ML20207A882
| ML20207A882 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 07/10/1986 |
| From: | Oconnor P Office of Nuclear Reactor Regulation |
| To: | Schnell D UNION ELECTRIC CO. |
| References | |
| NUDOCS 8607170302 | |
| Download: ML20207A882 (16) | |
Text
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Docket No.: STN 50-482 Mr. Donald F. Schnell Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166
Dear Mr. Schnell:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE CALLAWAY STATION PUMP AND VALVE INSERVICE TESTING PROGRAM The staff is continuing its review of your submittals dated January 31, 1984; May 29, 1984; February 11, 1985; March 11, 1985; June 28, 1985; August 9, 1985; and March 4, 1986. To permit us to continue our review on our current schedule, we require the information requested in Enclosure 1 to this letter be provided.
We have found from past experiences that acceptable responses can best be arrived at through a discussion between our staff, consultants, and your staff. Please notify us when you are ready for us to schedule a meeting to discuss your responses.
Sincerely,
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Paul W. O'Connor, Project Manager PWR Project Directorate #4 Division of PWP, Licensing-A
Enclosure:
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9 Mr. D. F. Schnell Callaway Plant Union Electric Company Unit No. I cc:
Mr. Nicholas A. Petrick Lewis C. Green, Esq.
Executive Director - SNUPPS Green, Hennings & Henry 5 Choke Cherry Road Attorney for Joint Intervenors Rockville, Maryland 20850 314 N. Broadway, Suite 1830 St. Louis, Missouri 65251 Gerald Charnoff, Esq.
Thomas A. Baxter, Esq.
Ms. Marjorie Reilly Shaw, Pittman, Potts & Trowbridge Energy Chairman of the League of 1800 M Street, N. W.
Women Voters of Univ. City, M0 Washington, D. C.
20036 7065 Pershing Avenue University City, Missouri 63130 Mr. J. E. Birk Assistant to the General Counsel Mr. Donald Bollinger, Member Union Electric Company Missourians for Safe Energy Post Office Box 149 6267 Delmar Boulevard St. Louis, Missouri 63166 University City, Missouri 63130 U. S. Nuclear Regulatory Commission Mr. Dan I. Bolef, President Resident Inspectors Office Kay Drey, Representative RR#1 Board of Directors Coalition Steedman, Missouri 65077 for the Environment St. Louis Region Mr. Donald W. Capone, Manager 6267 Delmar Boulevard Nuclear Engineering University City, Missouri 63130 Union Electric Company Post Office Box 149 St. Louis, Missouri 63166 Chris R. Rogers, P.E.
Manager - Electric Department 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator U. S. NRC, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources P. O. Box 176 Jefferson City, Missouri 65102 Mr. Glenn L. Koester Vice President - Nuclear Kansas Gas and Electric Company 201 North Market Street Post Office Box 208 Wichita, Kansas 67201 j
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ENCLOSURE 1
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l CALLAWAY NUCLEAR PLANT PUMP AND VALVE INSERVICE TESTING PROGRAM OUESTIONS AND COMMENTS REQUEST FOR ADDITIONAL INFORMATION I.
Valve Testing Program l
A.
General Questions and Connents 1.
The NRC.posi,tica fo; inseryi.ce testi.ng of valyes!
identified to be tested during cold shutdown is that testing shall commence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching the cold shutdown condition rather than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> specified in the Callaway IST program.
2.
Are all valves that are leak-rate tested in accordance with 10CFR50, Appendix J included in the IST Program and categorized "A" or "AC'?
3.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10CFR50, Appendix J (see relief request V-04). Relief from paragraphs IWV-3421 through -3425 for containment isolation valves presents no safety problem since the intent of IWV-3421 through -3425 is met by Appendix J requirements, however, the utility must comply with the Analysis of Leakage Rates and Correct.ive Action Requirements paragraphs of Section XI, IWV-3426 and -3427. Does the current Callaway IST program meet this NRC staff position?
4.
Are valves (if any) that perform both a containment isolation and a RCS pressure isolation function leak-rate tested to both the Appendix J and the Section XI requirements?
5.
Are the corrective action requirements of Section XI, IWV-3417(a) and (b) followed for all power operated valves at Callaway? The NRC staff will grant relief (if properly requested) from the 1
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trending requirements of Section XI. IWV-3417(a) for solenoid and other valves with normal stroke times less than 2 seconds.
In order to obtain this relief the licensee must assign a maximum limiting stroke time of 2 seconds to these valves and comply with the requirements of IWV-3417(b) when the 2 second limit is exceeded.
6.
Are remote position indicators being verified in accordance with the requirements of Section XI IWV-3300 for all applicable valves in the Callaway IST program?
7.
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 requirements. 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. Does the Callaway IST program conform to this staff position?
8.
What cooling system is used at Callaway Nuclear Plant to meet the control room habitability requirements. Are all applicable pumps and valves in this system included in the IST program and tested in accordance with the Code?
9.
The note on Page 4, Section 2.2.L. states that testing of specific valves during cold shutdown is not required if plant operating conditions will not permit the testing of those valves. It is the staff position that specific requests for relief should be provided for any valves that routinely or frequently fall into this situation.
2
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B.
Feedwater System 1.
Provide the technical justification for not exercising valves AE-V-120,121,122, and 123 during cold shutdowns (refer to relief request AE-1).
C.
Auxiliary Feedwater System 1.
Are any of the following valves ever required to change position in order to mitigate the consequences of an accident or to shut down the reactor to the cold shutdown condition or to maintain it in the cold shutdown condition? If so, they cannot be classified as passive valves and should be tested in accordance with the Code.
AL-HV-5 AL-HV-8 AL-HV-11 AL-HV-6 Al-HV-S AL-HV-12 AL-HV-7 AL-HV-10 r
2.
Review the safety related function of valve AP-V-33 (P&ID M-02AP01 coordinates F-4) to determine if it should be included in the IST program.
D.
Is design accident flow verified through the following check valves when they are exercised? If not, how are these valves full-stroke exercised?
BB-8948A BB-8949A BB-V-001 88-89488 88-89498 BB-V-022 BB-8948C BB-8949C BB-V-040 88-89480 BB-89490 BB-V-059 2.
Do valves BB-8378A, 83788, 8379A, and 83798 perform a pressure boundary isolation function to protect the low pressure piping on the suction of the centrifugal charging pumps?
3 j
5 3.
Is credit taken for the operability of valves BB-V-084 and BB-HV-8145 to reduce plant pressure in order to meet Reactor Systems Branch Position 5.1? If so, these valves should be tested in accordance with the Code unless specific relief is requested.
l 4.
The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise during plant operation and these valves are specifically identified by the licensee and are full-stroke exercised during cold shutdowns. The staff requires that the licensee provide a technical justification for each valve that cannot be exercised quarterly during power operation that clearly explains the difficulties or hazards encountered during that testing. The staff will then verify that it is not practical to exercise those valves and that the testing should be performed during cold shutdowns. The pressurizer PORVs (BB-PCV-455A and 456A) are being exercised during cold shutdowns but no justification has been provided. Provide the justification for exercising these valves at the cold shutdown frequency.
5.
What is the safety related function of valves BB-HV-13,14,15, and 167 6.
Provide a more detailed justification for not exercising valves BB-HV-8001A, 8001B, 8002A, and 8002B quarterly during power operation. Is there an alternate method of verifying the position indication for these valves such as using temperature or pressure indicators on the downstream piping?
E.
Chemical and Volume Control System 1.
Are valves BG-8481A and 8 partial-stroke exercised quarterly during plant operation? Is the boric acid concentration in the boron injection tank maintained at a level above the normal charging water boric acid concentration?
4 1
l' 2.
Does valve BG-8440 perform a safety related function in the closed position?
Can valves BG-8546A and B be exercised while going into the cold 3.
shutdown mode?
4.
Are valves BG-HV-8357A and B fail-safe tested in accordance with the requirements of Section XI IWV-34157 Can some alternate means be used to verify valve position indication (refer to relief request BG-8)?
5.
Valves BG-V-0605 and 0606 do not appear on P&ID M-028G03 Revision 15 at the indicated coordinates. Provide the correct P&ID location for these valves or a P&ID revision that shows these two check valves.
6.
Do air operated valves 8G-FCV-1118, FCV-121, or HCV-182 have a required fail-safe position? If so, they must be exercised to verify that they will go to that required position upon a loss of actuator power.
7.
Describe the boric acid flow paths for which credit is taken to meet the reactivity control system redundancy requirements. Are all applicable pumps and valves in these flow paths included in the IST program and tested in accordance with the Code?
F.
Steam Generator Blowdown System 1.
Can an alternate method, such as a pressure test, be used to verify that the remote valve position indication accurately reflects valve position for the valves referenced in relief request BM-27 5
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G.
Borated Refuelina Water Storace System 8
Do valves BN-HCV-8800A and B have a required fail-safe position?
1.
If so, they must be exercised in the IST program to verify that they will go to their required position upon a loss of actuator power.
H.
Fuel Pool Coolina and Clean-Up System What safety related cooling systems will be used to provide 1.
cooling for the spent fuel pool? Are all applicable pumps and valves in these systems included in the IST program and tested in' J
accordance with the Code? (If credit is taken for the fuel pool cooling pumps, then valves EC-V-004 and 013 should be included in the program and valves EC-HV-11 and 12 may not be passive.)
1.
Component Coolina Water System 1.
Do valves EG-HV-72, 73, 74, and 75 have remote position indicators? If so, will they be checked in accordance with IWV-33007 2.
Are any of the following check valves ever required to change position in order to accomplish any specific function?
EG-V-036 EG-V-124 EG-V-061 EG-V-129 J.
Residual Heat Removal System 1.
Are the following valves leak-rate tested in acccrdance with the Appendix 3 requirements to verify a containment isolation function?
EJ-8841A EJ-HV-8701A EJ-HV-8809A EJ-8841B EJ-HV-8701B EJ-HV-8809B 6
J
4 I
How are Valves EJ-8730A, 87308, 8958A, and 8958B full-stroke 2.
exercised quarterly during power operation. Is design accident flow established through these valves during the quarterly RHR pump test?
Relief request EJ-2 does not appear to be applicable for 8
3.
Therefore, this valve should be exercised in valve EJ-8969A.
accordance with the Code unless an appropriate relief request is provided.
Do valves EJ-FCV-606, 607, 618, and 619 have a required f ail-safe 4.
If so, are they tested to verify this f ail-safe position?
actuation per IWV-3415? Are these valves required to change position in order to take the plant to the cold shutdown condition following an accident?
How is the valve position indication verified for EJ-HV-8811A and 5.
B which are located inside the valve encapsulation tanks?
What is the normal stroke times for 3/4" air operated globe 6,
valves EJ-HCV-8825, 8890A, and 8890B7 What is the basis for the assigned limiting values of full-stroke time for these valves?
Do valves EJ-HV-14 and 15 have a required fail-safe position?
7.
What is 'the normal stroke time of the following 1" solenoid 8.
operated globe valves? What is the basis for the assigned Are the limiting values of full-stroke time for these valves?
. corrective action requirements of IWV-3417 followed for these rapid acting valves? Do these valves have remote position indication?
EJ-HV-21 EJ-HV-23 EJ-HV-25 EJ-HV-22 EJ-HV-24 EJ-HV-26 7
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I Provide a more detailed technical justification for not 9.
8 exercising valves EJ-HV-8804A and B quarterly during power operation?
How does failure of either EJ-HV-8716A or EJ-HV-87168 in the 10.
closed position render both trains of emergency core cooling inoperable (refer to relief request EJ-7)?
Provide the technical justification for not exercising valves 11.
EJ-HV-8811 A and 8 during cold shutdowns.
X.
Hiah Pressure Coolant Iniection System Are the following valves leak-rate tested in accordance with the 1.
Appendix J requirements to verify a containment isolation function?
EM-HV-8802A EM-HV-8835 EM-HV-8801A EM-HV-8843 EM-HV-88028 EM-8815 EM-HV-88018 Are valves EM-HV-8923A and 8 ever required to change position to 2.
take the plant to cold shutdown following an accident?
What is the normal stroke time for 3/4" air operated globe 3.
valves EM-HV-8823, 8824, 8843, 8871, and 89647 What is the basis for the assigned limiting value of full-stroke time for these valves?
How is a full-stroke exercise of valves EM-V-005 and 007 verified 4.
during the quarterly valve exercise test?
5.
Is the boron injection tank ever subjected to boric acid concentrations greater than the RWST concentration, where recirculation would be required to prevent boron precipitation?
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I 6.
What is the norn21 stroke time for the 1" solenoid operated valves EM-HV-8837A and B? Are the corrective action requirements
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of IWV-3417 followed for these rapid acting valves?
L.
Containment Soray System 1.
Provide a more detailed technical justification for not exercising valves EN-HV-1 and 7 quarterly or during cold shutdowns. How is the valve position indication verified for these valves which are located inside the valve encapsulation tanks?
2.
The NRC position is that an alternate means should be used to full-stroke exercise any check valves that perfctm a safety related function which cannot be full-stroke exercised with flow. What alternate means have been considered to full-stroke exercise the following valves?
EN-V-003 EN-V-009 EN-V-004 EN-V-010 3.
The basis for relief in relief requests EN-1 EN-2, and EN-3 need to be expanded to describe some of the possible negative consequences of the listed events.
4.
Is there any concern about chemicals from the spray additive tank contaminating the refueling water storage tank during pump l
testing after valves EN-HV-15 and 16 have been exercised?
M.
Accumulator Safety Injection System
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1.
When a check valve that performs a safety related function cannot i
i be full-stroke exercised with flow, it is the NRC staff position that an alternate means must be used to full-stroke exercise the f
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I valve. What alternate means have beEn considered to full-stroke e
exercise the following valves?
Provide the technical justification for not exercising 2;
valves EP-HV-8950A, B, C, D, E, and F during cold shutdowns.
N.
Auxiliart Feedwater Pump Turbine How are the following valves individually verified to full-stroke 1.
open during quarterly testing? Do these valves perform a safety function in the closed position?
FC-V-001 FC-V-024 FC-V-002 FC-V-025 O.
Containment Hydrogen Control System Is credit taken for the containment air sample and return flow 1.
paths to and from the post accident sampling system? If so, 1
review any safety related function for the following valves to determine if they should be included in the IST program and be exercised in accordance with the Code.
i GS-HV-30 GS-V-054 GS-HV-35 GS-V-059 P.
Comoressed Air System 1.
What is the safety related function of valve KA-HV-307 3
Review the saf ety related function of valves KA-V-703, 704, 705, 2.
and 706 to determine if they should be included in the IST program.
i 10 f
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Standby Diesel Generators 1.
Do any of the following control valves have required fail-safe positions? If they do, then they must be included in the IST program and exercised to verify that they will go to their required position.
KJ-TCV-56 KJ-TCV-34 KJ-TCV-161 KJ-TCV-60 KJ-TCV-158 KJ-TCV-134 KJ-TCV-61 KJ-TCV-160 2.
It is the NRC staff position that the emergency diesel generator air start system performs 'a safety related function and the appropriate system valves should be included in the IST program and be tested in a manner that demonstrates individual valve operability. The following valves may be affected by this staff position.
KJ-PV-1A KJ-V-711A KJ-V-716A KJ-PV-1B KJ-V-711B KJ-V-7168 KJ-PV-101 A KJ-V-712A KJ-V-7I7A KJ-PV-1018 KJ-V-7128 KJ-V-7178 R.
Nuclear Samolina System 1.
Is any credit taken for the post accident operability of the post accident sampling system? If this system is required to function
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to take samples, then the following valves should be tested.as active valves in the IST program.
SJ-HV-3 SJ-V-100 SJ-V-116 SJ-HV-4 SJ-V-101 SJ-HV-133 SJ-HV-20 SJ-y-111 S.
Service Gas System N
1 1.
Is credit taken for the nitrogen supply to the main steam 1 solation and feedwater isolation valves? Is any credit taken 11 1
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I for closure of check valve KH-V-131 in the nitrogen supply line to the valve actuators?
R 12
t II PUMP TESTING PROGRAM 1.
Are lubricant levels or pressures observed during pump testing for all pumps in the Callaway IST program? If not, provide the specific technical justifications for not performing this testing.
2.
The NRC staff position is that the lack of installed instrumentation is not an acceptable long term technical justification for not measuring the Code required parameters on pumps that perform a safety related function. Unless the licensee can demonstrate that a valid alternate method is used to obtain the data required to assess pump condition and determine pump degradation, the licensee should make the necessary system and/or component modifications to allow measurement of the required parameters. Pump program relief request P02 is affected by this position.
1 3.
Provide additional information that justifies the selection of the emergency fuel oil transfer pump discharge piping as the best location for measuring pump bearing vibration to provide an indication of pump mechanical degradation (refer relief request P02).
4.
The 1974 Edition of Section XI did not require measurement of both pump flow and differential pressure in a fixed resistante system, only one of the two parameters was required to be measured. However, all subsequent Code Editions have required the measurement of both parameters to provide a better indication of pump degradation.
Provide a more detailed technical justification for not measuring the flow rate for the centrifugal charging pumps during testing.
5.
Provide the industry data that shows that pump bearing temperature measurements are not good predictors of pump degradation for the staffs review (refer to relief request PO4).
6.
What is the accuracy of the vibration analyzers used at Callaway Nuclear Plant for pump testing? Do these instruments have an accuracy of AS% of three times the pump reference vibration measurements?
t 13
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P 4
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neview the safety related function of the fuel pool cooling pumps to determine if they should be included in the IST program.
8.
Review the safety related function of the boric acid transfer pumps to determine if they should be included in the IST program.
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