ML20205Q804

Forwards Request for Addl Info Re Inservice Testing Program. NRC Should Be Contacted to Arrange for Meeting to Discuss Util Response

ML20205Q804
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/31/1987
From:	Norris J Office of Nuclear Reactor Regulation
To:	Farrar D COMMONWEALTH EDISON CO.
References
NUDOCS 8704060053
Download: ML20205Q804 (8)

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~ March 31, 1987.

o Docket Nos. 50-295 DISTRIBUTION

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and 50-304 pocastemej NRC PDR Local PDR " PDf3 Rdg.

T. Novak .0GC Mr. Dennis L. F3rrar E. Jordan B. Grimes Director of Nuclear Licensing J. Partlow N. Thompson Comonwealth Edison Company J.Norris C. Vogan Post Office Box 767 ACRS (10)

Chicago, Illinois 60690

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - INSERVICE TESTING (IST)

PROGRAM - ZION NUCLEAR POWER STATION, UNITS'1 AND 2 The staff and its contractor, EG&G Idaho, has reviewed Zion IST program for pumps and valves. The review revealed that additional information, outlined in the enclosure, is necessary before the staff can complete its review of the Zion.IST program.

The staff found from past experience that responses can be obtained more efficiently during.a meeting between the licensee, EG&G and the staff.

We request therefore, that when your responses are ready, you contact the NRC Project "anager to arrange such a meeting.-

The reporting and/or recordkeeping requirements of this letter affect fewer than ten recoondents; therefore, OMB clearance is not required under ,

PL 96-511.

Sincerely, Jan A. orris, Project Manager Project Directorate #3 Division of PWR Licensing-A

Enclosure:

As stcted cc: See next page PDf3 Di l 3 63 JNorr s:pds CVogan 3/9 /87 3/q /87 i

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l 8704060053 870331 l PDR ADOCK 05000295 P PDR i

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e' Mr. D. L. Farrar Commonwealth Edison Company Zion Station cc:

Robert J. Vollen Esquire Mr. Michael C. Parker, Chief 109 North Dearborn Street Division of Engineering Chicago, Illinois 60602 Illinois Department cf Nuclear Safety Dr. Cecil Lue-Hing 1035 Outer Park Drive, 5th Floor Director of Research and Development Springfield, Illinois 62704 Metropolitan Sanitary District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611 Mr. P. Steptoe Isham, Lincoln and Beale Counselors at Law Three First National Plaza 51st Floor Chicago, Illinois 60602 Mayor of Zion Zion, Illinois 60099 Illinois Department of Nuclear Safety ATTN: Manager, Nuclear Facility Safety 1035 Outer Park Drive, 5th Floor

. Springfield, Illinois 62704 U.S. Nuclear Regulatory Commission Resident Inspectors Office 105 Shiloh Blvd.

Zion, Illinois 60099 Regional Administrator, Region III U.S. Nuclear Reguiatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

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ZION NUCLEAR POWER STATION, UNIT 1 AND 2 e PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS

1. VALVE TESTING PROGRAM i

A. General Questions and Comments

1. Valve Position #12 appears to request relief from a Code requirement. Therefore, suitable justification must- be provided demonstrating the impracticality of meeting the Code requirement.

2. The Code (IWV-3416) states that valves in systems out of service need not be exercised quarterly, however, these valves will be exercised within 30 days prior to return of the system to i service. Are the valves addressed in Valve Position #13 in

! systems out of service?

3. What criteria is utilized for assigning limiting values of full-stroke time for power operated valves?

4. The statement on page 212a "...where the Code requirement (sic) conflict with Zion's stated " Positions", the Positions shall supersede Section XI" is unacceptable to the staff. The reqairements of Section XI must be met unless specific relief is requested and subsequently granted by the NRC.

B. Condensate Storage System

1. Do valves MOV-FWOO74, 0075, and 0076 perform a safety function in the closed position?

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V C. Diesel Oil / Generator System

1. Provide P&ID's No. M-38 and M-530.

2. Can one diesel air start check valve be verified to full-stroke open during each regularly scheduled diesel generator test (monthly?) to satisfy the Section XI quarterly test requirement for each valve.

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3. Valve Relief #30 is not necessary since valve full-stroke is defined by the NRC as opening sufficiently to pass the maximum flow rate identified in any of the plant's. safety analyses.

D. Isolation Valve Seal Water System

1. The information presented in Valve Position #10 is a deviation I

from the Code requirements, therefore, a specific request for i relief must be provided with a detailed technical justification demonstrating the impracticality of complying with the Code requirements.

E. Containment spray System

1. Valve Relief #13 is unnecessary since the longest interval

. between tests is at least as often asSection XI requires.

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2. Why were valves MOV-CS0002, 0004, and 0006 categorized A and not leak-tested and valves MOV-CS0005, 0009, and 0013 not categorized A when they are leak tested?

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o F. Chemical and Volume Control' System

1. Has the ultrasonic flow instrumentation been permanently installed in the charging pump miniflow line (see Valve Relief

1. 23) to verify the full-stroke capability of valves VC8542A and B quarterly?

G. Residual Heat Removal System

1. Valve Relief #4 is unnecessary since valves RH8730A and B are

! being exercised during cold shutdowns in accordance with the Code l requirements.

2. How is full flow verified through each of valves RH8736A and 8 and RH8949A and B?

3. Can valve RH8958 be full-stroke exercised quarterly utilizing the j test line to the refueling water storage tank via SI8735?

H. Safety Injection System

$ 1. How is full-stroke verified for each of the following valves:

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.' S!8905 A and B SI8949 A and B SI9004 A and B SI9012 A thru D t

2. Has a test been implemented to verify closure of valve SI89127

3. Have the accumulator discharge check valves, SI8948 A thru 0 and 2 SI8956 A thru D, been full-stroke exercised (see Valve Relief #9) l by dumping the accumulators under nitrogen pressure into the partially drained refueling cavity during refueling with the reactor vessel head removed? How is the flow-rate through these valves measured?

i' a. Is the flow through valves SI9001A thru D and SI9002A thru D

sufficient to verify their full-stroke capability during cold shutdown residual heat removal operations?

5. Has the leak-rate testing proposed in Valve Rel'ief #25 been successfully performed or are valves SI9002A thru D verified 4

leak-tight by performing valve disassembly and inspection?

6. Should valve SI8857 be categorized A/C since it appears to be leak-rate tested per Appendix J7 I. Containment Air Monitoring System

1. Valve Relief #14 is unnecessary since the longest interval i

between tests on valves PR0029 and 0030 is at least as often asSection XI requires.

2. Should valve PR0029 be categorized A/C?

3. Why is valve PR0030 leak-rate tested according to Appendix J but (IT ,  ;

not required to be shut following an accident (see CECO's revised response to NRC Question P-3, Attachment 4, page 2, of'the letter from P.C. Le Blond to Harold R. Denton dated June 17,1986.)

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, J. Instrument Air System i

1. Provide a more detailed technical justification for not l i

full-stroke exercising valves FCV-IA01A and IA01B during cold I shutdowns.

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2. PUMP TESTING PROGRAM-

1. The statement on page 174a "...where the~ Code requirements-conflict with Zion's stated " Positions", the positions shall supersede Section XI." is unacceptable to the staff. The requirements of.Section XI must be met unless specific relief is requested and subsequently granted by the NRC.

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2. Provide a more specific technical justification for not meeting the allowable' ranges of test quantities'as specified in TABLE IWP-3100-2 (see Pump Position #1).

3. Since +.he component cooling water pumps, OCC003 thru-0CC007, are known to be operating slightly above the manufacturer's provided pump curve, pump specific curves or repeatable' reference values t should be developed for each of these pumps and the alert and required action limits as-specified by the Code should be applied to these unique curves (see Pump Relief #1).

4. The-NRC recognizes that operation of only one-service water pump _

during power operation at Zion Station is impractical for performance of the Section XI required testing. However, a test method should be developed that provides information similar to 4

that required by the Code for quarterly evaluation of operational readiness and pump degradation for the service water pumps, SW001, 002, and 003 (see Pump. Relief #2).

5. The NRC Staff agrees that measurement of vibration velocity for

- safety related pumps can provide better information for

evaluation of pump _ degradation and assessment of continued operability than measurement of vibration displacement as required by Section XI. However, the only NRC Staff acccptable-criteria is provided in ASME OM-6, draft 8, "An American National 1

Standard _In-Service Testing of Pumps" (see Pump Relief #3). I

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.I 6. What alternative testing is proposed in Pump Relief #4 in lieu of the Code required pump bearing temperature measurements?

7. From which Code requirements is relief being requested in Pump ,

-Relief #S? -Does the installed instrumentation meet the accuracy requirements of Section XI,' Table IWP-4110-1?

8. Has the instrumentation referenced in Pump Reliefs #7 and #8 been installed in these systems? Do these instruments meet the accuracy requirements of Section-XI?

9. How do the pump reference values established per IWP-3100 compare to the manufacturer's supplied pump curves? Is.the full pump flow seen in the flow instrument indication or is a portion of the pump's flow diverted through the miniflow line?

10. Why has the test requirement for bearing temperature measurement *

and lubrication level or pressure considered N/A for the residual heat removal pumps RH001 and 2 when the previous IST program specifically stated that these parameters would be measured and/or observed?

11. Why were the spent fuel cooling pumps deleted from the IST.

program?

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