ML20154G574

Forwards Request for Addl Info Re Facility Third 10-yr Interval Inservice Testing Program for Pump & Valves. Response Requested within 30 Days of Ltr Receipt

ML20154G574
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	05/11/1988
From:	Wang A Office of Nuclear Reactor Regulation
To:	Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO.
References
TAC-65687, NUDOCS 8805240430
Download: ML20154G574 (12)

Text

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, MAY 11196 1 1

Docket No. 50-213 DISTRIBUTION cg 6 AWang NRC & Local ~PDRs OGC-WF SVarga EJordan l Mr. Edward J. Mroczka BBoger JPartlow Senior Vice President SNorris ACR$(10)

Nuclear Engineering and Operations Gray File RBrady Connecticut Yankee Atomic Power Company JHunter P. O. Box 270 Lartford, Connecticut 06141-0270 l

Dear Mr. Mroczka:

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE HADDAM NECK PLANT THIRD TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM FOR PUMP AND VALVES (TAC NO. 65687)

A working meeting was held with your staff on January 13, 1988 to review 4 Connecticut Yankee Atomic Power Company's (CYAPCO) third ten-year interval inservice testing (IST) program for pumps and valves for the Haddam Neck Plant. Based peon our review and discussions with your staff, the NRC has ,

identified additional information that is needed to complete our review.

Please provide your response within 30 days from the date of receipt of this letter.

The reporting and/or recordkeeping requirements contained in this letter

affect fewer than ten respondents; therefore, OMB clearance is not required  ;

under P.L.96-511.

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l If you have any questions or coments please contact me at (301) 492-1314.

l Sincerely, 4 6 $E23EW Alan B. Wang, Project Manager Project Directorate I-4 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation i

Enclosure:

As stated cc w/ enclosure:

l See next page I.

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I Y 05/11/88 b

05/u /88 35/' /88 i

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l 6805240430 880511 1 PDR ADOCK 0S000213 P PDR 1

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Mr. Edward J. Mroczka Connecticut' Yankee Atomic Power Company Haddam Neck Plant cc:

Gerald Garfield, Esquire R. M. Kacich, Manager Day, Berry and Howard Generation Facilities Licensing Counselors at Law Northeast Utilities Service Company City Place Post Office Box 270 Hartford, Connecticut 06103-3499 Hartford, Connecticut 06141-0270 W. D. Romberg, Vice President D. O. Nordquist Nuclear Operations Manager of Quality Assurance Northeast Utilities Service Company Northeast Nuclear Energy Company Post Office Box 270 Post Office Box 270 Hartford, Connecticut 06141-0270 Hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator Radiation Control Unit Region I Department of Environmental Protection U. S. Nuclear Regulatory Commission State Office Building 475 Allendale Road Hartford, Connecticut 06106 King of Prussia, Pennsylvania 19406 Bradford S. Chase, Under Secretary Board of Selectmen Energy Division Town Hall Office of Policy and Managenent Haddam, Connecticut 06103 80 Washington Street Hartford, Connecticut 06106 J. T. Shediosky, Resident Inspector Haddam Neck Plant D. B. Miller, Station Superintendent c/o U. S. Nuclear Regulatory Commission Haddam Neck Plant Post Office Box 116 Connecticut Yankee Atomic Power Company East Haddam Post Office RFD 1, Post Office Box 127E East Haddam, Connecticut 06423 East Hampton, Connecticut 06424 G. H. Bouchard, Unit Superintendent Haddam Neck Plant RFD #1 Post Office Box 127E East Hampton, Connecticut 06424

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s Docket No. 50-213 REQUEST FOR ADDITIONAL INFORMATION CONNECTICUT YANKEE ATOMIC POWER COMPANY (CYAPCO)

HADDNt NECK PLANT The staff has completed the initial review of the Connecticut Yankee Atomic Power Company's June 30, 1987 submittal to the NRC of the Haddam Neck Plant's Third Ten-Year Interval Inservice Testing (IST) Program for pumps and valves.

Based upon the staff's review and discussions with CYAPCO representatives en 1 January 13, 1988 during a working meeting at the Haddam Neck Plant, additional I information will be required for the staff to complete the review and issue a j safety evaluation. -

Please provide your response to the following questions within 30 days.

1. Your schedule for submitting the required additional information to resolve the open items in the attached meeting minutes from the i January 13, 1.988 meeting. The open items are listed in the table below.

Valve Section Questions or Comments: 3, 4, 7, 8, 15, 23, 29, 31

2. The date that you will forward to the staff your revised third ten-year inservice testing program submittal for pumps and valves incorporating the resolutions for the items discussed in the attached January 13, 1988 meeting minutes.

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MINUTES FROM THE NRC STAFF AND THE CONNECTICUT YANKEE POWER CCMPANY MEETING ON THE INSERVICE TEST PROGRAM, JANUARY 13, 1988 A working meeting was held on January 13, 1988, at the Haddam Neck Plant in East Haddam, Connecticut, with Connecticut Yankee Atomic Power Company and NPC representatives in attendance to discuss questions and comments resulting from the NRC's review of the licensee's Third Ten Year Interval Inservice Test (IST)

Program Submittal (developed in accordance with ASME Boiler and Pressure Vessel Code,Section XI, 1983 Edition, including Addenda through Summer 1983) dated June 30, 1937. The staff's questions and comments served as the agenda for the  !

meeting. Each of the staff's questions and comments were discussed during the >

meeting and are included below with the meeting's minutes (comments) following each question. The licensee agreed to take specific actions as documented in the com?ents following each question er comment. The meeting resolved the staff's questions pending the completion of the agreed upon action by the licensee with the exception of open items for the licensee and open items for the staff. The discussions resulted in 8 open items for the licensee and 23 itens to be corrected in their revised submittal. There were also 2 open items for the NRC which have been addressed in Section C.

The purpose of these minutes is to document the results of the above discussions.

The participants were:

A. Asars NRC-RI J. Hunter NRC-RI S. Kucharski NRC-RI J. Calderone Connecticut Yankee J. Celawrence Connecticut Yankee  :

T. Iches Connecticut Yankee M. Smith Connecticut Yankee At the conclusion of the meeting the staff requested that the IST program be revised to incorporate the needed program revisions. The staff stated that the revised licensee's IST program submittal will be used as a basis for the staff's_ safety evaluation of the IST program.

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I I Questions and Comments Concerning the Third Ten Year Interval IST Program l l

! A. Pumps

1. The licensee's IST submittal states in part, "...shall be tested ,

ll within 1 week after the plant is returned to steady state i

! operation...". This is not consistent with ASME Section XI, IWP-3400 l which requires testing within 1 week after the plant is returned to l normal operation which by Section XI defintion includes plant startup.

' l 4 The licensee stated that they will review this item. If they do not ,

j change their program to be consistent with Section XI, then Relief ,

Recuests (RR) for each pump not tested to the Section XI requirements  !

will be included in their revised submittal. ,

2. There are no test frequencies listed in Table IWP-1 as stated in  !

Section 2.5.2 of the program,  :

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The licensee stated that this would be corrected in their revised l l submittal.  !

i j 3. Where are the test metheds of measurement and test durations defined?

The licensee stated that these areas are addressed in test l j procedures.

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! *4. Pump RR2 asks for relief from differential pressure measurement in l

{ the Test Requirement section, however, the basis for relief section '

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- asks for relief from inlet pressure measurement.

j The licensee stated that this was a typographical error and that the j Test Requirement section would be corrected in their revised l j submittal, l

B. Valves

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1. Are there any category D valves at the facility?

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fi The 'lleensee stated that there are no Category 0 valves at Haddam Neck.

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2. The licensee's submittal in section 2.3.3 states in part, " .. shall  ;

be tested to extent necessary to demonstrate that the performance

! parameters which could have been affected are within acceptable t I limits...".Section XI specifies that the testing be performed '

prior to returning the valve to service.

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! The licensee stated that they would be consistent with Section XI I and add "prior to returning to service" to this section in their t i revised submittal.

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3. The licensee has not established limiting values (for determining l the need for corrective action in accordance with section XI,  !

IWV-3417(b)) for the opening and closing times of all power operated valves in the program. l

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! The licensee stated that they would establish limiting values for opening and closing times (based on engineering judgement of i component operability) for all power operated valves in the ,

program. This information will be incorporated into implementing l

< procedures and reviewed by the NRC. j

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4. Does the licensee test all Air Operated Valves (A0Vs) in the fail safe position by obeirving operation of the valve upon loss of actuator power? If not, provide justification in the form of RR's  !

, for each valve not testad. The licensee must also change the  !

4 program to list all tests required by Section XI in the "test  ;

required column" and then submit RR's to justify why some tests are I

not performed.

! The licensee stated that they will review the tests performed on

! their A0Vs and submit RR's if necessary. They also stated that all i tests required by Section XI woutc be listed with RR's submitted to justify why certain tests are not performed.

This item remains open.

s 1 5. Are all containment Isolation valves (CIVs) local leak rate tested?

I j The-licensee stated that all CIVs except for two relief valves and i valves CH-CV-399 and SI-V-860, for which relief has been requested, j are local leak rate tested.

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6. The licensee's submittal in Section 2.3.7 states in part, "...

o ercised within 30 days of returning the system to service...",

however,Section XI states in part "...within 30 days prior to j return to service...".

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The licensee stated that "prior to return to service will be incorporated in Section 2.3.7 in their revised submittal.

7, New are corrective actions controlled for power operated and check valves?

The licensee provided procedure ENG 1.7-55 which was then reviewed by the staff. The staff determined that the procedure did not (a) address evaluation and corrective action for check valves (b) specify "monthly" as the increased frequency in section 6.2.1, and (c) specify "doubled" as the increase in frequency in note Ia.

The licensee stated that the procedure would be revised to incorporate the information in order to become consistent with Section XI. The procedure will be reviewed by the NRC after being revised.

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The item remains open.

8. How are expanded frequencies and corrective action 2 controlled for relief and safety valves?

The licensee stated that maintenance controls this portion of the program and that information would be protided on what maintenance does when a valve fails.

This item remains open.

9. Were any valves added or dropped from the program due to modifications made during the 1987 outage?

The licensee stated that the changes to the program as a result of the modifications would be incorporated in their revised submittal.

10. How are the analysis of leakage rates and corrective action , for leak rates exceeding specified values, controlled to meet the requirements of Section XI, IWV 3426 and 3427.

The licensee stated that procedure EN3 1.7-55 addresses these items.

As stated in question 7 above, the procedure is being reviewed to maky _it consistent with Section XI requirements.

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! 11. Valves SI-MOV-24, RH-MOV-874, RH-FCV-796, RH-FCV-602 and SW-V-271 A,

, B, C, O are listed on both the tested and not subject to testing l s tables. Which is correct? l The licensee stated that valves SI-MOV-24, RH-MOV-874, and SW-V-271

} A, B, C, O are tested and that they will be taken out of table l i IWV-3. The licensee also stated that the SW valve designations j i should be CV not V. The licensee stated that valves RH-FCV-796 and RH-FCV-602 are not tested and that they will be taken out of Table i j IWV-1. The licensee stated that these changes would be incorporated i j! in their revised submittal. L

! 12. Why was the category of RC-CV-509, 523, 536 and 545 changed from B i

to C? Were these valves tested during the 1987 outage?

The licensee stated that these valves are check valves, therefore category C. The licensee also stated that the valves we m tested

! during the 1937 outage and that Note 5 would be dropped from l

Table IWV-1 for these valves in their revised submittal.  ;

13. Why was the category of valves CA-CV-825, 826 changed from C to AC? f The licensee stated that these valves were always category AC and that the previous classification was a typographical error. The  !

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licensee stated that the correction would be incorporated in their j revised submittal, ,

14 Is the RR for position indication for valves $1-MOV-871A, B correct  !

i in Table IWV-17  !

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. The licensee stated that this was a typographical error and that the ,

j RR should be for the leak test requirement. The licensee stated '

i that this would be corrected in their revised submittal.

15. Please provide the normal position, the required safety position and i the procedures used for operability testing for all check valves in  !

the progrr.m.

I i i This item remains open. l 4 i l 16. Is OH-MOV-310 tested even though it is listed as passive in the l t remarks section? 1 1  :

The license 2 stated that this valve is tested.  !

j 17. Is DH-V-311 testeo even though it is listed as passive in the j

remarks section?

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. 1 The licensee stated that this valve is not operability tested and that it will be removed from table IWV-1. It is leak tested and is in Table IWV-4. The licensee stated that the corrections would be incorporated in their revised submittal.

18. Why is there no stroke time (MT) or fail safe (FT) testing specified for valves BD-TV-1312-1, 2, 3, 4?

The licensee stated that they would investigate this and provide the information in their revised submittal.

19. Please provide missir.g information for valves SW-TV-2365A, B; SW-A0V-73SA, B; and CC-RV-7C., B in Table IWV-1.

The licensee stated that they would incorporate the missing information in their revised submittal.

20. Why is there no MT listed for CC-TV-1411 and CH-T'V-3347 The licensee stated that they are not sure what tests are performed and that they would determine what tests are done. The licensee stated that this itani would be addressed in their revised submittal.

21. Why was valve RH-MOV-31 changed from Quarterly to Cold Shutdown?

Where is the justification?

The licensee stated that the justification would be incorporated in their revised submittal.

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, 22. Where is the justification for each CIV tested at Cold Shutdown j rather than Quarterly?

The licensee stated that they would investigate this and include the information in their revised submittal.

23. Are valves PW-CV-139 and FH-CV-296 leak tested? What happened to

] the RR's for operability and leak testing which were in the second ten year interval program?

The licensee stated that they would investigate this item and provide further information.

This item remains open.

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24. Are MT and FT tests performed on valves SS-50V-150A, B, C, 0 and SS-50V-151A, B, C C?

The licensee stated that they would investigate this item. They stated that the Section XI required test will be listed and that RR's would be submitted if they cannot be performed. The licensee stated that this item would be addressed in their revised submittal.

25. Why were valves BD-TV-1312-1, 2, 3, 4; BD-V-506, 515, 522, 529; and FW-CV-192, 194, 196, 198 dropped from the program? The licensee was informed that components cannot be dropped from the program without prior approval by the NRC.

The licensee stated that the valves would be put back into the l program and that they would submit RR's in their revised submittal l

to provide justification why the valves are no longer in the IST l

program. .

26. Where are the RRs listed in Table IWV-2 from valve OH-RV-1847 to the end of the table?

l The licensee stated that this was a typographical error and that the RR's were supposed to be listed for operability testing. The licensee stated that this would be corrected in their revised submittal.

27. Why is there a quarterly test requirement listed for manual valve SI-V-8607 Should the valve be listed as locked closed?

The licensee stated that the valve is not tested and that it should be listed as locked closed. The licensee stated that these changes would be incorporated in th31r revised submittal.

28. Why are valves CH-305A, B, C O Integrated Leak Rate Tested (ILRT) instead of Local Leak Rate Tested (LLRT)?

The licensee stated that the valves are LLRT and that the correction would be incorporated in their revised submittal.

29. Why were valves VH-V-588; PU-V-242A, BV-1-1A, B; HCV-1101; CC-V-884, VH-V-522, 525; RH-MOV-31; SI-V-860; WG-V-984A; SS-50V-150A, B, C, 0;

$5-50V-151A, B, C, 0; SS-V-993A and HC-V-220B dropped from Table IWV-37 Are they in another Table?

The licensee stated that they would determine if the valves were listed elsewhere in the program and provide that information. The licensee also stated that for those valves dropped from the program, they would place them back in the program and submit RRs in their revised submittal to provide justification why the valves are no longer in the IST program. ,

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30. She11d CH-%V-292 be locked open?

j The licensee stated that they would investigate this and correct the  !

program in their revised submittal. l

31. What function does valve CC-CV-802 perform? Why is it listed as  :

passive? Why are there no tests required? -

The licensee stated that they would investigate this item and provide further information.  !

This item remains open. I l 32. Why was LD-RV-205 dropped from the program?

The licensee stated that the valve would be put back into the program and that a RR would be included in the revised submittal to remove '

the valve and provide justification why the valve is no longer in the i

, IST program.

j C. NRC 0:en Items l 4  ;

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1. What are the acceptable methods of testing for normally open check  !'

valves which have a safety function to close; for normally closed check valves which have a safety function to be closed; and for  !

j normally closed check valves that have a safety function to open? Is 1 a leak test sufficient to verify closure of both normally open and j normally closed check valves which have a safety function to close?

Normally Open Check Valves - Safety Function to Close i  !

j IWV-3522(a) states, "Valves that are normally open during plant  !

operation and whose function is to prevent reversed flow shall be j tested in a manner that proves that the disk travels to the seat i j promptly on cessation or reversal of flow. Confirmation that the j i disk is on its seat shall be by visual observation, by an electrical  ;

i signal initiated by a position indicating device, by observation of j appropriate pressure indication in the system, or by other positive  !

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me a rts" . The staff has accepted leak testing as a viable means of  !

i verifying valve closure for those valves which cannot be tested using  !

the code specified methods.

Normally Closed Check Valves - Safety Function To Be Closed I l

j The staff position is that normally closed check valves, that have a }

safety function.in the closed position, should have the closure function verified periodicall; throughout plant life in accordance '

i with the intervals specified u. IWV-3520. The staff has accepted j i

leak testing as a viable means of verifying valve closure.  :

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9 Normally Closed Check Valves - Safety Function To Open The staf f has determined that, for those normally closed check valves of which the full stroke motion of the disk cannot be directly observed or where there is no position indicating device, the following methods are acceptable:

By demonstrating that the valve can pass the full flow which has been taken credit for in the FSAR analyses.

By showing that, for the measured flow, the pressure loss through the valve is such thit the valve could only be full open.

By using a mechanical exerciser which can be observed to move through a full stroke.

By partial disassembly of the valve and manually moving the disk through a full stroke.

This item is closed.

2. What test requirements apply to bo"ndary valves between the class 3 and non-safety class boundary?

All valves which are included in the IST program must be tested in accordance with all of the applicable Section XI requirements unles.1 specific Relief Requests have been submitted to and approved by the staff.

This item is closed.

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