A (St) isolation sigral. It was identified as passive in error and will be changad in the scheduled October 1988 revision.

2. Review the safety function of valves 1(2)VE 5A and 68 to determine if they should be categorized A.

Response

These valves terminate inside the annulus, but do not provide a leak path to the environment. These valves are Type C leak i rate testad and will be evaluated to determine if they should l be categorized A.

C. Auxiliary Feedwater Systee j 1. Concerning the relief request for valves 1(2)CA-60A, what prevents measuring the stroke tist of these valves when they are exercised quarterly? What is the frequency of the stroke timing now being j done, i.e., during ESF testing?

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Response

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f' CA 60A and all other auxiliary feedwater control valves i (CA 64f' CA 56A, CA 52AB, CA 44B, CA 48A8, CA-4% , and

. CA 36A8) are now cycled and timed quarterly. The relisf request will be removed in the schedu14 October 1938 IST program revision.

2. How are the following valves verified to full strc,ke exercise quarterly?

1 2 CA 8 1 CA-10 1 CA 12 1 2 CA-22 1 ;A 26 1 CA 31 6 l

, Response:

The auxiliary feedwater pumps are tested monthly to ensure they will develop full discharge pressure at full flow per Technical Specifications. The pumps are placed on recirculation to the upper surge tank. Full flow is passed through these valves which constitutes a full-stroke exercise.

3. What is the frequency of the stroke timing now being done for valves 1(2)CA 20A87

Response

j Valves 20A8, 27A, and 32B are now full-stoke exercised and

! stroke timed quarterly.

1

4. What is the safety grade water source for the AFW pumps? Review the safety function of the following valves to determine if they i should be included in the IST program and tested to Section XI

requirements

l Valve _ _ _ _

P110 Valve FAEL_,

l 1(2 CA 3 1{2592-1.1 1(2)CA 4 1(2)591 1.1 1 CA 5 1s2 592 1.1 1(2)CA 6 1(2)592 1.1 l 1 CA 151 1(2 592 1.1  :

Response

The safety grade water source for the auxiliary feedwater l

! pumps is tht nuclear service water system through valvus j i

1(2)CA 15A, 86A,165, and 1(2)M 69A for train 'A', ,

] 1(2)CA 188 and 1(2)M 1626 for train '8', and 1(2)CAi45, l j 86A, and 1(2)M 69A or 1(2)CA1168,166, and 1(2)M16Z'd for l the turbine driven auxiliary feedwater pump. These valves I

are all being exercised to Section XI requirements, i

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The safety function of valves 1(2)CA 3, 4, 5, 6, and 151 have been reviewed. These valves do not provide a safety function. This position is unchanged free Duke's previous response dated 8/17/82.

D. Baron Reevele System

1. If the only practical method of verifying valve closure is leak rate testing, then closure verification can be demonstrated each

! refueling outage. However, it must be dohe each refueling outage irrespective of the Appendix J required frequency. Does the testing frequency for valves 1(2)N8 262 conform to this position?

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Response

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i Yes. McGuire will clarify the wording on the relief request. Alternate testing will be changed to hdicate l every refueling, as indicated on the valve table in the submittal. These IST program revisions will be included in the scheduled October 1988 revision.  !

E. Breathina Air system I

i 1. If the snly practical method of verifying valve closure is leak l rate testing, then closure verification can be demonstrated cach

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l refueling outage. However, it must be done each refueling outage

] irrespective of the Appendix J required frequency. Does the j testing frequ6dcy for valves H2)VB 50 conform to this position?

kesponse:

! Yes. McGuire will clarify the wording on the relief f request. Alternate testing will be changed to indicate every refueling, as indicated on the valve table in the i

submitta). These IST program revisions will be included in the scheduled Octob'r 4 1984 revision.

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

F. Chemical and Vol"=a control svstaa j 1. Are valves 1(2)NV-94AC and 958 ever required to perfom a l containment isolation function?

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Response

Valves 1(2)NV 94AC a d 958 are required to perform a .

containment isolation function. However, they are exempt from Appendix J. Type C leak rate testing per the NRC Standard Review Plan (SRP) concerning secondary containment j 4 functional design, and the NRC Branch Technical Position i j (BTP) CSB 6 3. Therefore, these valves are category B l valves. Isolation of these valves is not important for 1 I bypass leakage.

2. Review the safety function of valves 1(2)NV-78, 457A, 458A, and 459A to determine if they should be Categorized A.  !

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Response

These valves 'are required to perform a containment isolation function. However, they are exempt from Appendix J. Type C  !

leak rate testing per the NRC Standard Review Plan (SRP)  !

concerning secondary containment functional design, and the  !

l NRC Branch Technical Position (BTP) CSB 6-3. Therefore, i j these valves are category B valvos. Isolation of these f j valves is not important for bypass leakage.  !

1 l 1

3. Do valves 1(2)MV 12 perform a safety function in the closed j j position?

Response

l 1 These valves are not required so be Appendix J. Type C leak l ra'.e tested, and do not perform a safety function. They will be removed from the IST program.

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

4. How will full-stroke exercising valves 1(2)NV-225 and 231 l

quarterly result in an increase in RCS boron inverstory7

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, Response:

1 McGuire Nuclear Station will provide a more detailed technical justification for this relief request in the l scheduled October 1988 IST program revision.

5. Review the safety function of the following valves to determine if they should be included in the IST program and tested to Section XI requirements:

Valve P&ID Valve P&ID 1 NY 45 1 554-1.0 1 NV 29 1 554-1.0

, 1 NY-77 1 554-1.1 1 NV-61 1 554 1.1 i 1 NV-14 1 554-1.2 1 NY-15 1 554 1.2 1(2 NV 20 1 554-1.2 1(2 NY 841 1 554-1.2 l 1(2 NV 218 1 2)554 3.0 1(2 NV-241 1 554 3.0 2NY-1044 2554 3.0 2NV-1046 2554 3.0

1 2)NV 264 1 554 3.1 1 NY 472 1 554 3.1 1 2)NV-267A 1 554-3.1 1 NY 2658 1 554 3.1

! 1 2)NV 411 1 554 5.0 1 NV-413 1 554-5.0 I

Response

4 I Valves 1(2)NV 29, 45, 61, and 77 will be evaluated to j determine if they have a safety function. Valves 1(2)NY 14, j 15,17, and 18 are pressure boundary isolation valvis, but l are exempt from lean testing (letter supplied). Yalves 1(2)NY-20 have no safety function. Valves 1(2)NV 841 are l) -

not in an RS8 51 required flowpath, therefore, they do not j have a safety position. Valves 1(2)NV-218 are required to l prevent gross diversion of flow, however, because of their ,

, location on the discharge of the positive displacement  !

l charging pumps, it is our position that gross flow through  ;

j those pumps would be near impossible ano these valves do not  ;

require backseat testing. Valves 1(2)NY 241, 2NV-1044, and I

l 2NV 1046 have no safety function since the reciprocating l ,

, e 10 i i i

=-w_- .-

, l l

charging pump is not safety related. Valves 1(2)NV 264, 472, 267A, 2658, 411, and 413 are required per NRC BTP RSB 51 and will be added to the IST program in the scheduled  ;

October 1988 revision.

t G. Connonent Coolina System -

1. Do valves 1(2)KC 5, 8, ll, and 14 perform a safety function in

the open and closed positions 7 IF so, the valves must be l exercised to both positions.

4

Response

l Valves 1(2)KC 5, 8,11, and 14 perform a safety function in  !

the open position only.

2. Review the safety function of valves 1(2)KC 972 (P&ID 1(2)5731,1) to detemine if they should be included in the IST

! program and tested to Section XI requirements. l 4

i

Response

I McGuire Nuclear Station will add valves 1(2)KC-972 to the IST program and test them to Section XI requirements,

3. Review the safety function of valves 1(2)KC 3158, and 3058 to  !

l; determine if they should be categorized A. '

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. Response

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J Valves 1(2)KC-3158and305Bperformacontainmentisolation  ;

. function, but are exempt from Appendix J. Type C, leak rate I testirg and are therefori category B valves. [

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H. Containment Air Release and Addition Systen

1. Clarify the testing being performed on valves 1(2)VQ-1A, 28, 58, and 6A.

Response

1(2)VQ 1A, 28, 58, and 6A are leak rate tested every refueling outage in accordance with 10 CFR 50, Appendix J.

These valves are stroke timed quarterly.

I 1. Containment Purae Ventilation f

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1. Clarify the proposed alternate testing in the relief request for '

all containment purge ventilation category A valves. The stroke ,

time of all power operated valves must be measured every time the -

valve is full-stroke exercised as required in Section XI, paragraph IW-3413(b).

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Response

l l l

1 The proposed alternate testing in the relief request for l these valves will be clarified and the trending of stroke .

i times will be addressed.

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{ J. f,imtainment Soray System l 1

1. The NRC Staff position is that check valves must be full stroke l

. exercised. If the Code required frequency is impractical, then j the licensee must request relief to perform the testing at a  !

lesser frequency. However, relief requests seeking exemption l j from full-stroke exercising of check valves will not be granted. l The .>elief request for the following valves will be affected by  !

,i this Staff position l l i 1(2)NS13 1(2)MS 16 1(2)NS 30 l 1(2)NS33 1(2)NS-41 1(2)NS-46 12

[

. . l 1

Responsn: ,

l currently there is no way to verify a full-stroke of these valves. An evaluation will be performed te datarmine a l method of verifying the full-strone operability of these valves. The licensee should recommend and justify an 1 approoriate time for the implementation of this, testing, as it will require physical modifications to the plant.

THIS IS AN OPEN ITEM FOR THE LICENSEE

2. Review the safety function of the following valves to determine if they should be categorized A:

1 1(2)MS-158 1(2)MS-29A 1(2)NS128 (2)NS 32A 1(2)NS383 1(2)MS 43A

Response

These valves are required to perform a containment isolation function, however, they are exempt from Appendix J, Type C j i leak rate testing per the NRC SRP and NRC STP CSB 6-3 and i are therefore categorized B.

)

l K. Diesel Generator Rcw Suen P- Systen

1. Do valves 1(2)W3, 5. II, and 13 parform a safety function in j the closed position?

I i

i Response:

l These valvu are required to perform a safety function in the closed position and will require backseat testing. This j change will be incorporated in the IST program in the scheduled October 1988 revision.

.l 13

L. Diesel Generator, Startina Air Systen

1. Provide P&lDs MC-1609 4.0 and 2609 4.0 for our review.

Response

The requested P& ids were provided.

Additional coament:

The air dryer, air compressor, and associated piping are now [

seismically qualified, therefore, the air compressor  ;

discharge check valves do not need to be tested in the ,

closed position. t I

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M. Eaui - nt Decontamination Svitem

1. What type of valve is 2WE-237 Is the AC categori.tition for this valve correct? i i

Response: i No. This is a packless sten valve. The AC categorization I

is incorrect and was changed to category A in the May 6, 1988 IST program subelttal, revision 6.

t j N. Lieuid Waste Reevele System I I 1. , Review the safety function of valve IN! 266A to determine if it l

i should be categorized A.  !

i i I

Response:  :

Yalve 1NI 266A has been deleted by a Nuclear Station l l Modification (NSM) and was removed from the IST program.  !

i Note however, that valves 1(2)NI 263, 2648, 265, and 267A  !

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have been re tagged pcr a different NSM for use as containmentisolationvalves1(2)WL-1306,1301B,1307,and 1302A respectively. Valves 1(2)WL-13018 and 1302A are categorized A and were added to the IST program in revision

10. for Unit 1, and revision 6. for Unit 2. They will require Appendix J. Type C, leak rate testing.

O. Main Steam Sunniv to Auxiliary Eauinme d

1. How are valves 1(2)SA 5 and 6 verified to full-stroke open quarttrly?

Response

i These valves are full stroke exercised, alternately, during i

monthly turbine driven auxiliary feedwater pump testing.

The test positions will be specified in the valve table.

P. Main Steam Vent to Atmosahere i

1. Review the safety function of the following valves to deters lne if they should be included in the IST program and tested to Section XI requirements: I i

Valve P&ID - Valve P&lD 1(2)$V25 1(2)5931.3 1(2)$V26 1(2)554 1,3 I 1(2)$V 27 1(2)593 1.0 1(2)$V28 1(2)593 1.0  :

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' Respor.se: l These valves do not perform a safety function, are not active velves, and do not receive emergency power. l f

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Q. Nuclear S = lina

1. What type of valves are 1(2)M 420 and 421? Should these valves be categorized AC7

Response

Valves 1(2)NM 420 and 421 are pressure equalization check valves, and should be categorized AC. This change will be incorporated into the IST program in the scheduled October -

1988 revision.

l R. Nuclear Service Water Systes  ;

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1. De valves 1(2)RN 28 and 30 perform a safety function in both the l open and closed positions? If so, both positions must be j verified during valve tests.

Response

The trains are not run in parallel during an accident. l These valves perform a safety funci..sn in the open position

) only. l l l i

2. Valves 2RN 418 and 2RN 43A are listed in both Unit 1 and Unit 2 l valve tables. Is this correct? l

Response

l i These valves are Unit 2 valves, however, they will remain in l Unit l's IST program since they receive a Unit I safety i signal to shut. These valves are in a partially shared system.

16 1

l Add'itional comment:

, It is the NRC Staff position that if the nuclear service water ,

system is the safety grade makeup for the spent fuel pool, and if l the spent fuel pool cooling system is not to be included in the

!!T tr9 ras, then the valves in this flow path must be included l in the !$T program and tested to Sectier. XI requirements. The [

I licensee should evaluate check valves 1(2)RN 113 and 214 for inclusion in the IST program as Category C valves. Twlt 11 AN ,

l OpEN ITEM FOR THE LICENSEF. l

.l i

{ $. Reactor Coelant System i

1. The NRC Staff position is that the PORVs should be exercised [

during cold shutdown or prior to estabitshing conditions where f

the PORVs are utilized for low temperature overpressure ,

j protection. The relief request for the 70RVs will be affected by  !

i this Staff position. i i

J Response:  ;

i  :

l McGuire Nuclear Station will reyvaluate the current testing [

j frequency of every 18 months. The reevaluation should consider

{

! whether the power operated relief valves should be tested at  !

I j the entrance to cold shutdown, not to exceed every three months, l' l but no less than once each refueling cyr.le. Results of the I

reevaluation and any recomended changes should be submitted

! to the NRC. THIS*15 AN OPEN ITEM FOR THE LICENSEE, i , i 1 . I

) 2. idhat is the full stroke test frequency for valves 1(2)NC 27C and l 19Cf  !

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! Response:

i

! l l McGuire Nuclear station will evaluate whether the spray i control valves have a safety function. If it is determined 1  ;

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1  ;

a p 1_._-_-_-....-....----_._-.------.--_._-. - . _ .

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l that these valves have no safety function, then they will be i removed from the IST progras and the relief request ,

deleted. THIS IS AN OPEN ITEM FOR THE LICENSEE.

3. Provide P&lD MC-1553-2.1 for our review.  ;

Response

The requasted P110 was provided.

Additional question:

Do valves 1(2)NC-59 perform a containment isolation function?

I  ;

Additional response:

l 1 No. This valve does not perform a containment isolation function.

t 1 4. Are valves 1(2)NC 141 and 142 passive valves?

l'

Response

l l Yes. This will be reflected in the scheduled October 1988 j IST program revision.

j T. Refuelina Water sysits

1. Provide a detailed technical justification for not full stroke exercising valves 1(2)FW 28 during cold shutdowns.

Response

1 1

j McGuire Nuclear Station will revise the relief request for ,

) these valves to provide a detailed technical justification i l

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for not f all stroke exercising during cold shutdowns, j Currently, full flow testing through these valves cannot be i done because the reactor coolant system cannot acc.ommodate this quantity of water.

2. Why are valves 1(2)FW 67(63) designated passive whilt all other small check valves that perform a thermal relief function are  ;

not?

t Response: (

These valves are thermal relief check valves on a passive containment penetration. The other isolation valves in the ,

, penetration are 1(2)FW 11 and 15, wnich are listed as j passive, falves IFW 67 and 2FW 63 are categorized AC passive and closure verified via the leak test performed during refueling outages.

i U. Residual Heat Removal Systee ,

1. What type of leak testing is performed or. valves 1(2)NO 18 and l j 2AC? Do these valves perform both a pr6ssure isoh tien function i and a containment isolation function? See general coseent A.13. l i

l j Response l

These valves are categorized A be.au- ' hey are pressure ,l l 1soittion valvas. Thty are also containment isolation I valves, however,. they are exempt from Appendix J. Type C, leak rate testing per the NRC SRP and NRC STP CSB 6 3.

j These valves will be noted in the !$T program as pressure j j isolation valves. l i

2. Previde a detailed technical justification for not full stroke exercising valves 1(2)NO 8 and 23 during cold shutdowns, j i I

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-- - ,,_--- - - . -- -. - - --.-.--.-,.-__..,..n,.-,,- -

Response

The relief request for these valves will be revised to include a more detailed technical justification for not

! testing during cold shutdowns. i

3. Provide a more detailed technical justification for not full stroke exercising valves 1(2)NO 70 quarterly and during cold i

shutdowns, r i 4

Response

4 i The relief request for these valves will be exparded to '

include the concerns of low temperature overpressurization j when full-flow testing these valves during cold shutdowns, s

4. Why must hs.th trains of the residual heat removal system be l removed from service to test the 1(2)NO 58A valves?

j Response: l l

The relief request will be changed to a cold shutdown ,

j justification and expanded to explain that interlocks would  !

J have to be defeated, using jupers, to perforin this testing, i i V. Safety Inbetion !vstem .

I 4

) 1. Review the safety function of valves 1(2)MI 12 to determine if l ,they should be categorized AC. r i

Response

i

< Valves 1(2)N! 12 perfona a containment isolation function. .

However, they are exempt from Appendix J. Type C, leak rate  ;

testing per the NRC SRP and NRC BTP CS8 6-3. Therefore, the valves will remain Category C valves. l

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2. Review the safety function of valves 1(2)N! 11 (P&l01(2)5621.0) ,

to determine if they should be included in the IST program and tested to Section XI requirements. ,

Response

t These valves are passive and do not perform a safety i I function.

3. How are valves 1(2)N! 59, 70, 81, and 93 verified to full stroke open during refueling outages?

l Response: l 1

McGuire Nuclear Station currently calculates the f differential pressure required to full-stroke exercise these valves. These calculations may be provided for NRC evaluatien. An evaluation will be performed to determine  ;

9hether the current method of testing will indeed full stroke exercise the accumulator discharge check i

valves. TH15 IS AN OPEN ITEM FOR THE LICENSEE.

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4. How are valves 1(2)N! 60, 71, 82, and 94 verified to full stroke open during cold shutdowns? l I i l Response:

j t l Current practice is to put 3000 gpm of flow through these J valves, two at a time. McGuire Nuclear Station has been l

l hilormed of the following NRC Staff positions. First, that l

, these val.'s must be demonstrated capable of passing at j

least the same amount of flow as the accumulator discharge  !

I check valves. Second, that these valves should be l I

individually verified to full stroke. An evaluation will be j j performed to determine a method to adequately, and j 4

individually, demonstrate a full-stroke of these valves.  ;

j THIS IS AN OPEN ITEM FCR THE LICFNSEE.  !

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5. ' Review the safety function of valves 1(>JN! 121A and 1528 to determine if they should be categorir.ed A.

Response

i Valves 1(2)MI 121A and 1528 perform a containment isolation function. However, they are exempt from Appendix J. Type C, leak rate testing per the NRC SRP and NRC BTP CS8 6 3.  :

Therefore, the valves will remain Category 8 valves.

6. What is the safety function of valves 1(2)Nt 12287 i Response:

These valves are passive and do not perform a safety function. Dulie has concluded per consultation with Westinghouse that this should not be an automatic isolation  ;

l i

valve. Technical Specification changes have deleted these valves as Engineered Safety Features (ESF). Therefore,

these valves no longer receive a Phase A isolation signal. l j Met.uire Nuclear Station has been informed of the NRC Staff's l position that if these are indeed 8 passive valves, then l

{ they say be removed from the IST program. 1 i

7. Describe the procedure used to full stroke exercise the following valves during refueling outages: l i 1(2)V! 124 1(2)N! 128 1(2)MI 156 [

) 1(2)MI157 1(2)NI-159 1(2)MI-160 1

! t

) Response:

l j A flow balance test was performed during startup testing.

I With current testing methods only total flow is actually I sensured. An evaluation will be performed to deterstne a l

method to adequately, and individually, v6rify a full stroke

of these valves. TH15 IS AN OPEN ITEM FOR THE LICENSEE.

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8. How are valves 1(2)NI 125, 126, 129, and 134 verified to I full-stroke durinc cold shutdowns.  :

Response

Current practice is to put 3000 gpa through all tour valves. There is no means to isolate the parallel injection flow paths. An evaluation will be performed to determine a method to adequately, and individually, verify a full stroke of these valves. THIS IS AN OPEN ITEM FOR THE LICENSEE.

9. Review the safety function of the following valves to determine

! if they should be categorized A:

, 1(2)NI-162A 1 2 NI-173A 1(2)N!-178B 3 1(2)N! 184B 1 2 NI-185A i Response:

Valves 1(2)fl! .'52A,173A, and 1788 are containment isolation

] valves; 1(2)NI-1848 and 185A are containment sump j rectreulation isolation valves. lione of these valves  ;

I perform an automatic isolation function. These valves are ~

oxempt from Appendix J. Type C, leak rate testing per the l NRC SRP and NRC BTP CSB 6 3.

10. Review the safety function of the following valves to determine ,

i if they should be included in the !$T program as category A valves and tested to Section XI requirements:

l 4

r Valve PalD

] i I 1 NI-143 1 562 3.1 l 1 NI-174 1 552-3.1

• j 1 N! 179 1 562 3.1

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._ - _ . ~ _.

e' .**

' Response:

These valves are B passive valves. These penetrations are not Appendix J. Type C, leak rate tested. ,

11, Describe how the interlocks mentioned in the relief request for valves 1(2)N!-1848 and 185A preclude valve operation.

Response:

• The relief request for these valves will be changed to a cold shutdown justification and revised to include a more detailed technical justification. This change will be reflected in the scheduled October 1988 IST program revision.

12. How are valves 1(2)N! 175, 176, 180, and 181 full stroke ,

exercised during cold shutdowns?  !

"esponse:

i Current practice is to put 3000 gpa through these valvis,  !

two at a time. An evaluation will be performed to determine a .mthod to adequately, and individually, verify a [

full stroke of these valves. THIS IS AN OPEN ITEM FOR THE LICENSEE.

13. The NRC Branch Technical Position, RSB 51, establishes s requirements for taking reactor plants from power operation to l cold shutdown using only safety-grade equipment. To comply with i this position, credit is normally taken for the safety injection i accumulator vent paths and/or the accumulator motor operated '

isolation valves. Evaluate the safety function of the following  !

valves to determine if they should be included in the IST program and tested to the Code requirements * '

I 24

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1 i Valve P1 D Value P1 D t j 1 1 502 2.0 II; N: 54A 1 562 2.0  !

[N!50 542-2.0 542 2.0 '

i 1 JNI41 1 1( NI 458 1 1 JN!-72 1 542-2.1 1 542 2.1 l

1 JN! 83 1 H2-2.1 11lN!N!8474A 11 1 542 2.1  !

1 JN! 888 1 542-2.1  ;

Response

I l In compliance with BTP Ast 5 1, no credit is taken for  !

! remote manual operation of either the cold leg accumulator 7 l (CLA) vent valves cr the CLA discharge isolation valves.  :

l Credit was taken for the local manual operation of valves at  !

j hot standby and during cooldown, if necessary, to achieve l i cold shutdown. i

) Valves 1(2)N! 50, 41, 72, 83, and 84 do not perform a safety

function and will not be included in our IST program.

(

)  !

3 However, valves 1(2)MI 54A, 658, 74A, and 888 do perform a j j safety function. These valves are categorized B, will be l l added to the IST program in the scheduled October 1988 IST program revision, and will be tasted to Section XI  :

l requiresents.  ;

14. Review the safety function of the following valves to determine j if they should be included in the IST program and tasted to j j Section XI requirements: l l

Valve Palo Valve Palo i 1(2 N! 2428 1(2)542 4.0 1(2)N! 243A 1(2)5424.0 t j 1(2 N! 2448 1(2)542 4.0 1(2)N!245A 1(2)5424.0 l

< INI 244A 1542 4.0  ;

1  !

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Response

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I l j These valves have been deleted by a Nuclear Station Modification (NSM), and are no longer in the IST program.

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15. What type of the valves are the following:

IN!-244 1N!-249 INI 250 INI-251 INI-252 INI 253

Response

These valves were upper head injection system check valves and were deleted by the NSM sentioned in the previous response . These valves have been removed and the piping has -

l been capped.

!!. PUMP TESTING PROGRAM j 1. The deviations from the Code requirements discussed la Ites !.A j and 8, page 1.1 1, have not been indicated on the pump table, i

l Response:

l These deviations will be added to the pump table in the scheduled October 1984 !$T pregram revision. l

2.Section XI requires that both flow and differential pressure be seasured during the performance of pump testing, i.e., all 1

! quantities required by Table IWP 3100 1 should be recorded and that lack of installed instrumentation is not a suitable long j ters justification for not performing the required Section XI ,

l testing. Ites !.C does not agree with this Staff position.

4 Responre:

) McGuire Nuclear Station will evaluate methods of flow l l esasurement for the centrifugal charging pusps. Also, the frequency of flow sensurement fer the residual heat removal and safety injection pumps will be evaluated. THESE ARE OPEN ITEMS FOR THE LICENSEE, 26

• c *; .

i 3.* Has McGuire Nuclear Station attempted to procure portable vibration instrumentation that meets the accuracy requirements of Section XI?

Response

Investigation into a meter and probe thtt would give an .

accuracy range of 55 is in, progress now. Information is '

being supplied from Duke's' standards lab on a vendor that can potentially satisfy this requirement. THIS IS AN OPEN ITEM FOR THE LICENSEE.

, 4. Is the pump vibration monitoring program conducted utilizing units of vibration displacement or vibration velocity? ,

1 1 Response:

i

. Units of displacement are used.

] 5. Relief may be granted from the requirement of Section XI to

measure pump bearing temperature annually, howev6r, specific l relief must be requested describing the difficulties encountered in each case. These relief requests will then be reviewed on a

) case by case basis. Itts !.E does not agree with this Staff position.  ;

i Response: l l

l j

McGuire Nuclear Station will request relief from the beartrg

temperature measurement requirements of Section E! on a case by case basis if vibration measurement is in the units of displacement, j 1

6. Is the flow rate of the diesel generator fuel oil transfer pumps  !

l deterstned while the diesel engine is running?

I 1

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Respo.tse:

l J The relief requests for the diesel generator fuel oil transfer pumps will be revised to clearly state the l acceptance criteria for pump testing, and when corrective l action will be initiattd. This will also be done for the l l

diesel generator sump pumps. A detailed technical  ;

j justification for deviations from Section XI requirements 1 will be provided.

7. In those cases where instrumentation is not installed to permit monitoring pump performance, individual specific relief must be l

l requested. This requirement will affect the pump test program for the diesel fuel oil transfer pumps, diesel generator room i sump pueps, and the standby makeup pumps.

l Response:

! l

'] McGuire Nuclear Station will request individual reitet from j j the measurement requirements of Section XI for 1Eh

] parameter listed on Table IWP 3100-1, with a detailed technical justificatica for deviation from the Code L r

)

requireser.ts, i .

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D!$TRIBUTION Dechet F1le NRC PCR Local PDR P0ll-3 Reading S. Varga 14-E-4 G. Lainas 14-H-3

0. Matthews 14-N-25 H. Rood 14-H-25 D. Hood 14-H-25 OGC 15-B 18 E. Jordan HNBB-3J02 B. Grires 9-A-2 ACRS (10) H-1016 PCGUIRE PLANT FILE

' . Sullivan 9H-3 T. McLellan 9H-3 l

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