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Forwards Rev 7 to Inservice Testing Program,Callaway Nuclear Plant. Changes Will Be Fully Implemented by End of Refuel 2 Outage
	ML20207Q154
Person / Time
Site:	Callaway
Issue date:	01/14/1987
From:	Schnell D; UNION ELECTRIC CO.
To:	Harold Denton; Office of Nuclear Reactor Regulation
Shared Package
ML20207Q155	List: ML20207Q154; ML20207Q156;
References
	ULNRC-1426, NUDOCS 8701230125
	Download: ML20207Q154 (11)
	v • d • e

,

Union ELECTRIC s

1901 Gratet Street, St. Louis Donald F. Schnell

#" *"' January 14, 1987 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

ULNRC- 14 26 CALLAWAY PLANT DOCKET NUMBER 50-483 CALLAWAY PUMP AND VALVE INSERVICE TESTING PR3 GRAM

References:

1) ULNRC-738 dated January 31, 1984

2) ULNRC-833 dated May 29, 1984

3) ULNRC-lO39 dated February 11, 1985

4) ULNRC-ll27 dated June 28, 1985

5) ULNRC-ll52 dated August 9, 1985

6) ULNRC-1267 dated June 28, 1986

7) P. W. O' Conner letter to D. F. Schnell dated July 10, 1986 Reference 1 transmitted the Callaway Pump and Valve Inservice Testing Program. References 2 through 6 transmitted updates to this same program.

Included as attachments to this letter are further updates to the Callaway Testing Program. Attachment 1 is a brief description of the changes and Attachment 2 contains a copy of the revised program in its entirety. The changes to testing resulting from these program changes will be fully implemented by the end of the Refuel 2 outage.

If you have any additional questions, please contact me.

Very truly yours, m

Donald F. Schnell WEK/ mat Attachments 7q

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8701230125 870114 PDR ADOCK 05000483 PDR I(

P Mailing Address: P.O. Box 149, St. Louis, MO 63166

STATE OF MISSOURI )

) SS CITY OF ST. LOUIS )

Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union LElectric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to th'e best of his knowledge, information and belief.

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By Donald F. Schnell Vice President Nuclear SUBSCRIBED and sworn to before.me this / day of ,198[,

W D / b y[

BARBARAM PFAF[ f NOTARY PUBUC, STATE OF MISSOUR1 MY COMMISSION EXPIRES APRIL 22, 1983 ST. Louis county i

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ccs. Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge .

t 1800 M. Street, N.W.

Washington, D.C. 20036 Nicholas A. Petrick Executive Director l SNUPPS !'

5 Choke Cherry Road Rockville, Maryland 20850 W. L. Forney Division of Projects and Resident Programs, Chief, Section lA ,

U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little

_Callaway Resident Office U.S. Nuclear Regulatory Commission RR#1 Steedman,' Missouri 65077 Paul O'Connor (2)

Office of Nuclear Reactor Regulation

-U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public' Service Commission P.O. Box 360 Jefferson City, MO 65102 ,

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A'TTACHMENT 1 PAGE 1 of 8 CHANGES TO CALLAWAY NUCLEAR PLANT INSERVICE TESTING PROGRAM ITEM 1: CHANGE: Revise section 2.2.L to state that valve testing at cold shut-down will commence not later than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months af ter reaching cold shutdown, rather than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

BASIS FOR CHANGE: Per meeting with EG&G, it is the NRC's position that:

cold shutdown valve testing shall be initiated within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months upon reaching cold shutdown.

ITEM 2: CHANGE: Delete IWV-3426 and IWV-3427 from relief request V04.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC will not grant relief from IWV-3426 and IWV-3427.

ITEM 3: CHANGE: Delete relief requests BB-10, BB-11, BG-8, BM-2, EF-1, EM-4, and V05. Add note 13 stating " Position indication will be performed by verification of flow conditions" to the affected valves.-

BASIS FOR CHANGE: Verification of flow conditions is an acceptable test of position indication per the Section XI code and therefore a relief request is not needed for this test method. It has been determined that position indica-tion testing using flow can be performed for valves associated with relief requests BB-11, EF-1, EM-4, V03, BB-10, BG-8, and BM-2.

ITEM 4: CHANGE: Revise note under section 2.2.L to state that specific cold shutdown justifications will be written for valves to be tested upon reaching cold shutdown. The following relief requests are now effective cold shutdown justifications:

AB-1, AB-2, AE-3, AE-4, AL-1, BB-3, BB-5, BB-6, BB-8, BB-9, BG-2, BG-3, BG-6, BG-7, BM-1, BN-1, BN-2, EJ-1, EJ-3, EJ-4, EJ-5, EJ-7, EM-6, EN-4, EP-1, EP-4, KA-1 BASIS FOR CHANGE: Per meeting with EG&G, it is the NRC's position that the utility will provide specific justification for valves tested during cold shutdown.

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, ATTACHMENT 1 PAGE 2 cf 8 ITEM 5: CHANGE:. Revise relief request AE-1 to give further justification in basis for relief. Alternate testing changed from full stroke testing to valve disassembly on refueling frequency.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests further justification for relief request AE-1. Method of full stroke exercising without dissassembly has not been developed..

ITEM 6: CHANGE: Add valve AP-V-0033 to test program. Add relief request AP-1 (cold shutdown justification) to full stroke exercise the valve during cold shutdown and partial exercise the valve during normal power operations.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests that this valve be added to the test program.

ITEM 7: CHANGE: Revise relief request BB-1 to change alternate testing from full stroke testing to valve disassembly and inspection on refueling frequency.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC holds the position that the valves in this relief request, BB-8948A, B, C,

. and D, should be tested by disassembly and inspection on a refueling frequency since accident required flowrates cannot be attained.

L ITEM 8: CHANGE: Add new relief request BB-10 (cold shutdown justification). Add fail safe testing to valves BB-PCV-455A and BB-PCV-456A at cold shutdown.

l BASIS FOR CHANGE: Relief request and fail safe testing were inadvert-ently omitted from the program.

f ITEM 9: CHANGE: Revise relief request BB-5 to provide further technical justifi-(

cation for exercising BB-HV-8001A & B and BB-HV-8002A & B at

cold shutdown.

l BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests a more de-tailed justification for testing valves l

BB-HV-8001A & B and BB-HV-8002A & B at cold shutdown.

riJM 10: CHANGE: Add partial stroke testing on a normal power operation frequency to relief request BG-4 for valves BG-8481A & B. Remove note 5 from NOTES column for these valves.

BASIS FOR CHANGE: These valves can be partial stroke tested during power l operation.

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. ATTACHMENT 1 PAGE 3 cf 8 ITEM 11: CHANGE: Revise relief request BG-5 to add further justification to the basis for relief.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests further technical justification for full stroke testing valves BG-8546A & B at refuel frequency as addressed by relief request BC-5.

ITEM 12: CHANGE: Add fail safe testing at normal power operation frequency for valves BG-HV-8357A & B.

BASIS FOR CHANGE: Fail safe testing was inadvertently omitted.

ITEM 13: CHANGE: Add. Boric Acid Transfer Pumps PBG02A & B to the test program.

l Add relief request BG-8 (cold shutdown justification) to exer- '

i cise check valves BG-V-0147, BG-V-0165, BG-V-0174. Add check valve exercising for valves BG-V-0155 and BG-V-0167 during.

normal power operations. Add position indication testing and full stroke testing for BG-HV-8104.

BASIS FOR CHANGE: Per meeting with EG&G, it is the NRC's position that the Boric Acid Transfer Pumps and associated system flowpath valves be added to the test program.

ITEM 14: CHANGE: Delete valves BM-HV-19, 20, 21, and 22 from test program. Add note 3 to NOTES column for these valves.

BASIS FOR CHANGE: These passive valves do not require testing.

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ITEM 15: CHANGE: Add position indication testing for valves EG-HV-72, 73, 74, i and 75.

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BASIS FOR CHANGE: These valves require position indication testing per l

i Section XI IWV-3300. Position indication testing was inadvertently omitted from the program.

I ITEM 16: CHANGE:' Delete relief request EG-1 and valves EG-HV-0126, 0127, 0130, 0131, 0132, 0133 from the test program. Add note 3 to NOTES l column for these valves.

BASIS FOR CHANGE: These are by-pass valves around containment isolation valves. These are normally closed and do not require testing.

ITEM 17: CHANGE: Delete the open test direction for seat leak testing EG-V-0204.

BASIS FOR CHANGE: EG-V-0204 is normally open and needs testing only in the closed direction.

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.ATIACHMENT 1'

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PAGE 4 cf 8 ITEM 18: CHANGE: Add relief request EJ-8. Valves EJ-8958A & B will be partial stroke tested every three months and full stroke tested on a refueling frequency per relief request EJ-8.

BASIS FOR CHANGE: See relief request EJ-8. -

ITEM 19: CHANGE: Add relief request EJ-10. Valves-EJ-8730A & B will be partial stroke tested every three months and full stroke tested on a cold shutdown frequency.

BASIS FOR CHANGE: See relief request EJ-10.

ITEM 20: CHANGE: Delete valve EJ-8969A from relief request EJ-2. Add relief request EJ-9 to provide relief justification for EJ-8969A.

BASIS FOR CHANGE: See relief request EJ-9.

ITEM 21: CHANGE: Delete valves EJ-HCV-8825, 8890A, and 8890B from test program.

Add note 3 to NOTES column for these valves.

BASIS FOR CHANGE: These are passive valves and do not require testing.

ITEM 22: CHANGE: Delete valves EJ-HV-21 and 22 from test program. Delete stroke testing valves EJ-HV-23, 24, 25, and 26.

BASIS FOR CHANGE: These valves are part of the post-accident sampling system which performs no safety-related function except containment isolation. These valves are passive. The only testing required is leak testing the containment isolation valves.

ITEM 23: CHANGE: Add additional basis for relief to relief request EJ-4.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests a more de-tailed justification for not testing EJ-HV-8804A & B on a normal power operations frequency.

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ITEM 24: CHANGE: Add additional basis for relief to relief request EJ-6.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests a more de-i tailed justification for not testing EJ-HV-8811A & B on a cold shutdown frequency.

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! ITEM 25: CHANGE: Add additional basis for relief to relief request EJ-7.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests further justification for not testing EJ-HV-8716A & B on a normal power operations frequency.

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~. ATTACHMENT 1

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PAGE 5 cf 8 ITEN 26: CHANGE: Delete valves EM-HV-8823, 8824, 8843, and 8881 from the test program and add note 3 to NOTES column for these valves. Delete full stroke testing, fail safe testing, and position indication testing for valves EM-HV-8871 and EM-HV-8964.

BASIS FOR CHANGE: Valves EM-HV-8823, 8824, 8843, and 8881 are passive and not Appendix J Type C leak rate tested, so testing is not required. Valves EM-HV-8871 and 8964 are Category A passive which require only seat leak testing.

ITEM 27: CHANGE: Revise the alternate testing frequency of relief request EN-4 from refueling to cold shutdown.

BASIS FOR CHANGE: It has been determined that EN-HV-0001 and EN-HV-0007 may be tested at a cold shutdown frequency.

ITEM 28: CHANGE: Add additional documented basis for relief to relief requests

EN-1, EN-2, and EN-3.

BASIS FOR CHANGE: Per meecing with EG&G, the NRC requests that an expanded basis for relief be provided for these relief requests.

ITEM 29: CHANGE: Revise the testing of valves EP-8956A, B, C, & D from a partial exercise test to valve disassembly, inspection, and manual full ,

stroking per relief request EP-2.

BASIS FOR CHANGE: Per meeting with EG&G, it is the NRC's position that these valves be disassembled and tested by this method since accident required flows cannot be attained.

ITEM 30: CHANGE: Revise test frequency from refuel to cold shutdown for valves EF-HV-8950A, B, C, D, E, and F per relief request EP-4.

BASIS FOR CHANGE: Per meeting with EG&G, it is the NRC's position that these valves be tested on a cold shutdown frequency.

ITEM 31: CHANGE: Delete valve KA-HV-0030 from the test program. Add note 3 to NOTES column for this valve.

BASIS FOR CHANGE: It has been determined that this valve is passive, and therefore, need not be tested.

.ATTACEMENT 1 PAGE 6 cf 8

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ITEM 32: CHANGE: Add lubrication verification column to the test parameters division of the pump testing matrix.

. BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests the addition of pump lubrication level observation to the test program.

ITEM 33: CHANGE: Add flowrate measurement to pump test matrix for Emergency Fuel Oil Transfer pu:nps PJE01A & B. Add note 3 stating _" Pump flow measurements will be made when design change to install flow indicators is implemented". Add note 3 to Notes column of pump test matrix for pumps-PJE01A & B. Revise relief request P02.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC holds the position that PJE01A & B pump flowrate measurement should commence upon installation of system flow indicators.

ITEM 34: ' CHANGE: Delete vibration testing of Emergency Fuel Oil Transfer pumps PJE01A & B from test program. Revise relief request P02.

BASIS FOR CHANGE: These pumps are submerged, making direct vibration testing infeasible. It has been determined by the NRC that indirect vibration testing on system piping is unacceptable, per meeting with EG&G.

ITEM 35: CHANGE: Add further basis for relief to relief request P03. _

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests a more de-tailed technical justification for not measuring Centrifugal Charging Pump flowrates during testing.

ITEM 36: CHANGE: Add further basis for relief to relief request PO4.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests a more de-tailed justification for relief from measuring bearing temperatures on test program pump tests.

ITEM 37: CHANGE: Add valve disassembly and inspection testing to relief request EN-2 for valves EN-V-0003, 0004, 0009, and 0010.

BASIS FOR CHANGE: Per meeting with EG&G, it is the NRC's position that valves that cannot be full stroke tested with flow, shall be tested by disassembly.

ATTACHMENT:1

.- *PAGE.7 cf 8 ITEM 38: CHANGE: 'Ad'd relief request FC-1 (cold shutdown justification). This adds partial stroke testing open during normal power operations and full stroke testing in the open and closed direction on a cold shutdown frequency to valves FC-V-0001, 0002, 0024, and

' 0025.

BASIS FOR CHANGE: Per meeting with EG&G, the NRC requests that these valve tests be included in the test program.

ITEM 39: CHANGE: Add full stroke testing to KJ-PV-0001A & B and KJ-PV-0101A & B on a normal power operations frequency. Add position indication testing for KJ-PV-0001A & B and KJ-PV-0101A & B on a refuel frequency. Add relief request KJ-2 and full stroke test for KJ-V-0711A 6'B and KJ-V-0712A & B on a cold shutdown frequency.

Add relief valve setpoint check to valves KJ-V-0716A & B and.

KJ-V-0717A & B on a refueling frequency.

BASIS FOR CHANGE: Per meeting with EG&G, it is the NRC's position that the emergency diesel generator air start system performs a safety-related function and these valves should be included in the test program.

ITEM 40: CHANGE: Revise the alternate testing of relief requests AL-2, EN-1, EN-2, and EN-3 to clarify testing to be performed.

BASIS FOR CHANGE: Per meeting with EG&G, the-following alternate testing method is acceptable: "A different valve of each group must be disassembled, inspected, and manually full stroked at each refueling until the entire group has been tested".

ITEM 41: CHANGE: Revise alternate testing for AB-2 and AE-4. Reword frequency from "at least once per 92 days" to " quarterly".

BASIS FOR CHANGE: Standard testing frequency is stated as quarterly and not as "at least once per 92 days".

ITEM 42: CHANGE: Revise relief request P07 and P08 to delete applicability of pumps PJE01A & B.

BASIS FOR CHANGE: Vibration testing on the Emergency Fuel Oil Transfer Pumps is not required since they are inaccessible.

ITEM 43: CHANGE: Add relief request P09 to seek relief from measuring flowrates on the Boric Acid Transfer Pumps PBG02A & B.

BASIS FOR CHANGE: See relief request P09.

<- v, ATTACIDENT 1

.- PAGE 8 cf 8 ITEM 44: CHANGE: Add M-22AP01 revision 1, M-22KJ02 revision 0, and M-22KJ05 revision 0 to Piping and Instrumentation drawing list.

BASIS FOR CHANGE: Selected valves being added to the test program are shown on these drawings.

ITEM 45: CHANGE: Add further basis for relief to relief request P02.

BASIS FOR CHANGE: Pump lubrication levels require verification but these pumps are lubricated by the liquid they are submerged in. Lubrication levels, therefore, need not be verified.

ITEM 46: CHANGE: Remove revision bars, reformat pump test matrix, and add Rev. 7 to all pages of test program.

BASIS FOR CHANGE: N/A i ITEM 47: CHANGE: Add stroke test in closed direction and position indication test for. valves AL-HV-0005, AL-HV-0006, AL-HV-0007, AL-HV-0008, AL-HV-0009, AL-HV-0010, AL-HV-0011, and AL-HV-0012.

BASIS FOR CHANGE: These valves are needed for the analysis for Steam Generator Tube Rupture.

ITEM 48: CHANGE: Ravise maximum allowable stroke time for EF-HV-0052 from 60-to 66 seconds.

BASIS FOR CHANGE: Change of design requirement, t

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ML20207Q154

Text

Dear Mr. Denton:

References:

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