ML20196L206

Forwards Request for Addl Info Re Inservice Testing Program, Submitted on 860829 & Revised on 880408.Questions & Comments Encl for Info Will Be Used as Agenda for Meeting.Draft Responses Prepared for Meeting Would Be Desirable

ML20196L206
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/01/1988
From:	Chan T Office of Nuclear Reactor Regulation
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
TAC-62727, NUDOCS 8807070290
Download: ML20196L206 (13)

Text

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'[' - July 1,.1988

. Docket ho.: 50-344 Mr. David !! Cockfield Vice President, Nuclear Portland General Electric Company 121 S.W. Salmor. Street '

Portland, Oregon 97204

SUBJECT:

TROJAN NUCLEAR PLANT - INSERVICL TESTING PROGRAM (TAC N0. 6?727)

The staff has completed its preliminary review of the Inservice Testing (IST)

Program for the Trojan Nuclear Plant as described in Portland General Electric Company's (PGE) submittals dated August 29, 1986, as revised April 8, 1988.

As a result, re find that additional information is required in order for us

-to. complete our review.

A set .of questions and comments is enclosed for your information. It is proposed that this list of questions be used as an agenda for discussion during a meeting at Trojan between the staff and PGE, on a date which will be coordinated with your staff.

Formal responses are not required at this time. However, draft responses ,

prepared for the meeting would be desirable.

Sincerely, original signed by P Terence L. Chan, Project Manager ,

Project Directorate V Division of Reactor Projects - III, fra IV, Y and Special Projects

. gg Office of Nuclear Reactor Regulation 98 cor, cc: See next page (D o ox

Enclosure:

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,, UNITED STATES d, n NUCLEAR REGULATORY COMMISSION h *r WASHIMGTON, b. C. 20555

%.,* July 1, 1988 Docket No.: 50-344 Mr. David W. Cockfield Vice President, Nuclear Portland General Electric Company 121 S.W. Salmon Street .

Portland, Oregon 197204

Dear Mr. Cockfield:

S!JBJECT: TROJAN NUCLEAR PLANT - INSERVICE TESTING PROGRAM (TACNO.62727)

The staff has completed its preliminary review of the Inservice Testing (IST)

Program for the Trojan Nuclear Plant as described in Portland General Electric Company's (PGE) submittals dated August 29, 1986, as revised April 8,1988.

As a result, we find that additional information is required in order for us to complete our review.

A set of questions and comments is enclosed for your information. It is proposed that this list of questions be used as an agenda for discussion during a meeting at Trojan between the staff and PGE, on a date which will be cocrdinated with your staff.

Formal responses are not required at this time. However, draft responses prepared for the meeting would be desirable.

Sincer ,

- 4 +'. A m .n T rence L. Chan, Project Manager Project Directorate Y Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Re '+or Regulation cc: See next page

Enclosure:

As stated.

e Mr. David W. Cocifield Portland General Electric Company Trojan Nuclear Plant cc:

• Senior Residenthinspector U.S. Nuclear-Regulatory Commission Trojan Nuclear Plant Post Office Box 0 Rainier, Oregon 97048 Mr. Michael J. Sykes, Chairman Board of County Commissioners Columbia County St. Helens, Oregon 97501 -

Mr. William T. Dixon Oregon Department of Energy Salem, Oregon 97310 Regional Administrator, Region V V.S. Nuclear Regulatory Commission -

1450 Maria Lane, Suite 210 Walnut Creek, California 94596 o

ENCLOSURE I s ,

TROJAN NUCLEAR PLANT PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND C0ffiENTS

1. VALVE TESTING PROGRAM A. General Questions and Comments

1. Provide a list of all valves that are Appendix J, type C, leak rate tested but not included in the IST program and categorized A or A/C.

2. The NRC staff position is that the emergency diesel generators perform a safety function and that the appropriate valves in the emergency diesel air start system should be included in the IST program and tested to the Code requireme..ts.

3. 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 the valve would be an adequate demonstration of the full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differential pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve. If there are any check valves in the Trojan Nuclear Plant IST program whose full-stroke testing does not conform to this staff position, provide a discussion on how their full-stroke capability is verified.

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4. The NRC 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 valves, if any, at Trojan Nuclear Plant, that serve both a pressure boundary isolation function and a containment isolation function. What leak rate testing is performed on these valves't 1

5. Are valves remote position indications verified every two years as required by Section XI, IWV-33007

6. Are power operated valves with fail-safe actuators tested in accordance with the requirements of Section XI, IWV-3415?

7. Provide the limiting values of full-stroke times for the power onerated valves in the Trojan Nuclear Plant IST program for our review. What are the bases used to assign the limiting values of full-stroke time for these valves?

8. Solenoid operated valve,s are not exempted from the stroke time measurement requirements of Section XI. Their stroke times must be measured and corrective action taken if these times exceed the limiting value of full-stroke time. The NRC staff will grant relief from the trending requirements of Section XI, Paragraph IWV-3417(a), for these rapid acting valves, however, in order to obtain this relief the licensee must assign a maximum limiting stroke time of 2 seconds to these valves and perform corrective action as required by IWV-3417(b) if the measured stroke times exceed the 2 second limit.

B. Reactor Coolant System

1. Provide a more detailed technical justification for not full-stroke exercising valves SV-1015A, SV-1015B, SV-1016A, and SV-1016B quarterly.

2. What is the safety function of valve CV-8032?

3. What are the consequences of full-stroke exercising valves 8900A, 8900B, 8900C, and 8900D during cold shutdown? Could this testing result in a low temperature overpressurization af the RCS?

4. Is RHR pump flow sufficient to full-stroke exercise valves 8948A, 89488, 8948C, and 8948D during cold shutdown (see comment A-3 of this RAI)?

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5. What are the consequences of full-stroke exercising valves 8949A,

, 8949B, 89490, and 89490 during cold shutdown? Could this testing result in a lo'w temperature overpressurization of the RCS?

6. If valves 8046 and 8047 are required to operate during power operation, then they are not passive and should be full-stroke exercised quarterly,

7. What is the safety function of valves 8090A and 8090B?

C. Chemical and Volume Control System

1. What are the consequences of valve failure during quarterly full-stroke exercising of valves M0-1128, MO-11?C, M0-1120, and M0-112E?

2. If valves MO-8105 and MO-8106 are required to be Appendix J, type C, leak rate tested, then they must be categorized A. What are the consequences of valve failure during quarterly full-stroke exercising of these valves?

3. What are the consequences of valve failure during quarterly full-stroke exercising of valve CV-81527

4. How are valves 8481A and 8481B verified to full-stroke open quarterly?

5. What are the consequences of full-stroke exercising valve 8546 during cold shutdown? Could this testing result in a low temperature overpressurization of the RCS?

6. Review the safety function of the following valves to determine if they should be included in the IST program and tested to the Code requirements: .(note: valves on figure 9.3-14) 8442 (location C-4) 8473 (location C-1) 8487 (location C-2) 8480A (location C-6) 8480B (location B-6) 8497 (location D-6) 3

7. Provide a more detailed technical justification for not full-stroke exercising valves M0-8100 and M0-8112 quarterly and during cold shutdown. l

8. If valves 8368A, 8368B, 83680, and 8368D are required to be Appendix J, type C, leak rate tested, then they must be categorized A.

D. Residual Heat Removal System

1. How are valves 8730A and 8730B verified to full-stroke exercise quarterly? i

2. Provide a more detailed technical justification for not full-stroke exercising valves MO-8804A and M0-8804B quarterly.

3. What are the consequences of exercising valves MO-8811A and MO-8811B quarterly? Could this testing void the suction piping of the RHR pumps?

4. Provide a more detailed technical justification for not full-stroke exercising valve MO-8812 quarterly.

5. Provide a more detailed technical justification for not full-stroke exercising valve 8958 quarterly and during cold shutdown.

6. If valves M0-8700A, MO-8700B, MO-8703, M0-8809A, and MO-8809B are required to be Appendix J, type C, leak rate tested, then they must be categorized A.

E. Safety Injection System

1. What are the consequences of full-stroke exercising the following valves during cold shutdown? Could this testing result in a low temperature overpressurization of the RCS?

8815 8819A 8819B 8819C 8819D 8905A 89058 8905C 8905D 8922A 8922B 4

- - 2. How is valve 8926 verified to full-stroke open quarterly?

4 3. Provide a more detailed technical justification for not full-stroke exerci:ing valves 8956A, 8956B, 8956C, and 8956D during cold shutdown. How is the required safety flow of these check valves verified?

4. If valve 8968 is required to operate during power operation, then it is not passive and should be full-stroke exercised quarterly.

5. Branch Technical Position RSB 5-1 establishes requirements for taking reactor plants f' rom power operations to cold shutdown using only safety grade equipment. To comply with this position, credit is generally taken for the safety injection accumulator vent paths *. Evalt. ate the safety function of the following valves to determine if they should be included in the IS1 program and tested to the Code requirements:

CV-8875A* CV-8875B* CV-8875C*

CV-8875D* HCV-943*

6. If valves MO-8801A, M0-8801B, MO-8802A, MO-8802B, and MO-8835 are required to be Appendix J, type C, leak rate tested, then they must be categorized A.

7. Review the safety function of the following valves to determine if they should be included in the IST program and tested to the Code requirements: (note: valves n figure 6.3-1b) 8823 (location E-7) 8824 (location B-6) 8843 (location F-6) 8881A (location E-6)

MO-8803A (location E-4) MO-8803B (location D-3) 5

F. Containment Spray System

1. How are valves CS 2001, CS 2002, CS 2003, and CS 2004 verified to full-stroke open quarterly?

2. Provide a more detailed technical justification for not full-stroke exercising valves CS 028 and CS 029 during cold shutdown.

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

Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

A different valve of each group is required to be disassembled, inspected, and manually full-stroked at each refueling until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, then the remainder of the valves in that group must also be disassembled, inspected, and manually full-stroked at the same outage.

The containment spray system valve relief request will be affected by this NRC position.

3. If valves CS 028 and CS 029 are required to be Appendix J, type C, i leak rate tested, then they must be categorized A.

l 4. If valves H0-2052A, MO-2052B, M0-2053A, MO-2053B, M0-2069A, and MO-2069B are required to be Appendix J, type C, leak rate tested, then they must be categorized A.

5. Are valves PSV-2084 and PSV-2085 spring loaded devices or simple check valves? If these valves are simple check valves, they should be full-stroke exercised quarterly.

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G. Main Steam System i

i t 1. How is the closure capability of valves MS 2001, MS 2002, MS 2003, and MS 2004 verified during cold shutdown?

2. How are valves MS 2006, MS 2007, MS 2008, and MS 2009 verified to l full-stroke open quarterly?

3. How are the following valves individually verified to close quarterly?

MS 220 MS 221 : MS 222 MS 223 MS 224 MS 225 MS 226 MS 227 H. Main and Auxiliary Feedwater

1. How are valves FW 2033 and FW2034 verified to full-stroke open and closed during cold shutdown?

2. How are valves FW 2027, FW 2028, FW 2029 and FW 2030 verified to full-stroke open quarterly?

3. How is the dosure capability of valves FW 2017, FW 2018, FW 2019, and FW 2020 verified during cold shutdown?

4. How are the following valves verified to full-stroke open and close during cold shutdown?

FW 2005 FW 2009 FW 2013 FW 2006 FW 2010 FW 2014 FW 2007 FW 2011 FW 2015 FW 2008 FW 2012 FW 2016

5. How is valve SW 2002 verified to full-stroke open quarterly?

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6. Review the safety function of the following valves to determine if they should be included in the IST program and tested to the Code requirements: (note: valves on figure 10.4-2C except FW 2035)

FW 2035 (fig. 10.4-2B, location B-6)

FW 2001 (location B-4) FW 2002 (location A-4)

MO-2947A (location B-4) MO-2947B (location C-4)

I. Component Cooling Water System

1. If valves M0-3290, M0-3291, MO-3292, and MO-3346 are required to be Appendix J, type C, leak rate tested, then they must be categorized A.

2. How are valves CC 2037, CC 2038, CC 2039, and CC 2040 verified to full-stroke open quarterly?

3. The containment air coolers (8 total) need to have their component cooling water air vent valves (32 total) added to the IST program and tested to the Code requirements.

4. Review the safety function of valves CC 2033, CC 2034, CC 2044, and CC 2045 to determine if they should be included in the IST program and tested to the Code requirements.

5. Provide a more detailed technical justification for not full-stroke exercising valves CC 2035, CC 2036, CC 2046, and CC 2047 during cold shutdown.

J. Service Water System

1. Review the safety function of the following valves to determine if

! they should be included in the IST program and tested to the Code l requirements:

l cW 022 SW 023 SW 024 SW 025 SW 026 SW 027 l

l SW 028 SW 042 SW 043 SW 044 SW 045 SW 223 8

2. How are valves si' ?n03, SW 2004, and SW 2005 verified to full-stroke open and' closed quarterly?

. 3. Provide the P&ID that shows valves SW 2012, SW 2013, SW 395, and SW 397 for the staff's review.

K. Instrument and Service Air Systems

1. Provide a more detailed technical justification for not full-stroke exercising valves IA 2001 and CV 4471 quarterly and during cold shutdown.

2. Provide a detailed tech'nical justification for not full-stroke exercising valve SA 2005 quarterly.

L. Diesel Fuel Oil System

1. How are valves DO 2001 and DO 2002 verified to full-stroke open quarterly?

M. Spent Fuel Pool Cooling System

1. Review the safety function of valves SF 2003 and SF 2004 (fig. 9.1-4, locations C-5 and B-5) to determine if they should be included in the IST program and tested to the Code requirements.

N. Containment Personnel Air-Lock Leak Detection System

1. Provide the P&ID that shows valves SV 6991 and SV 6992 for the staff's review.

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• II. PUMP TESTING PROGRAM

. 1. What safety grade cooling is provided to the spent fuel pool? Do the spent fuel pool cooling pumps perform any safety function? If so, they should be included in the IST program and tested to the Code requirements.

2. Pump relief request 3.2.1 for service water pumps states that the pump motor inboard bearing will be periodically monitored for vibration amplitude. What is the specific frequency that this vibration measurement is performed?

3. Provide the documentation that demonstrates that the diesel fuel oil transfer pumps' hydraulic performance is assured in accordance with the Code requirements when operational readiness is demonstrated by the pumps' ability to supply 20 gpm makeup to the day tanks (as assumed in the FSAR).

4. Flowrate and differential pressure curves utilized for component cooling water pumps' operability need to be pump specific to be acceptable to the staff.

5. Lack of installed instrumentation is not a suitiable long term justification for not measuring the Code required parameters during pump tests. What alternate means of flowrate measurement have been considered for the boric acid transfer pumps, auxiliary feedwater pumps, and the centrifugal charging pumps?

6. Provide the technical justification for not measuring bearing temperature annually or flowrate quarterly for the component cooling water makeup pumps. What safety function do tnese pumps provide?

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