ML20209G727
| ML20209G727 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/04/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20209G725 | List: |
| References | |
| NUDOCS 8509190671 | |
| Download: ML20209G727 (182) | |
Text
_,
ORIGINAL UNITED STATES OF AMERICA
("' -
NUCLEAR REGULATORY COMMISSION In the matter of:
]'
Meeting on TMI 1 In-Service Testing - Pumps and Valves Review of Second 10-Year Program Docket No.
(
0 l
Location: Bethesda, !!aryland y
Wednesday, September 4, 1985 Pages:
1 - 180 Date:
ANN RILEY & ASSOCIATES Court Reporters g
8509190671 050916 1625 I St.,
N.W.
PDR ADOCK 0D000 9
Suite 921 T
nashington, D.C.
20006 (202) 293-3950 i
a 1
1 UNITED STATES OF AME3ICA 2
NUCLEAR REGULATORY COMMISSION
(.~
3 i
4
-x 5
Meeting on TMI 1 In-Service Pumps and Valves 6
Testing
'9 7
e 8
Review of Second 10-Year 9
Program 10
-x 11 12 Room P-110 13 Phillips Building
(
14 7920 Norfolk Avenue 15 Bethesda, Maryland 16 Wednesday, September 4,
1985 17 18 The TMI-1 In-Service Testing Group convened at 7:45 19 a.m.,
pursuant to notice, Owen Thompson presiding.
o 20 ATTENDEES:
o 21 Owen Thompson 22 Richard Conte 23 Bob Knight 24 Joe Colits 25 J.
R.
Bashista
,y.
.~
lA 1
Julien Abramovici i
//
2 Mark Sanford i~
3 Henry Shipman i
4 Richard Earley I
5 Rick McGoey 6
Clair Ransom
,9 l
4 7
Herb Rockhold e
8 Joel Page 9
Courtney Smyth l
10 Frank Cherny 11 12 i
13
(?
14
}
l 15 l
f, 16 17 r
i 18 19 20 e
21 l
22 i
23 i
24 i
25 4
~,,,
2 1
PROCEED I NG S 2
MR. THOMPSON:
My name is Owen Thompson.
I am the 3
Project Manager for TMI-1 on the in-service testing of pumps 4
and valves.
5 Our meeting here today is to discuss the second 6
ten-year program of in-service testing of pumps and valves for 5
(
7 TMI-1.
The first ten-year program was basically approved in e
8 Amendment 71, August 3,
1981, and associated with that were 9
some relief requests that were subsequently granted or denied 10 by a letter of October 23, 1984.
11 So that completed the first ten-year program, which 12 terminated in September of 1984.
Now we are into the second 13 ten-year program, and we received a revised IST Program dated i
14 July 10, 1984, and in a letter dated December 11, 1984, we 15 addressed some of the denials that had been addressed in the 16 first ten-year program and essentially redenied some of those 17 relief requests.
18 On March 19, 1985, you sent us a letter appealing 19 some of the denials and rerequesting some of the relief 20 requests, and by letter dated August 16, 1985, we informed you 21 that we did not find most of the issues that you addressed to 22 be backfits under the new or proposed backfit rule.
23 There was one or maybe two items where we identified 24 that you could appeal on technical grounds, and we also took
'j 25 out what we will call pres $sure isolation valves because they
3 l
1 are currently under consideration by the Staff in a generio 2
sense.
Just prior to that, we sent out on July 15, 1985 a 3
list of questions and requests for additional information 4
associated with the second ten-year program.
5 These requests were developed by our contractor, 6
EGSG Idaho, and we have representatives from EG40 here today 4
4' 7
to discuss those questions, and we got responses from you 8
dated August 22, 1985.
9 Now, I think our discussion today should focus on 10 the RAIs or the questions of July 15th and your responses of 11 Augur.t 22nd.
We would propose just going through the 12 questions and responses in the order in which they were 13 provided in the correspondence.
14 We will essentially skip over those items where your 15 responses satisfy the Staff, where we have no further 16 questions, and try to focus on the areas where we do have 17 questions or concerns.
18 Our goal today would be to try to cover everything, 19 and it's a pretty big program, but try to cover everything 20 today, and by the end of the day get down to, let's say, the 21 hard spots, the areas where we have differences. That will 22 leave us for tomorrow to try to resolve those ourselves in 23 this working group and, if necessary, bring in management to 24 help us come to some deoision.
25 With that, I think I will turn it over to Jnel, but
4 1
is there anybody who has got any comments or questions or 2
discussion?
3 MR. MC GOEY:
The only comment is on the initial 4
ten-year period with the four items, I guess, left for some 5
discussion.
We are interested in talking about those first 6
thing tomorrow morning.
We are going to have an individual o
7 from upper management.
Mr. Wilson will be here.
So we are 8
interested in talking about those items first thing tomorrow 9
morning.
10 MR. THOMPSON:
He will be here at 8:30, is that 11 right?
12 MR. MC GOEY:
Right.
13 MR. PAGE:
With respect to your comment, do you have 14 those listed, exactly which four items you wculd like to 15 discuss tomorrow morning?
16 MR. MC GOEY:
Just the August 16th letter from you.
17 We have Attachment 1,
which listed four items.
So just from a 18 scheduling point of view, we would like to put it on the i
~
19 agenda for first thing tomorrow morning, those four items.
20 MR. KNIGHT:
Those would be 1-1, Q-3, M-1 and DD-1 i
21 and DD-2.
DD-1.
22 MR. PAGE:
My name is Joel Page.
I represent the i
l 23 Mechanical Engineering Branch of HRC.
My responsibility is 24 for IST reviews.
(,/
25 MR. ROCXHOLD:
I am Herb Rockhold, EG&G Idaho. We l
l
5 I
1 have a contract.
We are doing the detailed review of the pump 2
and valve service testing program, 14-1-1 Clair and I were 3
the reviewers for the program.
4 MR. RAMSOM:
I'm Clair Ransom, EG&O Idaho reviewer.
5 MR. MC GOEY:
I'm Rick McGoey, OPU Licensing.
6 MR. BARLEY:
I'm Rick Barley.
I'm with Plant 7
Engineering at the site.
8 MR. SHIPMAN:
Henry Shipman, TMI-1 Operations 9
Engineer.
10 MR. SANFORD:
Mark Sanford, Tech Functions, GPU 11 Mechanical Systems.
12 MR. ABRAMOV!CI:
Julien Abramoviol, Tech Functions, 13 Mechanical Components.
14 WR. BASHISTA:
Joe Bashista.
I'm Plant Engineering.
15 MR. COLITZ:
Joe Colits, Plant Engineering.
16 MR. KNIGHT:
Bob Knight, Site Licensing.
17 MR. CONTE:
Rich Conte, Senior Resident, TMI-1. NRC.
18 MR. PAGE:
With the completion of those 19 introductions, I guess we ought to start down the list, 20 starting with Question A-1 would be my preference, and just go 21 right straight through them.
22 With that, I will turn it over to Herb and we wit!
23 see how far we can get.
24 MR. ROCKHOLD:
This is Herb Rookhold.
25 I will give you a brief introduction on what we are
=
6 1
trying to accomplish here at this meeting.
What we would like
- U) 2 to do is go through each question and individually discuss the
%.. J 3
items, and Clair will make a set of notes, which is basically I
4 a summation of your responses, and write them down.
5 Frequently we will refer back to your written response and 6
say, well, the written response is okay, we will just 7
reference this rather than write the same thing down again.
8 But on a few of them I'm sure we are going to have a few 9
discussions where either your written response is not to sufficient or is not in enough detail or something to that 11 effect, and we will have some more written verbiage.
12 At the end of the meeting what we would like to do 13 is get some copies of our notes and give them to everyone here
- b.,-)
14 so we can go over them together, read them.
If we have 15 written down any words that you don't like or if we 16 misinterpreted what you have said, we would like it brought to 17 our attention and make changes, if necessary.
18 We will also identify any open items and who was 19 responsible for those open items, who has the ball, and 20 whether you are going to be providing more information for us 21 or whether it is the NRC's ball where we have to provide or 22 make a decision back to you.
But we will clearly identify any 23 open items and who is responsible for those open items.
24 Also I would like to comment that, as far as we are
't 5;)
25 concerned, anyway, this is a two-way meeting.
If you have any J
7 1
questions about the Code, any parts that are not clear to you
~
2 or you have heard different interpretations of the Code, 3
please bring up your questions, we will discuss them and try 4
to get them straightened out so at least we will each know how 5
the other person stands.
6 I guess at this point we will continue with
=
7 individual questions we have identified and your responses.
8 On the questions where your written response is I
9 satisfactory for our needs, we will just make a comment that 10 the written comment is all right and go on to the next 11 question just to conserve time.
I am sure there will be a few 12 of them we will discuss at great length.
13 The first item was to provide the limiting value of 14 full-stroke time for each power operated valve in the IST 15 program.
16 Your written responses did provide a table of about 17 160 valves, and the stroke times that were identified for 18 those valves all appear to be satisfactory to us, with a 19 couple of exceptions There seems to be a minor inconsistency 20 en what we call rapid-acting valves.
I'm not sure whether you 21 use fast-acting or rapid-acting or whatever.
22 We have nottood on valves in the table, item 3 and those are valves
! guess that's the only three 23 4,
95 24 that are identified with stroke times of less than 2 seconds
,i 25 and 1.7 seconds that are not identified in the program or your i
I i
8 1
relief request as rapid-acting valves.
I'm just wondering if 2
you want to add those to the table or why those are different 3
than the other " rapid-acting" valves.
4 MR. COLITZ:
The ones for AHV-1 are less than 2 1
5 seconds.
Do we have a 30 degree closure on those valves?
6 They are 2 seconds.
Is that established?
We have always had 7
2 seconds.
Did we just change them?
r 8
MR. BASHISTA:
That is 30 degrees also.
9 MR. COLITZ:
When did we change them?
10 MR. BASHISTA:
These valves are a special 11 ostegory. These four valves are, when the reactor is critical, 12 held to 30 degrees open, and the times less than 1 second j
13 and less than 2 seconds are related to tech specs for these i
14 valves.
I 15 MR. FAGE:
Expanding on what you just said, are all 16 these valves assigned tech spoo times for limiting values 17 rather than times based on the actual stroke time?
18 MR. BASHISTA:
The actual stroke time is less than 19 what is on Appendix A.
It's a little bit less.
20 MR. FAGE:
I guess what I'm saying is for some of 21 these valves you will indicate 144 seconds, 120 seconds.
Does 22 that relate in some way to the actual stroke time or is that l
23 something out of the tech spoo that is system related?
i 24 MR. BARLEY:
In almost all cases, those values in i
25 Appendix A relate to the actual stroke times, first measured l
i i
9 1
on the valves.
2 MR. PAGE:
They are component oriented?
3 MR. BARLEY:
Yes, sir.
In a few instances, such as 4
the purge valves, HV-1 valves, and the main steam isolation 5
valves, the MSV-1 valves, there are some tech spoo 6
requirements in tech specs for valve position.
Purge valves 7
are 90 degree butterfly valves that are limited by tech spoos 8
to a 30 degree opening, 9
MR. PAGE:
The AMV-1s are'30 degree valves, and you 10 stroke those at 30 degrees, I suppose.
11 MR. BARLEY:
Yes.
12 MR. BASHISTA:
Right.
13 MR. ROCKHOLD:
The reason we brought these items up 14 is you have a list of valves in Relief Request No. 9 that 15 appear to be what we call rapid-acting valves, valves that 18 operate fast enough where trending the stroke time and 17 measuring a variance on that stroke time is somewhat i
18 impractical with stopwatch timing.
19 You have provided a pretty good relief request.
20 Like I was saying, it appears that these three valves that !
21 have just identified to you also fall into this category, and 22 we are wondering if there was a particular reason why they 23 were not included in this relief request.
If you have a good 24 reason, I'm sure that we could probably get along with it 25 pretty easily, but it just appeared that you are doing more
10 1
than is necessary on these three particular valves.
2 MR. BARLEY:
I think the answer to your question is 3
no, there is no good reason why they should not be included in 4
that relief request for the other valves that stroke in less 5
than 2 seconds. They probably should b e '.
1 6
MR. BASHISTA:
The purge valves, AHV-1 A through D,
?
7 are ir Relief Request 9,
however, valve 51 is not.
8 MR. ROCKHOLD:
We interpreted the table in Relief C
9 Request 9,
AHV-1 A/D, as A and D because they are listed
)
10 somewhere else.
We found them listed as A/D and then A/C, so
)
11 we interpreted them as not being in the program.
12 MR. BARLEY:
I think that was an omission on our 13 part.
The B and C valves used to have a stroke time of less 14 than 5 seconds before they were restricted and traveled the 30 15 degrees, and we didn't pick up that.
We used to stroke them 16 at 90 degrees.
We didn't pick up the change in stroking 30 17 degrees. It should be added to Relief Request 9.
j 18 MR. ROCKHOLD:
We would have no problem if you 19 added those to Relief Request 9.
One of the things that we 20 look for during our review is consistency.
If we find any 21 apparent omissions or even a typographical error, which is one 22 of the items I was going to point out to you also item 151 23 in that Appendix A valve table. That should be n.WDO rather I
24 than a WDL.
25 MR. BARLEY:
That is correct.
l
11 1
MR. ROCKHOLD:
All right.
/
2 Then you said the make-up valve, V-51, should also 3
be included in that Relief Request 97 4
MR. BASHISTA:
Yes, it should.
5 MR. ROCKHOLD:
Are we ready to move on to Question 6
A-2?
7 During the course of the meeting here, we will have 8
to pause occasionally to allow Clair to catch up a little bit 9
on his notes.
Neither of us are real good at speed writing, 4
10 especially if we expect anyone to read it afterwards.
So 11 occasionally I might pause to allow the note taker to catch 12 up.
13 Item 2.
Basically we asked if all valves that are 14 Appendix J, Type C leak tested included in the IST program and i
15 categorised A or A/C. That is just a cross-check on one of the 16 items that we looked at during the review.
17 Your response is yes.
18 MR. PAGE:
I would like to expand a little on 19 that. There is such a thing as a modified Type C.
Do you do 20 any modified Type C testing?
It's not an exact Type C test.
21 It's termed, I believe, by Containment Systems as modified 22 Type C for water-filled systems. Is this also part of your
(*
23 answer?
I was not sure.
Or are you familiar with the term 24
" modified Type C"?
25 MR. BAALEY:
Can you clarify what is modified Type C
12 1
testing?
2 MR. PAGE:
You are not familiar with it at all.
Who 3
does that testing here?
There is someone.
4 MR. BARLEY:
The fellow most familiar with that 5
testing is not here today.
6 MR. FAGE:
So the person that generated the answer 7
is not here?
8 MR. BARLEY:
We generated the answer from reviewing 9
the tech speos.
We did not answer the question as to whether 10 they were Type C test or modified Type C test.
I wasn't aware 11 that was the question.
12 MR. PAGE:
Okay.
I will follow that up myself, 13 then.
14 MR. BARLEY:
If you clarify the question, we can get 15 you that answer.
16 MR. PAGE:
I will check with Containment Systems on 17 that.
18 MR. ROCKHOLD:
Ready for Question A.3.
All Catgory 19 A and B active valves must be stroke timed during quarterly 20 testing unless specific relief is requested from the stroke 21 timing ' equi rement s of Section XI.
22 Your written response was satisfactory for our 23 needs.
24 Core flood system, Question B.1 In reference to
,i 25 Valves CF-V4A and B, the NRC position is that sample
13 1
disassembly program of inspection is an acceptable means of
~
2 full stroke exercising check valves and should be performed at 3
each refueling outage.
4 We found your written response was not in accordance 5
with the current NRC position, or at least with Mechanical 6
Engineering Branch's position for most other plants, and we 7
are going to need to discuss this one in a little more detail.
8 Are the 4s the valves directly off the oore flood 9
tanks or the combined 10 MR. BASHISTA:
Directly off.
11 MR. PAGE:
I think you added some words to what was 12 in the SER.
The last sentence.
Could you clarify what that 13 means exactly, the partial test of the CF-V4A/B each cold 2
14 shutdown adequately demonstrates system performance?
The core 15 flood valve?
I guess I didn't see the need for that 16 statement.
I didn't know why it was thrown in there.
i 17 MR. BARLEY:
The purpose for including that 18 statement was to point out again there are certain tech spec 19 requirements that are done on some of these components as part t,
20 of system tests that involve major system lineups in O
21 restricted plant conditions.
The surveillance testing 22 frequency has been defined in tech specs, margins of safety 23 defined on the basis of toch specs.
I point out that those i
24 frequencies have been accepted for years as a measure of 25 system performance.
I l
14 1
MR. PAGE:
As a system test of some verification of 2
system operability, but not, obviously, full verification 4
3 because we are not going to do a blowdown to show that.
This 4
is just a further enhancement of some component reliability, I 5
guess.
I assume you will be moving on to the others?
They 6
already have one of the four done satisfactorily.
They agreed 7
that if they ran into problems, that the others would be 8
disassembled, yes.
9 MR. ROCKHOLD:
Okay.
10 MR. COLITZ:
One thing. The frequence of the valve 1
11 disassembly comes up quite a bit throughout this.
The last 12 time we were down here, based on discussions we had with the 13 NRC on frequency, we put together a pretty detailed 14 disassembly inspection report, what we have done over the 15 years with with some of these valves, to try and justify our 16 position on that.
17 I don't know if you people saw the disassembly 18 report we put together.
19 MR. PAGE:
No, they did not.
This was generated 20 right here in NEB based on your report. That is why, if they 21 seem a little questioning on what was here, they really didn't 22 play a role in this particular SSER here.
23 MR. ROCKHOLD:
So our response to Question B.2, or 24 our understanding of your response is that your written
.,/
25 response is acceptable to Mechanical Engineering Branch as
15 1
written.
B.1.
.~,,
2 Okay, Item B.2.
How are valves CF-V5A and B fu 1 3
stroke exercised during cold shutdown?
4 Your response indicated that during cold shutdowns, 5
you are going to stroke either SA or B,
which is a change from 6
previous programs we looked at, and I am wondering why you 7
made this particular change and whether the stroke that you 8
do, in fact, perform on these valves during cold shutdowns is 9
a full stroke or not.
10 MR. COLITZ:
I think the main reason for doing one 11 or the other' on cold shutdown frequency is normally we only 12 run one string of decay heat.
We wanted to get out of the 13 additional burden of just swapping loops from an operational g~,
( '-
14 standpoint.
15 MR. ROCKHOLD:
In the past, the NRC's position on 16 valve testing is that inconvenience is not a suitable 17 justification, and we found no real technical reason why both 18 valves could not be exercised during cold shutdowns.
How much 19 of an additional burden is it?
20 MR. SHIPMAN:
I would say the additional burden of 21 swapping loops is not really that significant.
We probably 22 could do it.
It does take several hours to perform if there 23 are any time constraints.
I 24 MR. ROCKHOLD:
We found this response occur about 25 four times in the program where you have requested a change be I
\\
=
16 1
made, assuming it would be the injection check valves, pumps,
.N 2
suction and/or discharge check valves, and maybe another valve 3
or two.
4 MR. SHIPMAN:
The actual operation of swapping loops 5
is not a significant burden to an operator.
However, from my 6
perspective it seems a lot of system operations to check one 7
particular check valve that is tested, has been tested in the 8
past and would demonstrate that there is no need to increase 9
the frequency of it.
We have not seen problems with these 10 check valves in the past. Starting and stopping a large system 11 like that just to perform a stroke test in a check valve that 12 has not demonstrated a problem does not seem to make the value 13 of that test worth the additional operation of the system.
s
(
14 MR. PAGE:
The reason I think Herb was questioning 15 that is that the whole key to the Code t,here is not just 16 testing the valve to see what it will do; it is also 17 exercising the valve, which is in addition to performing the 18 test, to see that it will do whatever it is supposed to do.
19 The other key word was " impracticality," and I guess 20 we really haven't heard anything that comes to impracticality 21 on this particular situation.
I believe Herb indicated there 22 are three more that are very similar.
23 I believe our viewpoint there would be that you 24 should do them unless there is indeed an impractical reason to 25 make that swap.
17 1
Are they all involved with making the swap from one 2
loop to the other?
3 MR. ROCKHOLD:
I believe so.
4 MR. SHIPMAN:
We have the ability to exercise that 5
valve without swapping loops.
My concern is you start and 6
stop the pumps just to check the swing valve, and that is wear 7
and tear on the motor for exercising the check valve when !
8 can exercise the check valve without starting and stopping the 9
pump.
10 MR. ROCKHOLD:
The reason behind this is, at least 11 from the reviewer's side of the table, the Code is written to 12 ensure that you demonstrate the operability of safety-related 13 equipment, and the people that develop the Code have 14 determined that quarterly is the optimum frequency for 15 demonstrating operability.
16 The NRC has accepted the Code with the same 17 understanding, and the way that we view it is that the valves 18 should be exercised quarterly in all cases unless there is 19 some real impracticality involved.
So I guess the way we have 20 to look at it is if you cannot demonstrate real 21 impracticality, then you must live with the requirements of 22 the code.
23 MR. SHIPMAN:
We cannot stroke those valves i
24 quarterly.
That is truly impractical with the system at 25 present.
18 1
MR. ROCKHOLD:
We understand that. The next idea is 1
(
2 frequency during cold shutdowns, and we do not see any real 3
impracticality with stroking all of these valves during cold 4
shutdown for these particular valves.
5 Also I would like to comment about the flow rate 6
that you are demonstrating through the valves and whether that l
7 really is a full stroke or not.
You state that you get 8
approximately 3000 gpm through the valves during the cold 9
shutdown stroking, and the 5A and B are the combined core 10 flood tank outlet checks and the low injection /RHR decay heat 11 valves.
Okay?
12 It is our understanding that during the postulated 13 LOCA, that there would be significantly more than 3000 gallons 14 a minute going through that valve for it to perform its safety 15 function.
Have you done anything to see if the stroke that 16 you do during cold shutdown does, in fact, open the valve 17 fully:
1.e.,
put the valve against its backstop, or 18 demonstrate that the valve is physically full open?
19 MR. COLITZ:
We know we get 3000 gallons per 20 minute.
Julien, have we looked at whether that is full 21 stroke?
How far open that is calculational-wise?
22 MR. ABROMOVICI:
No, I don't think we looked at 23 that.
24 MR. COLITZ:
That is why we put in there, 25 demonstrates full LPI flow stroke on each shutdown test.
19 i
MR. ROCKHOLD:
Is the 3000 gallon per minute the 2
flow rate that you take credit for in your safety analysis for 3
LPI flow?
4 MR. COLITZ:
Yes, it is.
5 MR. BARLEY:
It is in excess of what we take credit 6
for.
7 MR. PAGE:
You take credit for 3000 gym in the 8
FSAR?
9 MR. ROCKHOLD:
For LPI.
10 MR. BARLEY:
I think the actual number for LPI flow 11 is somewhere on the order of 2734 gallons a minute or 2750, 12 something like that.
13 MR. PAGE:
This is including the accumulators?
14 MR. BARLEY:
That is the LPI.
15 MR. ROCKHOLD:
Check valves that we are talking 16 about are the combined check valves.
However, the flow they 17 are demonstrating is only the LPI flow.
18 MR. PAGE:
They are not demonstrating the 19 accumulator?
20 MR. ROCKHOLD:
Right.
21 MR. PAGE:
How can you say it's a full stroke?
22 MR. COLITZ:
We specifically stated that it 23 demonstrates full LPI flow stroke since that is all we have 24 running at the time.
It's not for the refueling outage when l
25 we actually flow in from the core flood tanks.
20 1
MR. PAGE:
You don't full stroke there either,
~~
2 do you?
3 MR. BASHISTA:
Refueling for the cold shutdown test 4
would be CFV-5, is probably not a full stroke test from the 5
6 MR. PAGE:
Can you explain what the test is?
7 MR. BASHISTA:
Briefly, we look for several inch 8
increase in the pressuriser.
9 MR. PAGE:
That's it?
10 MR. BARLEY:
With the core flood system valves open 11 to actuate the core flood system.
12 MR. BASHISTA:
We watch for a drop in core flood 13 tank level and an increase in the pressurizer level.
14 MR. PAGE:
,I think I remember the discussion in 15 great detail we had before on the subject.
16 Okay, I think we better move on.
We' will probably 17 have to come back to this one later.
I believe it also keys 18 to one we have already covered.
19 MR. SHIPMAN:
Can we talk about the practicality of 20 a full stroke, just to get that understanding out?
To 21 actually full stroke the valve at the LOCA that I presume you how 22 are assuming, I'm not sure how we would do that without 23 we would do that safely.
l 24 MR. PAGE:
Okay.
But I believe Herb also indicated 25 that a disassembly inspection program involving a manual full
21 1
stroke is an acceptable method if you don't want to do it by 2
flow.
So it sounds to me like we are getting a very small i
3 part stroke, yet you are calling it a full stroke and you are 4
using it as a partial basis also in a previous discussion here 5
that you are full stroking the valve, and that is not full 6
stroking in any sense of the word.
7 MR. SHIPMAN:
I think we clarified it by saying LPI 8
full stroking.
LPI flow stroke.
9 MR. PAGE:
I think the Code says full stroke the 10 valve.
The NRC has adopted a fallback position sometime back 11 that if you can demonstrate the maximum flow rate that you and I don't think LPI 12 take credit for through the valves then we will accept that.
In other 13 flow is that flow rate
(
14 words, it is a part stroke but it is demonstrating the 15 accident requirement.
So I believe that we probably will have 16 more disoussions on this.
This will probably be one of the 17 items towards the end of the meeting that I would imagine wo 18 should discuss.
They key is right here, too.
They are tied 19 together.
O 20 MR. ROCKHOLD:
So this remains an open i
=
21 item. However, is it just open for further discussions, or is I
22 the NRC expecting some more feedback from the utility?
23 MR. PAGE:
At this point I would not expect anything 24 from TMI'.
I would wait until the whole meeting is over.
We 25 will iron out which way to run with this.
22 1
MR. RANSOM:
Does this remain open on both issues 2
MR. PAGE:
I would just say it also relates to the
~ '
3 previous item.
Just say that it does relate to it.
4 MR. BARLEY:
The item here, just to be clear, is 5
that the test of those valves on cold shutdown demonstrates 6
the full stroking for the LPI system function of the valve.
7 The valve also serves a second function during large break 8
LOCAs to provide core flood flow through it.
For that point, 9
demonstration of full flow is, in our view, impractical from a 10 system flowing standpoint and relates to Question B.1, the adequacy of the disassembly inspection 1
11 disassemblies 12 and frequency.
13 MR. SANFORD:
I think it's important to keep in mind 14 that disassembly of CF-V5 renders one of the two decay heat 15 trains inoperable. We are verging on a tech spec changes in 16 that area at this time as well.
That's an important issue 17 that we address here as we get into this discussion on l
18 disassembly.
19 MR. PAGE:
I thik we will have a discussion of this 20 item at the very end of the meeting, which I believe George 21 Lear will be attending, and maybe at that point you can 22 enhance what you just said about your tech specs.
If we do 23 run into a problem there, it would be important to pull out 24 all the impracticalities, including those associated with 1
- _[/
25 disassembly.
1
23 1
I believe we have a new member of the meeting here.
~
2 MR. THOMPSON:
Two new members.
Frank Cherny is the 3
Acting Branch Chief, Mechanical Engineering Branch, and 4
Courtney Smyth on the other side of the room is TMI Licensing I
5 at the site.
Your exact title there, Courtney?
6 MR. SMYTH:
Licensing. TMI Licensing Manager.
7 MR. CHERNY:
I'm going to have to shuttle back and 8
forth on this meeting and Davis Besse, which I just found out 9
about last night, so we will see how it goes.
10 MR. ROCKHOLD:
Okay, are we ready to get going again 11 on Item C.1?
What is the purpose of CA-V29 located in the 12 lower left-hand corner of Drawing FD-0207 13 The written response is satisfactory for our needs.
14 The new P& ids that we got showed us a lot more about what the 15 valve did.
The drawings that we had showed a lot of valves 16 that had no bites connected to them, didn't give us a whole 17 lot of information on what quite a few of the valves did, so 18 we were confused about that.
19 Item D.1, Chemical Addition and Waste Disposal 20 System. What is the purpose of the chemical addition 21 penetration 307?
Why is valve 192 identified as passive while 22 valve 189 is not?
23 Your written response appears to be satisfactory.
24 However, it appears that a relief request is going to be 25 required to verify valve closure during refueling outages.
l qj l
1
24 1
What appears to us as valve 192 is a normally open valve whose 2
safety function is to provide containment isolation or to 3
close, so it is an actLve valve that is not currently being 4
stroked closed and positively verified to be stroked closed to 5
the Code requirements verifying that it does close during leak 6
tests and refueling outages.
7 So relief requests will be required for this 8
deviation from Code requirements.
9 MR. BARLEY:
We don't disagree with your analysis.
10 MR. ROCKHOLD:
So an additional relief request will 11 be provided in the program for this particular valve.
12 MR. BASHISTA:
You won't have any trouble with that 13 relief request. Straightforward; right?
14 MR. ROCKHOLD:
Yes.
The only way to verify valve 15 closure is by leak testing, and a leak test is performed 16 during refueling outages.
17 MR. PAGE:
Briefly, to go back to C.1.
I don't 18 understand what you mean by the loss of the makeup tank 19 pressure is acceptable following an accident.
What exactly 20 does it mean that it is acceptable?
You take not credit 21 whatsoever for that as a first source?
22 MR. SANFORD:
An ES signal in the plant will switch 23 the suction source from the makeup pumps to the BWST 24 automatically.
25 MR. PAGE:
Automatically.
I wish that had been i
25 1
included here.
)
2 MR. THOMPSONi So the response to C.1 was acceptable J#
3 as explained by the discussion.
And D.1, did we complete
)
4 that?
5 MR. ROCKHOLD:
Item D.1.
It is my understanding the 6
utility will provide an additional relief request in the IST 7
program for verifying valve closure of CAV-192 during 8
refueling outages by leak testing the valve.
9 MR. THOMPSON:
Which we will find acceptable.
I 10 MR. ROCKHOLD:
Yes.
11 Item D.2.
Does Valve CA-V134 perform any function 12 important to safety?
13 The response provided is acceptable 14 MR. PAGE:
This is Joel Page.
15 You are indicating that valves used for system 16 control are exempted from testing for the code.
We have put 17 an inquiry into ASME on that subject, the word "only" should 18 have appeared in that sentence, just like it did in the other 19 exemptions.
In other words, only for system controls.
We 20 mean that there is no safety function.
21 MR. ROCKHOLD:
This is relative to Question E.1.
Do 22 you understand what Joel is saying here?
23 MR. BARLEY:
Yes, I think we understand the point l
24 that Mr. Page is making.
I don't think it changes the
(.,/
25 instrument provided in this valve.
I l
26 1
MR. ROCKHOLD:
Let me ask an additional clarifying 2
question, then.
Do any of the temperature control valves 3
shown on Drawing FD-011 hava a required fail-safe position?
4 The word " required" is emphasized here. If the valves should 5
fail in what we will call the non-conservative position, is it 6
going to defeat the function of that safety system?
7 MR. BASHISTA:
I can tell you the fail positions for 8
the various valves.
9 MR. ROCKHOLD:
Okay.
I guess my question is: If you 10 identify a particular valve to fail full flow through the 11 cooler, for example, if it did not fail full flow through the 12 cooler, would it cause a loss of system function that you take 13 credit for?
The actual fail position. I guess, during this 14 discussion does not mean a whole lot to us, Our concern is 15 that if a temperature control valve or a control valve has a 16 required fail position, then you must demonstrate that it 17 does, in fact, fail to that required position.
18 MR. BASHISTA:
On the fail positions of the valve 19 for AH-V11A and B, they fail such that the cooler is i
20 bypassed.
The AH-V3 and AH-V16, they fail such that the valve 21 is open and cooling water goes through the cooler.
t 22 MR. ROCKHOLD:
Can you periodically demonstrate the 23 failure position of these valves?
Or let me back up.
24 MR. BASHISTA:
In most cases these valves are 1
25 controlled by a thermostat.
The thermostat has automatic
27 1
control of the valve.
I don't think there is a way to very 2
easily bleed off the air to the valve operator.
We would have J
3 to look at it.
4 MR. PAGE:
This is Joel Page.
5 Further enhancing what Herb just said, when valves 4
and we realize almost 6
have a required fail-safe position 7
all control valves by nature haww a fail position because they.
8 are air operated, usually spring to return, but we are 9
concerned only if there is a safety function associated with 10 that.
However, for the ones that are, and we believe there is 11 a handful that fall into that category, they by nature become 12 active safety-related valves.
So not only do they require 13 fail safe testing, they require full stroke testing if it's e..
a, 14 possible to do it.
So that is what we are trying to get at.
15 I feel you guys probably need to look at that a 16 little closer and want to come Lack after you have had a 17 chance to maybe look at that drawing.
Is that the way you 18 wanted to leave that one for now?
19 MR. BARLEY:
One clarifying question.
If the 20 control valve has a failure position to open, is it understood 21 that the requirement is to demonstrate that that valve fails 22 open or could not fail closed?
23 MR. PAGE:
You would have to assume the worst case, 24 that it had to make a full travel.
The direction of concern
,)
25 would be whatever it was to close or to open.
That would be i
i
28 1
the direction you would be verifying.
But it becomes active 2
because you don't know where it is at the point that an 3
aooident occurs.
4 MR. SANFORD:
Clarification.
You are then saying we fully 5
have to drive the valve to its non-failure position 6
to its non-failure position before testing!
That's the 7
position the NRC is taking?
8 MR. PAGE:
I am assuming that it can be done unless 9
there i.,s some impractical reason.
In other words, first of 10 all, I am saying by the description we gave, it becomes an 11 active valve.
From there, then we start discussing in terms 12 of stroking, timing, and fail safe testing.
First it comes 13 into the arena.
Then we discuss what can be done.
14 MR. ROCKHOLD:
Item E.1, then, is remaining an open 15 item for the utility to: one, determin,e if the valves are 16 safety related, and if they are, what testing can be performed 17 at what frequency on the valves to as closely as practical 18 meet the Code requirements.
19 Does everybody agree?
20 Item F.1, emergency feedwater and feedwater 21 systems.
The question was to provide a more detailed 22 technical justification for not full-stroke exercising valves 23 CO-V16A and B during each cold shutdown. The discussion you i
l l
24 provided is understandable; however, the 30 days is somewhat l
'.)
25 disturbing.
Why was 30 days chosen rather than 10 days or 50 1!. -- - - -. -
. ~ _ _ - - - - - -
29 1
days?
Why is it contingent upon 30 days that these valves 2
cannot be exercised?
3 MR. BARLEY:
The intention there was, I believe, in 4
the tech speo that promulgated that requirement when it was 5
negotiated with the NRC, the intention was to apply that 6
testing requirement only to cold shutdowns, periods that 7
lasted for some period of time, r
8 MR. PAGE:
I don't recall that.
I don't recall it 9
from my writeup here either, in reference 4 that you 10 indicate.
I don't see any 30-day discussion here at all.
11 MR. BARLEY:
I am referring to the tech spoo on j
12 emergency feedwater.
I believe you are referring to the tech j
14 MR. PAGE:
That's not a tech spec.
That's an IST l
.15 SER.
I didn't remember any discussion of 30-day cold 16 shutdown.
17 MR. BARLEY:
Ycu are correct.
There is no tech speo 18 in the IST SER.
The reference I was making was to a different 19 tech spec amendment that addressed emergency feedwater 20 testing.
I think, as I recall, that predated the IST.
21 MR. PAGE:
That's a different ballgame, though.
It 22 should have been brought up before.
l 23 MR. SMYTH:
I was involved in that tech spoo review 24 as part of the lessons learned requirements.
There were 25 additional emergency feedwater surveillance requirements i
30 1
proposed by the NRC, one of which was testing emergency i
2 feedwater flow each 30 days or each cold shutdown in excess of
^
3 30 days.
We initially proposed to do no testing because of 4
the concern over steam generator chemistry.
The 30 days 5
represents a compromise position with Staff.
6 It was felt a shutdown greater than 30 days was an 7
infrequent evolution, and therefore the testing was not so 8
frequent to represent a significant risk of steam generator 9
corrosion.
What we didn't want to get into was testing every 10 cold shutdown, which may be a relatively frequent occurrence 11 during the life of the plant, and therefore, it would 12 represent a relatively more frequent excursion in steam 13 generator chemistry, which creates concern for corrosion.
14 MR. PAGE:
I believe in our previous discussions we 15 indicated that they would be stroked each cold shutdown if 16 less than three months have elapsed or more than three months 17 have elapsed since the last full stroke.
In other words, if 18 you went into frequent cold shutdowns, if you had done it in 19 the previous 90 days, you would not have to do it again.
So 20 it sounds like you have got two different situations, or one
~
21 is system related and one is component related.
22 MR. SMYTH:
The concern is in both cases the same, 23 though, and that is the steam generator water chemistry.
24 MR. BARLEY:
Again, there is a secondary concern 25 where we have existing tech specs.
Test systems on I
31 1
frequencies happen to differ from the Code-specified 2
frequencies.
We have attempted as much as possible to conform 3
to the tech spec frequencies.
Otherwise, you end up in the j
i 4
position where you end up having to conform to the most 5
conservative testing frequency of both requirements, which 6
defeats both purposes.
7 MR. PAGE:
This 30-day thing was ironed out when?
8 MR. SMYTH:
I believe it was back in 1981 or
'82.
9 MR. THOMPSON:
Do you know the amendment number for 10 that?
11 MR. SMYTH:
It was Amendment 78 that approved it.
12 MR. BASHISTA:
Thirty-one days was mentioned in our 13 original submittal, the last submittal, so we really haven't
~
14 changed that from the old submittal.
15 MR. PAGE:
It wasn't mentioned at the time we were 16 negotiating the SSER, though.
17 MR. BASHISTA:
It is in the old submittal, the 18 original submittal.
19 MR. PAGE:
It just doesn't make any sense.
20 MR. THOMPSON:
What is the date of that?
21 MR. BASHISTA:
January 31, 1980.
22 MR. PAGE:
So you are taking issue with our SSER, 23 then, that it does not represent what you were requesting.
24 MR. BASHISTA:
I think this is in the SER, isn't it?
I l
25 MR. PAGE:
I'm talking about the SSER Reference 4.
I
32 1
It could have been October 23, 1984?
Page 4 Item B.2?
~ '
2 MR. THOMPSON:
That references October 23, 1984 3
Staff Supplemental Safety Evaluation to GPU, Page 4 of the 4
attachment, and the Staff has granted relief for from full 5
stroking each cold shutdown if less than three months has 6
elapsed since last full stroke, and your response of August 7
22, 1985, F.1, is not consistent with that.
8 MR. COLITZ:
The concern is the same, I agree.
9 Chemistry of steam generators. You have got a tech speo 10 amendment that addressed one timeframe.
Here is another 11 timeframe.
What is the best way to handle that?
We ought to 12 he consistent.
13 MR. THOMPSON:
Let me add another point.
I think 14 what GPU's position is is that your latest submittal is i
15 consistent with the other testing in your current tech speos, 16 which can be used as a basis for the Staff to approve testing 17 frequencies which are different from other Staff positions.
18 Let me reiterate that.
Staff can use as a basis for 19 varianoes from established positions on surveillances and 20 testing in the tech specs that is different from standard tech l
21 specs if the testing proposed is consistent with other parts 22 of the plant-specific tech specs.
I think what the Licensee 23 is saying here is that the testing proposed in recent 24 submittal is consistent with the tech specs for other testing 25 of the EFW system, and therefore is a basis for relief from
l 33 1
other testing the Staff might propose.
2 I am mentioning that that is a basis for Staff --
I 3
can be used as a basis for Staff acceptance.
4 MR. PAGE:
It seems like we have also dropped out of 5
here the three-month discussion in addition to the fact that a 6
cold shutdown would have to exceed 30 days to get this kind of 7
an exercise.
Is there some reason that was also dropped out?
8 MR. SMYTH:
The reason is to not have two 9
frequencies and have to track the more conservative of the 10 two. I suppose it would be possible to change the EFW tech 11 specs to conform with the IST logic.
We are proposing to do 12 it the way we are proposing here simply because it seems to be 13 the path of least resistance.
We already have that in our i
14 tech specs.
It was reviewed by the Staff previously and 15 deemed to be an appropriate frequency to do it.
It wouldn't 16 result in excessive testing and it wouldn't result in 17 insufficient testing, and that is why we are proposing it now.
18 There is an alternative that we can change the EFW 19 tech specs to conform to your position; however, that would you know it 20 require a license amendment.
It would also 21 would be an additional level of effort but doable.
22 MR. THOMPSON:
Let me suggest we go back and relook 23 at the safety evaluation in support of Amendment 78, we the 24 NRC 25 MR. PAGE:
I think we could work with what we have
34 1
now on that item.
and see how that compares with 2
MR. THOMPSON:
3 what we have here, and come back to revisit this item.
4 MR. PAGE:
I think we can handle it with what we 5
have now, the information we have now.
6 MR. ROCKHOLD:
Item G.1, Decay Heat Removal System.
7 Review the safety function of valves DH-V1, 2 and 3 to 8
determine if they should be categorized A.
9 MR. THOMPSON:
Would anyone want to take a few 10 minute break here before we get into the DHR?
11
[ Recess.3 12 MR. THOMPSON:
Are we ready to continue?
13 MR. ROCKHOLD:
We will pick up on Iter 2 G.1 under 14 decay heat removal system. Review the safety function of 15 valves DH-V1, 2,
and 3 to determine if they should be 1
16 categorized A.
17 Your discussion talks about an Event V order and 18 whether or not identified.
Basically during the course of 19 our review we compile what we call a PIV candidate list for 20 the NRC since we looked very closely at each valve. We put 21 together this candidate list for Joel, and then off of that we 22 expect to see those in the tech specs, and those that are not 23 in the tech specs that are on our list, we try to find a 24 reason why.
And occasionally there are some real good reasons 25 for it, but these particular valves appear to form a pressure l
35 1
boundary isolation function to us, and that is the reason we 2
asked the question.
3 Your response is that you feel they are not 4
identified in the Event V Order and that Franklin Research 5
Center did not identify them as PIVs; therefore, they are not 6
PIVs.
Is that your position?
7 MR. PAGE:
A further enhancement on that is I think 8
you are keying on the Event V PIVs, which is the Order, which 9
relegates only check valves and only penetrating the 10 containment-type systems.
So we have another group here that 11 I guess you are probably not prepared to discuss beyond what 12 your position is in detail, I would presume, so I guess at i
13 this point we will just live with our candidate list.
We will 14 provida you with a list and what our position is, but then you 15 will also be told in your letter that it is draft.
In other j
16 words, pending generic resolution.
17 However, I guess at this time it would be good to 18 discuss, though, a small statement I made in your Reference 4 19 on page 2,
bottom of the page. Down at the bottom of the page 20 it says, " Additional requirements."
21 MR. MC GOEY:
Reference 47 22 MR. THOMPSON:
This is the October 23, 1984 Staff 23 SSE.
1 24 MR. MC GOEY:
Can you tell us where you are again, 25 Joel?
36 j
1 MR. PAGE:
Bottom of page 2,
Item B.1.
It is titled 2
" Additional Requirements."
3 MR. ROCKHOLD:
It's the very last paragraph on page 4
2.
5 MR. THOMPSON:
This is the asterisk at the bottom of 6
page 2 of the October 23 SSE.
7 MR. PAGE:
Do you have a response to that 8
statement?
I would like to include that in the meeting 9
minutes.
10 MR. THOMPSON:
Let me read it.
" Procedure 1300-3-T 11 should be clarified to indicate that this testing must be 12 accomplished during heatup from cold shutdown as required by 13 the Event V Order.
Testing during cooldown would be T
14 additional testing rather than the option specified in 15 Paragraph 2 of Procedure 1300-3-T."
16 MR. COLITZ:
The procedure and, I think, the tech allow us to do it, either correct me if I'm wrong 17 specs 18 cooldown or on heatup, 19 MR. PAGE:
I don't believe the Order does. We can 20 certainly look that up.
21 MR. COLITZ:
Let's check it.
22 MR. PAGE:
I'm reading from page 4-12 of the tech 23 spec provided by the Event V order under 4.2.6(1)(b).
" Prior 24 to achieving hot shutdown following a cold shutdown of greater 25 than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> duration unless testing has been performed l
l
37 1
within the previous nine months."
I don't see where the 2
option to test o
3 MR. SHIPMAN:
Would you read that again, please?
4 MR. PAGC:
Prior to achieving hot shutdown.
5 MR. SHIPMAN:
That is during the heatup, going?
6 MR. PAGE:
Following a cold shutdow.
I would say 7
that is most definitely during heatup.
8 Your procedure indicates you have the option of 9
doing it during cooldown or heatup.
10 MR. BARLEY:
I guess our interpretation, I guess our 11 previous interpretation on the tech spec, an interpretation we 12 all deduced that tech speo only re t you complete the 13 test prior to achieving hot shutdown c o.
it does not 14 specify necessarily that that test need
.ae on the heatup 15 as opposed to the cooldown.
16 MR. PAGE:
I don't see how it is possible to read it 17 that way.
18 MR. COLITZ:
It says if the testing has not been 19 performed within the previous nine months.
I may have done it j
20 on the cooldown.
I did it on the cooldown two weeks ago.
21 MR. PAGE:
You are interpreting that because you okay.
We will 22 tested during the cooldown, this cooldown i
23 further clarify that in our SER.
24 MR. COLITZ:
The main reason we have the option to 25 do it on cooldown is because if you do have a problem with the
38 1
valve, you go into it while you are cooled down.
[i 2
MR. PAGE:
We agree that it is nice to test on the j
a 3
way down, but the verification is required on the way up.
4 MR. COLITZ:
If you went into the valve, you would 5
have to redo the test on the heatup because of age because it 6
says after returning the valve to service following 7
maintenance or repair or replacement.
So if we tested on the 8
way down and found it was a problem and had to go into it, we 9
would have to retest on the way back up because of 10 4.2.6(1)(a).
11 MR. CONTE:
This is Rich Conte. What is the issue 12 for doing it during the heatup?
13 MR. PAGE:
It is to assure that if the valves had a
14 gone through any disturbance or anything happened to them 15 while you were in this cold shutdown, that you are sure they 16 are back in the cold position.
You may have had a part stroke 17 in there, you may have inadvertently stroked one or part 18 stroked one.
19 MR. BARLEY:
There is an inconsistency in that
(
20 position, and the tech spoo also allows you to go 9 months 21 without repeating that test, which could allow for many cold 22 shutdowns and many disturbances of postion, as you call them, 23 that could occur and the surveillance would still be 24 considered to be current and the valves considered to be 25 operable.
l
- ~ - -
39 i
MR. PAGE:
All I can say is a I personally had 2
nothing to do with the nine months or this tech speo, and my 3
interpretation of it after talking to the people that did is 4
that the nine months came from the Code, which was a misprint 5
on the '74 Code.
It would have said three months had they 6
read it correctly, instead of nine months.
7 MR. BARLEY:
The point remains, whether it is three 8
months or nine months.
9 MR. PAGE:
I understand what you are saying, but I 10 personally feel it is most important to test them on the way 11 up.
I think we could have a better position if you test it on 12 the way down, and if you had to work on anything on the way 13 back up, your acceptance criteria would be a little looser but 14 still the valves are shown closed.
That would be my personal 15 position, but I have not been able to change any of these.
16 MR. BASHISTA:
May I ask a question?
Did you say wo 17 do test on the way down and on the way up?
Test on the way up 18 would be the complete test?
19 MR. PAGE:
As described in your 1300-T.
20 MR. BASHISTA:
Or would that be some sort of partial 21 test, faster test?
22 MR. PAGE:
I don't understand what you mean by a 23 faster test.
24 MR. BASHISTA:
It takes a lot of time to run this t
25 test, a lot of whole time, a lot of critical path time.
If we
40 1
did it on the way down and we were going back up and we didn't 2
do any maintenance on the valve, would the way-up test be some 3
sort of abbreviated test?
4 MR. PAGE:
I don't know how to answer your 5
question.
I don't know what an abbreviated test is.
6 MR. BASHISTA:
Okay.
7 MR. PAGE:
If you can accomplish the leak testing to 8
the'oriteria specified, the acceptance criteria, if it takes 9
five minutes, I don't know.
10 MR. SANFORD:
Can we summarize where we are on this?
11 MR. PAGE:
This one, I understand where your 12 position came from, and I think we will provide a decision on 13 it one way or the other.
I think we have everything we need 14 from you, i
15 In reading your procedure,.! got the position 16 definitely that you guys are going to be testing on the way 17 down, which is obviously more preferable to any utility.
My 18 understanding of the Order is not that is what is intended.
19 MR. THOMPSON:
So to summarise on G.1, the response 20 to G.1 Staff finds acceptable pending generio resolution of 21 pressure isolation valve issue *- and the additional aspect of 22 the Event V,
which Joel ;ori d-oussed.
We will develop a 23 Staff position on whether it is tested during heatup, 24 cooldown, either or.
25 MR. MC GOEY:
Are you going to be sending a letter
41 1
back to us responding to our response, or is the next step you 2
are going to be writing up an SEh?
What is your next step?
3 MR. THOMPSON:
Just a minute.
4 MR. PAGE:
I am going to discuss a lot of these 5
items with my management today when we break and try to get a 6
response to you before you leave tomorrow, at least something 7
that can go on the record here.
There may be some items left 8
open for us even there because they want to discuss it further 9
with, say, the people that generated the Event V Order.
We 10 got gifted the Event V stuff in 1981, and our understanding is 11 that is what the requirement is, so if everybody is reading it 12 that way, then we want to know.
Maybe we need to change some 13 of the wording.
14 MR. MC GOEY:
So your action, then, is an item to be 15 discussed at the end of our meeting.
16 MR. THOMPSON:
Right.
17 MR. KNIGHT:
But you say you will give us a 18 response.
Will we get a written response?
19 MR. THOMPSON:
This entire meeting will be presented 20 in a written response which Clair is writing and preparing, 21 and that will be provided.
22 MR. KNIGHT:
But that will separate for the SER?
23 MR. THOMPSON:
That will be the SER.
24 MR. ROCKHOLD:
He commented Clair's notes will 25 become the SER.
43 1
MR. PAGE:
That is what the SER will be generated 2
from.
It is not the SER.
It will be meeting minutes.
3 MR. KNIGHT:
The question I was asking would be: The 4
management position that you intend to give us at the end of 5
the day, will those be confirmed in writing?
6 MR. THOMPSON:
Yes.
,p r
7 MR. PAGE:
If the decision is made and given to you 8
in this meeting, it will show up in those meeting minutes and 9
you will get a copy of the ones as written here, and I believe 10 we will get you a copy of the typewritten, which will just be 11 a typewritten version of what you are looking at.
12 MR. ROCKHOLD:
Okay. Are we ready to proceed with 13 Question G.2?
Provide a more detailed technical justification 14 for not full-stroke exercising valves DH-Vi and 2 quarterly.
15 The reason we asked that question, I think, is 16 rather obvious to anyone who looks at a drawing anyway.
The 17 reason we asked the question was there was no discussion in 18 the program on why these valves cannot be exercised quarterly 19 as required by the Code. There should be a cold shutdown 20 justification provided in your program.
21 So I guess what we are asking for is an additional 22 footnote that discusses the DH-V1 and 2.
I guess it's a 23 clarification of Note 3.
Note 3 states that these valves 24 cannot be cycled because the margin of safety would be reduced 25 by opening either of these two pressure barrier valves.
I am
43 1
'sure it is not clear just what that means.
Typically what we 2
see here are valves are interlocked and 3
MR. BARLEY:
If you refer to our written response, I 4
think we have provided some additional detail.
5 MR. ROCKHOLD:
Okay.
So I guess we are asking the 6
statement about the valves being interlocked should be 7
included in the footnote in the program rather than having it 8
referenced here in just your responses.
9 MR. PAGE:
Is there any surveillance on those 10 interlocks?
11 MR. BASHISTA:
The answer is yes.
12 MR. PAGE:
What do you do, exactly?
13 MR. SHIPMAN:
I would have to check to be sure, but 14 I believe it is part of the core surveillance as done in the 15 ESAS system.
That interlock is included in the ESAS system 16 cabinet.
I believe the electronics of that interlock are 17 tested quarterly.
18 MR. RANSOM:
Then will you include an additional 19 discussion in note 3 in the IST program?
20 MR. COLITZ:
If that is required to resolve the 21 issue, yes.
22 MR. MC GOEY:
Is that necessary since it is already 27 on the record, already on the docket?
Do we have to go back 24 and modify that?
25 MR. PAGE:
It is good for the sake of completeness 4
44 1
to make sure the program stands alone. I would assume you will
[}.
2 be making other changes too at the same time.
What some
- f 3
people do during these meetings is actually have their program 4
here and they are marking it up as they go along.
5 MR. MC GOEY:
So I think you put that down for our 6
action item, then.
7 MR. ROCKHOLD:
Okay.
8 MR. THOMPSON:
Let me give you the reference to the 9
place where that footnote will be modified.
This is the July 10 10, 1984 IST program submittal, page 8 of 37, footnote 3.
11 MR. ROCKHOLD:
Okay.
12 Question G.3.
Review the safety function of valves 13 DH-V4A and B to determine if they should be categorized A.
14 Next to your response I have written: are these 15 valves currently Appendix J 1eak tested?
16 MR. BASHISTA:
No, they are not.
17 MR. ROCKHOLD:
Okay.
Now, you provided a discussion 18 about the Event V valves, and that was not our concern at the 19 time.
They appeared at a containment interface.
We were 20 wondering if they were curtently Appendix J 1eak tested for a 21 containment isolation.
22 The response is no, so we have no further discussion 23 about it.
24 Question G.4.
Review the safety function of Valves
,I 25 DH-V6A and B to determine if they should be categorised A,
and
45 1
provide a more detailed technical justification for not 2
full-stroke exercising these two valves during power operation 3
or cold shutdown.
4 These particular valves are the container reactor 5
building sump outlet isolations.
Are the valves currently 6
leak rate tested for Appendix J?
7 MR. COLITZ:
No, they are not.
8 MR. ROCKHOLD:
For your information, these are some 9
valves that Joel was referring to earlier'that received a 10 modified Appendix J 1eak test at some facility.
Some plants 11 are leak rate testing these particular isolation valves, but 12 they are doing with a water test rather than air test like 13 Appendix J.
14 MR. SHIPMAN:
We have a tech spoo requirement to 15 leak test those valves for decay heat system leakage less than 16 six gallons -- we do have a decay heat system leak check in 17 our tech specs that we have to perform on the suotion side of 18 decay heat pumps in tests between that pump and the suction in 19 the decay heat pump, but I was corrected in that we put a 20 flange on that connection and leave the valves open.
21 MR. ROCKHOLD:
Okay.
We need to further discuss the 22 stroking and stroke timing of these isolation valves.
Your 23 response has the statement, "We believe it is impractical 24 to test these valves each cold shutdown," yet a technical 25 discussion is not provided on what this impraattoality really
46 l
1 is.
Can you be more specifio?
s 2
MR. BASHISTA:
We addressed that in Relief Request s...
3 1.1.C.
Essentially that says stroking decay heat valves 6A and 4
B will allow a certain amount of dirty water, essentially, to 5
he let into the low pressure system just because of the way 6
the piping is sloped or the piping configuration.
There is no 7
drain so that we can get that water out of there before stroke 8
timing of the six valves, so we would like to continue to 9
stroke the six valves on a refueling basis rather than cold i
10 shutdown basis.
11 MR. ROCKHOLD:
I guess I don't see the difference
{
12 between cold shutdown and refueling outage. What is different 13 during a refueling outage that allows you to do this testing?
14 MR. BARLEY:
The refueling outage test that
]
15 Mr. Shipman referred to earlier requires this as a system 16 leakage test to enter the reactor building sump and flange the i
17 open end of the sump outlet line, which then allows us to 18 isolate the sump and the DH-V6 valves and the suotion piping 19 from the dirty reactor building sump water. It's under those o
20 conditions that we are allowed to stroke the valve.
21 MR. ROCKHOLD:
There is normally water in this 22 reactor building sump?
23 MR. BARLEY:
Yes.
24 MR. ROCKHOLD:
Typically we see a separate smaller 25 sump to take care of normal leakage and everything in this i
47 1
particular area, and the containment sump or reactor building e'
2 sump is dry.
That is not the case at your facility?
~..
3 MR. SANFORD:
We have only the one sump, and it does 4
maintain a water level 5
MR. ROCKHOLD:
Higher than these pipes?
6 MR. SANFORD:
Higher than these pipes.
7 MB. BARLEY:
For the refueling intervals, we drain i
8 the sump to some level, clean it up to reduce worker exposure, 9
go down and install those flanges.
That's why we would like 10 to maintain that refueling interval frequency for that test.
I 11 MR. ROCKHOLD:
So the reason for not performing the 12 same test or the same evolution during each cold shutdown 13 would be a significant increase in manpower and exposure to
't
~
14 personnel.
15 MR. RAMSOM:
You install flanges to keep the water 16 from running from the sump down into the valves, then?
17 MR. BASHISTA:
The question was do we install 18 flanges that do not allow the dirty water to enter the low 19 pressure injection system.
No, the valves are not installed 20 for that purpose. The flanges are I
21 MR. BARLEY:
In that function.
22 MR. COLITZ:
Run through the sequence of what you do 23 on a refueling outage.
24 MR. SHIPMAN:
Drain the sump as low as we can 25 get it, override an interlock that provides the seal to keep
48 1
that pipe covered, and drain the sump as low as we can get 2
it.
We go and install the flange, then recycle the valve.
In 3
addition to that, we pressurize that length of pipe between 4
that flange and the suotion valve to the decay heat removal 5
pump to, I believe, around 60 pounds and leak test it to 6
ensure we meet the tech speo on the six gallons per hour 7
leakage from the decay heat removal system.
8 MR. ROCKHOLD:
Are you also saying that you cannot i
9 drain the sump and stroke these sump isolation valves without 10 installing the flange
- 11 MR. SHIPMAN:
I think if you cycle the six valves 12 without installing the flange, you will empty the decay heat 13 removal system into the sump down from the BWST to the 14 isolation valve.
15 MR. ABRAMOVICI:
The suction of the decay heat 16 systne from the BWST water from the sump.
There is more 17 operated valves, most on BWST and the sump, and the piping in 18 between would eventually drain into the sump if we opened 19 those valves.
20 MR. SHIPMAN:
I think the confusion is that there i
21 are two purposes for putting that flange on.
One is to 22 prevent any dirty water that would come into the decay heat 23 removal system. The second purpose is also to prevent any 24 water from the decay heat removal system from emptying into 25 the sump and becoming rad waste, and we are ta1xing on the 1
-. - ~ -.. -.
,-~.----,----.---------:---~r-
49 1
orders of 5000 to 6000 gallons of water each time you cycle
/Th 2
the six without the flange on it.
Sb/
3 MR. ABRAMOVICI:
The six valves are slow-acting 4
4
- valves, I think on the order of a minute stroke.
5 MR. PAGE:
While Clair is catching up on the notes 6
here, I would like to clarify something from the MEV that I 7
have noticed in your writeup here.
For instance, on this item 8
we were just discussing here, we believe it is impractical to 9
test these valves each cold shutdown, I think it is very l
10 important in all submittals that we deal with on this subject 11 to deal with Code wording.
When you say tests, that could
)
12 mean leak test, it could be stroke test, it could be part 13 stroke test.
I think it is very important to use Code j c' 14 wording.
It can be very confusing sometimes as to what is 15 being discussed, really.
16 MR. ROCKHOLD:
Are we ready to move on to Question 17 G.5 now?
18 MR. COLITZ:
How did we leave G.4?
i 19 MR. ROCKHOLD:
G.4 basically is we agree with your 20 basis.
We would like to see some of this information that we 21 just talked about including in the relief request, but we 22 pretty much agree with what you are saying and we will 23 recommend that relief he granted for refueling outage 24 exercising of these valves.
25 MR. MC GOEY:
So GPU has no action.
50 1
MR. ROCKHOLD:
The action required on your part 2
would be to add some additional information to your relief G/
l 3
request, explaining in a little more detail on the problems i
4 with more frequent exercising of these valves.
5 MR. RAMSOM:
Like what has to be done during the 6
testing, during refueling to prevent the water from entering 7
the decay heat removal system or the decay heat removal water 4
from draining into the sump and so forth.
9 MR. ROCKHOLD:
Again, Question G.5, how are valves 10 DH-V14A and B part stroke exercised quarterly?
What alternate 11 test methods have been investigated to full-stroke exercise 12 these valves at the Code-specified frequenoy?
13 The 14s are the decay heat removal pump suction t
14 check valves from the BWST. Clair and I had a discussion about 15 this approximately 73 percent stroke of these check valves 16 during the refueling outage test, and we were wondering why it 17 wasn't a 100 percent stroke.
18 MR. BARLEY:
This is Rick Barley.
i 19 Again, this is a similar case to the one we 20 discussed before where a single valve functions in flow path 21 to systems.
In this case, under the worst case accident, you i
22 would have to pass flow from both the low pressure injection 1
23 system and the building spray system. The test done here is i
1 24 the LPI test, That lacks the additional increment of the i
25 building spray flow.
-,m,
51 1
Just for your information, the LPI flow we are 2
talking about is on the order of 3000 gallons per minute, and 3
the building spray flow is approximately 1500 gallons per 4
minute.
5 MR. ABRAMOVICI:
Maybe there is something worth 6
mentioning.
We have the counts from Walworth, which I think 7
we submitted to you before based on our last discussion, but 8
the calculation we got from them are at 3000 gpa, the valve is 9
opened 60 degrees, which translates to 73 percent open. At 10 4000 gpa, which is another point we have it, 68 degrees.
So 1
11 the delta, I think, is small.
12 MR. PAGE:
I remember the discussion very clearly.
13 I believe you are working with three unknowns, and you are 14 saying that the chart verifies that the valve is at a position 15 using only flow rate.
I believe you probably remember the 16 tong discussion we got into.
You have got to have two of the 17 unknowns to really know that the valve is there.
The delta p i
18 across the valve is the other one, the one that you would need 19 to know.
20 MR. ABRAMOVICI:
The delta p was calculated by the 21 manufacturer, but we don't know what it is.
22 MR. PAGE:
I understand on his valve test, perfect 23 5
valve, brand new valve, he had position indication on that 24 valve, so he was verifying the various low coefficients of the i
25 valve at the various positions, which are the curves that you
52 1
are using.
2 MR. FAGE:
Just based on flow rate alone, you are 3
putting in 67 percent of the required flow rate?
4 MR. SANFORD:
That's correct.
The building is 5
designed for 1500 gym, the decay heat system for 3000 gym on 6
tests, 3000 out of 45 total.
i 7
MR. ROCKHOLD:
The worst case sooident scenario, the 8
14s have to pass the 2500 gym during any test. They are only 9
put,through about 3000.
10 MR. PAGE:
So you are basically putting a pretty 11 significant part stroke on the valve.
l 12 MR. SANFORD:
That's correct.
13 MR. PAGE:
I would just leave that for us. That may i
14 he a close one there. We tend to lean in your direction on f,a i r l y decent part stroke, 15 something where you are getting a 1
16 so I would say there probably is no problem with that.
We 17 will contact you if there is.
18 MR. RAMSOM:
I will leave it an open item for the 19 NRC.
i 20 MR. ROCKHOLD:
Question G.6.
Provide a more 21 detailed technical justifloation for not full-stroke 22 exercising valves DH-V16A and 5 during cold shutdown.
The 23 valves in question here are the decay heat pump discharge 24 check valves.
25 In your discussion to the previous question talking l
53 1
about the 14s, you state that those valves are quarterly i
2 part-stroked by recirculating back to the BWST.
Am I correct?
3 MR. BARLEY:
Yes, sir, you are correct.
4 MR. ROCKHOLD:
So if the 14s are part stroked back 5
to the BWST,'the 16s would also be part stroked back to the 6
EWST.
What percentage of this part stroke i s this quarterly 7
test that you are performing?
8 MR. BARLEY:
I think the flow rate on that 1
9 rectroulation test is in the neighborhood of 800 to 900 I
10 gallons per minute.
11 MR. ROCKHOLD:
And that value is just based on 12 physical restrictions in pipe?
13 MR. RARLEY:
Yes.
I guess the flow rate is about 14 800 gallons a minute to the BWST and about 125 gallons a 15 minute to the 1-1/4 inch rootroulating that you see back to i
16 the pump section.
17 MR. ROCKHOLD:
But even the combined flow is not 1
18 oven half of design accident flow.
19 MR. BARLEY:
CNodding affirmatively.3 20 MR. ROCKHOLD:
Okay.
Would these particular valves 21 he full-stroke exercised during decay heat removal operation 22 at cold shutdown?
23 MR. BASHISTA:
Yes, they will.
One of the valves 24 will, either A or B.
25 MR. ROCKHOLD:
Again we get into the discussion
,.y y
e.--.--
.,-,,w.,,-m.-
,,-__c--,
,y,,,,,,_mm
_.-,,...-.,..--m.-,e
54 1
about the impracticality of only doing one train. Did we 2
decide to leave that open?
What are we going to do about i
3 that?
4 B-2.
4 MR. SHIPMAN:
You decided to leave B-1 open 5
MR. FAGE:
You basically changed your position from 6
our previous meeting on this subject, then, the one that the 7
SSER was based on.
8 MR. BASHISTA:
That's true. We modified it a little 9
bit.
We have looked at what we actually did, modified it 10 slightly.
11 MR. FAGE:
I think you said you had proposed to 12 utilise flow rate equal to or greater than the maximum seen in 1
13 the Safety Analysis Report, so it has changed from that 14 position.
You have assumed a 67 percent flow rate now.
l 2
15 MR. ROCKHOLD:
No, not on the 16s.
16 MR. PAGE:
Oh, I was back on the 14s.
17 MR. BARLEY:
That's true on the 14s and not on the 16 16s.
The answer -- what you said is applicable to the DH-V14 difference' in 19 valves but not to the 16 valves.
There is a 20 flow paths involved.
21 MR. PAGE:
Okay.
We are saying at least for the 14 22 valves, this is a different position now from what we had 23 discussed previously, which was refloated in the SSER.
24 MR. ROCKHOLD:
It is also different for the los in
)
25 that they get a full stroke during cold shutdowns, and this l. -.
55 1
states that they are part stroking quarterly, full stroking
('N 2
each review.
They do, in fact, get a full stroke on the 16s 3
during cold shutdown.
4 MR. THOMPSON:
At least one frame.
5 MR. ROCKHOLD:
Okay.
Now, this is still somewhat of 6
an open item as far as we are concerned.
7 MR. THOMPSON:
Is this the same as B-27
~
8 MR. ROCKHOLD:
Similar to B-2 on whether they are 9
going to do one train or two trains each cold shutdown, i
10 MR. ROCKHOLD:
I don't know the last time we 11 discussed it whether we came to any real conclusion.
12 MR. PAGE:
This is 1 and 4 you are talking about.
13 MR. ROCKHOLD:
Right.
14 MR. PAGE:
How did we leave the previous one?
What 15 was the writeup on the first one where we had switching from 16 one loop to the other?
17 MR. RANSOM:
1 put that if the Licensee decides to 18 only test one train of decay heat removal, that means cold 19 shutdown due to the inconvenience of switching loops.
This is 20 not in sooordance with the Code or the current NRC position.
i 21 I said this remains an open item for the Licensee.
1 22 MR. PAGE:
Licensee or the NRC?
23 MR. RAMSOM:
Well 24 MR. MC OOEY:
1 put it down as an open item we are 25 going to get back to at the end of the meeting.
1
56 1
MR. PAGE:
This is going to be one we are going to
~
2 add to the list.
You may want to say refer to that.
But !
l 3
think in this case we are not talking to the same system, 4
right?
5 MR. RAMSOM:
Yes.
6 MR. FAGE:
The exact same thing in all four?
They 7
would be switching loops?
8 MR. ROCKHOLD:
All the ones that I'm thinking of. It 9
would be just starting up the second loop of decay heat each to cold shutdown, not to exceed once every three months.
11 MR. RANSOM:
I will just put this will be discussed 12 later.
13 MR. ROCKHOLD:
Let me get this straight again.
We 14 are talking about the 16s, which is the pump discharge check 15 valves. Those check valves are partial-stroke exercised to 16 approximately 1000 gallons a minute, 800 to 1000 quarterly.
17 MR. BASHISTA:
That's right.
18 MR. ROCKHOLD:
During each cold shutdown at least 19 one of them is full-stroke exercised.
20 MR. BASHISTA:
That's right.
21 MR. SHIPMAN:
Full flow.
When you say full stroke, 22 I'm back to Joel's comment.
Does it bang against its 23 MR. ROCKHOLD:
The NRC's definition of full stroke i
24 exercising by utilising flow is that if you produce a flow 25 rate equal to or in excess of the maximum flow rate you take l
57 l
1 credit for in any safety analysis, that by definition is a 2
full stroke.
j i
3 MR. SHIPMAN:
That's correct.
i 4
MR. PAGE:
Is an adequate demonstration of a full 5
stroke.
6 MR. ROCKHOLD:
Then the only real open item on the 7
16 valves is whether you are going to be required to do both j
1 j
8 valves each cold shutdown, not to exceed once every three 9
months.
(
r 10 MR. THOMPSON:
And that can be tied back to Item 11 B.27 1
12 MR. ROCKHOLD:
Correct.
j 13 MR. SHIPMAN:
I guess the position, Joel, that we i
14 took in our submittal is when we are in cold shutdown, we are 15 definitely on one decay heat removal system, and one 16 valve 16 we can demonstrate will pass 3000 gallons, and the DH-V5 on the CF-V5 on that side would be partial 17 that side would be 16 stroke testing at 3000 gallons a minute, but our submittal 19 says we would test one each cold shutdown and both each 20 refueling, taking the position that excess wear and tear on 21 the system just to swap over to the other decay heat removal 22 system just to swing check valves represents an unnecessary 23 wear and tear on the decay heat removal system.
24 MR. PAGE:
1 guess that's a site enhancement over
/
25 what you previously said, in which it was the actual
58 e
1 manipulations of going from one loop to the other.
2 MR. SHIPMAN:
The actual manipulations is not a 3
complicated series of events.
It's a couple of valves and you 4
start the pump.
But the hydraulics of the situation isn't.
5 You know, check valves do slam.
You are moving an awful lot 6
of water very quickly from an operational point of view. !
7 don't agree that to swing a check valve, you should challenge l
8 the system.
It is much like the position people are taking on 9
starting diesels.
You can get to the point where excessive l
10 testing overwhelms the benefit that you get from it.
11 MR. PAGE:
I say the frequency of the testing on the 12 diesels is somewhat different from what we are discussing 13 here.
~
14 MR. SHIPMAN:
The concept of wear and tear on the 15 system is what I am talking about.
16 MR. PAGE:
I don't think there is any comparison of 17 wear and tear on a diesel and swinging a check valve. I can't 18 imagine they are that similar, especially on a cold shutdown I
19 frequency versus whatever you are doing on your diesels, which 20 is monthly or greater.
21 MR. THOMPSON:
Let me ask Rich Conte, the 22 resident: Do you have any comment?
23 MR. CONTE:
My opinion is it can be done.
I don't i
24 have a re appreciation for wear and tear on the system, but the 25 Licensee is trying to give a position right now.
If you ask
--w
59 1
me to come to a decision, if it was my choice, I would do it
' ')
2 to resolve the issue.
3 MR. THOMPSON:
Okay.
This point for O.6 is one we 4
will rediscuss at the end. Staff will think about it, talk 5
about it, and we will get back at the end of the meeting.
6 MR. ROCKHOLD:
Okay.
For everyone else's 7
information, with my exposure to pump and valve in-service 8
testing programs, I know of no other utility that is only 9
stroking one train each cold shutdown.
10 Question G.7.
Review the safety function of Valves 11 DH-V22A and B to determine if they should be categorized A/C.
12 I think this is just a notation problem that wo 13 had.
In your response you stated that the delta is used to 14 differentiate between "A"
valves, which are leak tested by 15 Appendix J, and the delta valves, which are leak tested as 16 WASH-1400 valves.
In the valve tables, we still need to see 17 these valves categorised "A"
or "A/C."
18 In this particular case it would be A/C.
As defined 19 in the Code, the valves do perform a function where their 20 leak tight integrity is important, and they are leak rate 21 tested; therefore, the category should be A/C.
You can still 22 leave the delta there in the other column, but as far as valve 23 category is concerned, it needs to be A/C.
24 MR. RAMSOM:
So you will do that, then?
25 MR. BARLEY:
We can oorrect the table if that will
60 1
resolve the issue.
, [h 2
MR. THOMPSON:
Let me get the reference to that.
v': ];
3 MR. SHIPMAN:
Page 3 of 37.
4 MR. THOMPSON:
Page 3 of 37 of the July 10,
- 1984, is that 3 or 77 7 of 37.
Okay.
To 5
and it is to revise 6
revise C to AC under oategory for the 22A and B valves.
7 Okay.
8 MR. ROCKHOLD:
Question G.8.
Provide a detailed
?
9 technical justification for not full-stroke exercising valves 1
10 22A and B quarterly.
How are these valves full-stroke 11 exercisd during cold shutdowns while upstream valves 16A and B 12 are only part-stroke exercised?
{ -
13 The second half of that question, I think we already s y 14 concluded that the upstream valves, 16s, are full-stroke i
i l
15 exercised during cold shutdown, so the cold shutdown testing 16 for valves 22 is already answered.
We are wondering how you i
17 do a part stroke exercise quarterly on these valves.
Wait a 18 minute.
Provide a justification for not performing a part 19 stroke test quarterly or full stroke.
20 In your response, the first paragraph is 21 acceptable.
That explains why the valves cannot be part 1
22 stroked or full stroked quarterly.
The second paragraph 23 states that the valves are full-stroke exercised both during 24 cold shutdown and refueling outages; cerrect?
25 MR. BASHISTA:
That's right.
Decay heat valves 22A l
61 1
or B during each cold shutdown, both during refueling.
2 MR. SHIPMAN:
It is tied in to the unresolved item 3
on B.2.
4 MR. PAGE:
This relates to our previous 5
discussion. This is number 3 on the list, I guess.
We have 6
B.2, 0.6 and 0.8 all on that same discussion.
7 MR. ROCKHOLD:
Given what they have provided in i
8 writing, the only open issue concerning valves 22A and B is i
I 9
the stroking of one valve during each cold shutdown versus two 10 valves during each cold shutdown.
11 MR. RANSOM:
I didn't hear.
Was it decided this is 12 a full stroke exercise, 3000?
i i
13 MR. ROCKHOLD:
Yes.
- f. s 1
(
14 MR. RAMSOM:
Before I leave it too far, on the 15 DH-V16A and B, are you planning on modifying your table, Table 1
16 B-1, to identify a full stroke exercise during cold shutdowns?
17 MR. BASHISTA:
Is the question are we going to add a 18 C*
in there?
i 19 MR. ROCKHOLD:
No. Currently for your type of test 20 and test frequency columns for Valve 16, you have a full 21 stroke indicated at refueling, whereas you are also performing 22 a full stroke more frequently at cold shutdowns, currently on 23 one of the two.
24 MR. BASHISTA:
Top of page 8,
I think it says we are 25 going to modify the submittal.
It has a C*
in there.
l l
l l
i
62 1
MR. RANSOM:
We are talking about the 16s now.
2 MR. ROCKHOLD:
The next page talks about 16s also.
3 MR. BASHISTA:
I'm talking about 16s also.
4 MR. RANSOM:
Okay.
I didn't know.
At the top of 5
page 8 it looked like that only applied to the 22 valves, the 6
C*.
7 MR. BARLEY:
We s a '. d the same thing in response to 8
G.6.
9 MR. RANSOM:
Okay.
Thank you.
10 MR. PAGE:
Let's take a five-minute break at this 11 moment.
12
[ Recess.3 13 MR. ROCKHOLD:
Okay.
Ready to pick up on Question 14 G.9.
What is the safety function of Valves DH-V38A and Bf 15 Your written response is acceptable.
16 Item G.10.
Review the safety function of DH-V59A 17 and B to determine if they should be included in the IST 18 program.
19 Your written response is acceptable, and these 20 valves need not be included in the program.
21 Under river water system, question H.1, review the 22 safety function of Valves DR-V6A and B,
7A and B to determine 23 if they should be included in the IST program.
24 Your written response is acceptable.
25 MR. COLITZ:
I think this will come up in several i
t 63 1
occasions where we say we will add these valves to the IST 2
program.
You may want to discuss frequency and type of test 3
on that now.
i j
4 MR. ROCKHOLD:
Make sure there are no differences.
l 5
MR. PAGE:
If you have anything not being tested 6
quarterly, make it evident to us so we can write down any cold i
7 shutdown justifications or anything where you don't meet the 8
Code, like part stroke versus full stroke.
9 MR. COLITZ:
I think we agreed to test them 10 quarterly.
The type of testing we do on these, Joel has j
11 looked at that.
J 12 MR. BASHISTA:
The valve consists of a body.
4 13 Inside that body there is a rubber flapper.
There is no hinge 14 pin, essentially no moving parts except the rubber flapper.
15 Essentially the rubber bonds.
The rubber flapper is l
16 reinforced with a metal plate inside the rubber flapper.
17 The way we propose to test these is to essentially this end is open, this end over 16 go in here with a pencil a pencil or some other similar instrument, l
19 here is piping j
20 and push on this rubber flapper and make su e this rubber 21 flapper moves up.
I guess you have about a 30 degree swing, 22 so it's easier to do with a pencil.
You need about two or 23 three pounds of force whtoh is in and up.
24
! need to see if you guys have any trouble with that 25 type of testing method.
l
64 1
MR. PAGE:
It sounds like you are full stroking it.
2 It appears you are even getting an idea of how much force is 3
required.
You would notice if there was excessive force 4
required.
5 MR. BARLEY:
We are not proposing to instrument this 4
6 test with spring gauges.
7 MR. PAGE:
You are not going to do that?
8 CLaughter.3 9
MR. ROCKHOLD:
And you are performing this penoi1 10 test, if you will, quarterly.
11 MR. RASHISTA:
Yes, in conjunction with regular pump 12 testing.
13 MR. ROCKHOLD:
We have no problem with that.
14 MR. PAGE:
That is probably one of the better check 15 valve situations around.
16 MR. ROCKHOLD:
Question 17
!.1.
How is EF-V3 part-stroke exercised quarterly?
Provide 18 detailed technical justification for not full-stroke 19 exercising these valves at Code-specified frequency.
Have the 20 internals been removed from this valve?
21 MR. COLITZ:
That was one, I think, that appeared in 22 Harold Denton's August 16th letter that you said you wanted to 23 discuss tomorrow.
24 MR. ROCKHOLD:
Okay.
25 MR. SANFORD:
I think we ought to discuss this one 4
65 1
now.
2 MR. COLITI:
Okay.
Let's cover it now.
t 3
MR. PAGE:
This is an all stainless steel valve?
4 MR. BARLEY:
It's oarbon steel.
5 MR. PAGE:
It's not stainless?
6 MR. BARLEY:
The feedwater piping is typically 7
carbon steel.
8 MR. PAGE:
When you say like new and it's exposed to 9
river contamination, you give a description like new, I was 10 Just trying to confirm the details.
Can you provide us the 11 disassembly report like you did on the other valves?
12 MR. BASHISTA:
I think that was part of the 13 disassembly report.
We have some pictures here if you want to 14 look at them.
15 MR. PAGE:
Sure.
16 MR. BASHISTA:
These are all EF-V3.
17 MR. PAGE:
These are all as found?
18 MR. BASHISTA:
Yes.
We didn't have to do anything 19 to it.
i 20 MR. PAGE:
Are there some parts missing in this 21 picture?
22 MR. BASHISTA:
I hope not.
i 23 MR. PAGE:
How do you get that flapper in there?
24 MR. BASHISTA:
I think the way that one is is l
i i
l 25 attached to the bottomi right?
I'm not positive.
Let me see i
i
l 66 1
~the pictures.
I can't remember it.
It was a ver'y simple type 2
valve is what I remember of it.
3 MR. FAGE:
It looks very similar to a lot of your In other words, the internals 4
makeup valves.
As I recall i
5 are actually made up of two separate pieces.
One is the disk 6
which is on that pin.
That's a solid pin now.
You replace t
7 the other ones with a solid pin rather than two pins.
But the seat itself, 8
that means you have to take the other part 9
not just the disk.
Doesn't the seat have to come out with 10 that?
11 MR. BASHISTA:
No, the seat did not have to come 12 out.
Yes, you are right.
I guess what you can't see is i
13 someplace in the body there is a base for the hinge pin.
14 MR. PAGE:
I was wondering how you can get a hinge 15 pin in that looks like that.
16 MR. BASHISTA:
I'm not positive, but I think it 17 slides in in the body.
The hinge pin slides in the body, and i
18 the hinge pin is' held in on either side by two big sit screws.
4 j
19 MR. PAGE:
Where are those?
20 MR. BASHISTA:
It is in the body, I think, j
21 MR. BARLEY:
I believe there are ears cast into the 1
l 22 body.
i 23 MR. PAGE:
It is not obvious to me how this valve I
24 works.
- /
25 MR. BASHISTA:
We can get you a drawing.
m 3
.,___--m-
,,,-y, y.
.sy_
,.-r_
g.
67 1
MR. ROCKHOLD:
I think the hinge pin goes into the
/~
2 bonnet on this particular drawing. I can see there is a raised 3
area here.
One of these tabs goes on either side of the 4
raised area. The pin goes through there, through this, through 5
the other here, then the whole assembly sits inside the body 1
6 and then just the physical limitations in the body keeps the 7
pin from sliding back and forth.
Probably a little bit of J
8 clearance, j
9 MR. BASHISTA:
The EF-V3 was part of the disassembly i
10 report.
11 MR. PAGE:
Freviously it had not been disassembled 12 before we gen 4 rated the SSER.
13 MR. BASHISTA:
We disassembled it just for IST i
14 purposes, for no other reason.
15 MR. PAGE:
I see how it is designed now.
The other 2
16 ones had little looking screws and stuff that held them in.
17 MR. BASHISTA:
This one has the hinges on the 18 bottom?
19 MR. ROCKHOLD:
Take a look at the bottom of the 20 bonnet in that particular photograph.
I think you can see a 3
21 raised area that the pin would go.
i 22 MR. FAGE:
There is a lug in the center of the i
23 bonnet that has a hole in it, and then the body itself 24 restriots motion.
Pretty good design.
I like that.
i
)
25 Do you have any proposal for future stroking or
.m 68 1
verification of this valve?
'nternals.
We 2
MR. SANFORD:
We intend to remove the i
3 intend to stroke them right on out of the valve.
4 ELaughter.3 5
MR. ROCKHOLD:
What is the frequency of this?
6 CLaughter.3 a
7 MR. SANFORD:
nce.
8 CLaughter.3 9
MR. PAGE:
We had a couple of makeup valves that 10 were dans that way too, weren't there?
11 ELaughter.3 12 MR. PAGE:
There were two sets of pictures, right?
13 MR. BASHISTA:
There are several pictures.
14 MR. PAGE:
Two sets of the same picture?
15 MR. BASHISTA:
Could have been.
16 MR. PAGE:
Is it possible for us to keep one set of 17 those?
I think there were two identical sets.
18 MR. BASHISTA:
If you really need a set, we can 19 probably get you a set.
l 20 MR. THOMPSON:
We would like to ask you to provide a 21 set of those pictures for us.
22 MR. BASHISTA:
Okay.
23 MR. PAGE:
What is the latest status of the removal 24 of the internals?
25 MR. SANFORD:
The engineering package, including the
69 1
5059 Safety Evaluation, is under preparation and will be 2
released by the end of the month to the plant.
3 MR. PAGE:
Will be released to the NRC?
4 MR. SANFORD:
To the site board.
5 MR. THOMPSON:
We don't really get the 5059 6
evaluations.
It is up to the resident to inspect them as he 7
sees fit.
8 MR. PAGE:
Then NRC has no' action associated with 9
the removal of those internals.
10 MR. SANFORD:
That is correct.
11 MR. PAGE:
But you don't know whether they are going 12 to be removed either at this point.
13 MR. CONTE:
It's a sure sign that they are leaning 1
14 towards that, and the 5059 will probably evaluate whether 15 there is no safety significance in removing the internals.
16 MR. PAGE:
So you feel quite sure the internals will 17 end up being removed.
Can we discuss some frequency, assuming 18 that it does nJt happen?
19 MR. THOMPSON:
Could we back off from that question 20 rather than making work by the acceptable pending removal or 21 contingent upon removal of the internals, and put some time 22 frame on it?
Give us some idea of how long it would be before 23 the internals would be removed, and we can set a time limit.
24 MR. PAGE:
I think it is better to go ahead and set 25 a frequency, assuming that they are not going to be
70 1
removed. If they are removed, there is no concern at all.
2 Rather than leaving it hang.
\\
3 MR. PAGE:
Have you had a chance to determine what 4
would be an acceptable interval?
5 MR. COLITZ:
The eddy current outage, that we are 6
required to come down for 90 days after full power operation.
7 The tech speo, the license says 90 days at full power, 120 8
days at 50 percent power.
So we have a scheduled shutdown 9
assuming -- I would commit to something earlier than that, but 10 if they are not getting the engineering out until the end of 11 this month, we could get that job done the next week.
But if 12 we get the okay to go and we are hot, we wouldn't want to pull 13 the emergency feedwater system.
14 That's why I'm saying we do have a scheduled outage 15 90 days or 120 days after we go back into operation.
16 MR. THOMPSON:
So you would remove the internals 17 during that outage, or if not, provide a testing frequency?
18 VOICE:
That's correct.
19 MR. PAGE:
Can we discuss a testing frequency now?
20 I feel sure you guys feel strongly the internals will be i
21 gutted from the valve.
Maybe this is a good time to discues 22 it.
If that did not happen, what would be the most probable 23 proposal from you?
24 MR. COLITZ:
Part of our objection here was the 25 chemistry concern of getting river water into the steam
j 71 l
1 generator.
2 MR. PAGE:
That's a real concern using flow to do 3
the stroke.
4 MR. COLITZ:
I wouldn't put any more frequent l
5 disassembly than we have on the other valves, especially since 6
it's like new once every ten years.
7 MR. P A G E :-
Why don't you write it down?
If it's not 8
gutted, they will probably make that proposal, Clair, to do it 9
once every ten years as they have for other valves in their 10 disassembly program.
11 MR. ROCKHOLD:
We are ready to start on Question 12 I.2.
Provide a more detailed technical justification for not 13 full-stroke exercising Valves EF-V11A and B, 12A and B,
and 13 14 during each cold shutdown.
How is Valve 13 partial-stroke 15 exercised quarterly?
16 Okay.
The response is that relief was previously 17 granted per Reference 4 and was also addressed in Reference 3.
18 I guess my question is: why not each. cold shutdown?
19 Is this where we talk about the 30 days cold shutdown, 20 preceding 30 days?
Okay.
l 21 MR. BARLEY:
I think we are into the similar issue 22 with toch spec Amendment 78 and trying to conform the testing 23 requirements to those, to be consistent with those testing 24 requirements.
V 25 MR. ROCKHOLD:
Okay.
.,,r.--,c
,,m.., - - + >
,.,,.,,.~m..,y-r.%.-.r-
72 1
The only item I see left to discuss on this 2
particular set of valves is why can you not partial stroke the 3
11s at the same frequency and same methods as you stroke the 4
13s?
5 MR. BASHISTA:
I think the answer has something to 6
do with piping configuration.
7 MR. ROCKHOLD:
From the drawings that we have, we 8
see the same vent and drain capability for the 11s as the 13.
9 Is there some physical difference that keeps you from doing 10 it?
11 MR. BARLEY:
I think we figured out the answer for 12 that.
Trying to remember the test procedure.
It involves the 13 test procedure lineup.
The test procedure lineup involved
-3 i
14 closing the 10 valves so that we were not forced to rely on 15 the 30 valves, which were control valves for leakage, as the 16 only barrier between us and the thermal cycle and the 17 emergency feedwater nossles.
So we closed the 10s, which 18 MR. BASHISTA:
If you close the 10s, we have no 19 vents or drains, no accessible vents or drains; therefore, you 20 can't do a partial stroke test.
j 21 MR. BARLEY:
The difference between that and the 13 22 situation is there we have the two valves, which you can shut 23 and still provide a better drain capability so you can provide 24 a barrier between yourself and the emergency feedwater nozules l
25 to avoid thermal cycling due to control valve leakage.
~..
73 1
MR. ROCKHOLD:
I am trying to write down a true 2
answer to the question.
The original question asked to 3
provide a more detailed technical justification for not 4
full-stroke exercis'ing the valves.
They just come back and 5
say in our previous response it was addressed in Reference 3,
6 and I don't think they discuss it.
t 7
MR. THOMPSON:
Would you summarise the position on 8
I.2?
We still have the same concern as F.1, 30-day testing, 9
cold shutdown greater than 30 days 10 MR. ROCKHOLD:
That is the only open issue involved it in Question I.2, is the cold shutdowns exceeding 30 days, 12 MR. THOMPSON:
Which is the same as I t em F.1 ?.
13 MR. ROCKHOLD:
Right.
l t
14 Ready for I.3?
Review the safety function of the 15 following valves to determine if they should be included in 16 the IST program.
i 17 Response for EF-V1A and B and 2A and B is 18 satisfactory.
Written response for Valves 19A and B and 21 1
19 still left us with the question: will the valves be included 20 in the program?
The discussion sounds very good to us, but 21 it didn't really specifically state whether the valves would 22 or would not be included in the program.
23 MR. ROCKHOLD:
Are we getting anywhere on the 24 discussion for Valves EF-V19A and B and 217
(
25 MR. BARLEY:
I guess where we are is that we are p
l
74
~
1 saying the valves do not have an isolation function, do not 2
need to be tested closed.
They are open during the pump test 3
that is done as part of the flow path, and if they did not 4
open, that would be detected as part of the pump test.
5 Whether you sign them off as an individual test or not, I 6
guess, is the question.
7 MR. ROCKHOLD:
Okay.
I was going to say I agree 8
with what you have said in your written response, but we 9
expected to see these valves individually identified in the 10 pump and valve testing program and tested at the same 11 frequency as the pump t e*s t ?
The safety function is to open to 12 provide pump protection and prevent loss of pump.
13 MR. BARLEY:
I guess our conclusion is that we would I
14 agree to put it in the program and put a sign-off in our 15 procedures doing the same tests that we are now doing with the 16 pump.
17 MR. ROCKHOLD:
So EF-V19A and B and 21 will be 18 included in the IST program's Category C valves and exercised 19 open at least quarterly.
2G MR. BASHISTA:
We agree.
21 MR. ROCKHOLD:
Joel had a confusing point or a point 22 of confusion on the discussion for Valves EF-V2A and B.
The 23 second sentence says these valves are not required to perform 24 an isolation safety function since 30A and B can be used for
(
25 isolation of the affected OTSG if required.
75 1
MR. PAGE:
What my question was: is the formal s
2 oredit assigned to the V30A and B valves or are these backups 3
in case the others don't work?
4 MR. COLITZ:
Our emergency procedures call for 30s.
5 MR. PAGE:
What you are saying for the V2 valves is 6
that they are 5 passing valves, Category B passing.
They have 7
no safety functions whatsoever.
We asked one question; you 8
answered another question. We asked if there were any safety 9
functions, and you said they have no isolation safety,,
10 function.
11 MR. COLITZ:
Yes, that's the only function those 12 valves can perform.
13 MR. BARLEY:
The answer to both questions would be 14 the same.
15 MR. PAGE:
It seemed like you answered another 16 question that wasn't really asked.
Okay.
17 MR. ROCKHOLD:
Okay.
We will proceed on to question 18 J.1.
Nuclear Services Closed Cycle Cooling Water System.
19 Provide a more detailed technical justification for not 20 full-stroke exercising valves EF-V4 and 5 during cold 21 shutdown.
You provide a discussion there but you really don't 22 say why this test cannot be performed during cold shutdown.
I 23 guess this is, again, based on putting river water in the 24 steam generators; correct?
25 MR. SHIPMAN:
Yes.
l
. = _. -
76 1
MR. ROCKHOLD:
I guess I don't see any difference in 2
plant conditions for cold shutdown versus refueling outage 3
testing for these particular valves.
l l
4 MR. SHIPMAN:
I think you are correct as far as i
l i
l 5
plant conditions and valve manipulations.
There is no
]
6 difference.
It is how many times you want to introduce 7
contaminants into your emergency feedwater system.
O l
8 MR. ROCKHOLD:
You indicate in your relief request 9
that you do flush the river water from the suction of the 10 emergency feedwater pumps, and we are interested in seeing the 11 valves tested as close to the Code-specified frequency as 12 possible unless there is a real technical justification for 13 not doing that.
The thing is we fail to see the technical s
~
14 justification for not 15 MR. SHIPMAN:
The sys, tem is not designed to be 16 flushed.
There are drains, but from a chemistry point of l
17 view, you are talking about parts per million, parts per 18 billion. The flush that can be performed is probably 19 marginal.
In my estimation, it is marginal.
20 MR. PAGE:
What does that mean?
21 MR. ROCKHOLD:
Stalemate, I guess.
4 22 MR. CONTE:
I guess what you are saying, Henry, is 23 there is a lot of stagnant places in this section of piping, 1
it's a 1
24 in the suction piping, that you are really sort of i
25 makeshift evolution to drain that header, and you are not
i 77 1
going to get it all.
2 MR. SHIPMAN:
That's right.
3 MR. COLITZ:
Again, chemistry is the overriding 4
concern here.
I think another factor is it is really our 5
fourth or last supply of last defense.
You have got two 6
condensate storage tanks.
You have got the condenser, you 7
have got the million gallon tank. Then'when you tre all out of 8
that, then you open up V4 and 5.
So the probability of 9
using all -- what assurance do you want that they are going to 10 work?
We feel, with the chemistry and so forth, that the 11 refueling test is adequate.
12 MR. THOMPSON:
I think the Staff should take the 13 additional information you have provided and consider it and 14 leave this as one of the issues to come back to at the end.
15 MR. PAGE:
Anything you can provide in terms of 16 details here will really help because I think in general, wo 17 are tending to lean with you, but we need something to write 18 in the SER, obviously, to support a refueling frequency.
So 19 anything you can provide we would really appreciate because it i
20 will help us make our decision.
21 MR. THOMPSON:
Let me clarify that, Joel Are you 22 asking them to provide additional discussion?
23 MR. PAGE:
Even now, if they wanted to.
Now, or 24 tomorrow morning, for that matter.
You mention things about
.w.
j 25 flushing, or the imprecise methodology, I guess, used for l
78 1
flushing which would introduce contaminants to the system or
~
2 which would most likely introduce contaminants, and that 3
overriding concern should dominate as opposed to doing it 4
every cold shutdown.
5 HR. THOMPSON:
Do you have anything more to add to 6
this as additional justification?
7 MR. SHIPMAN:
I think from an operational 8
standpoint, we used to do that same type of flush with the 9
building spray thiosulfate tank on the BS-V4s that came out 10 from that tank, and I think history showed that was a 11 potential source of contamination on the generators in the 12 first place.
13 MR. CONTE:
Let me see if we can get a little more 14 detail here, Henry.
The present flush that you can do is 1
15 basically use your condensate storage tank to flush out the 16 suction piping.
17 MR. SANFORD:
Basically it's a fill and drain type 18 flush, if you will.
It's a very low flow back out of that 19 pipe through a drain line.
It is not using the condensate 20 system to flush the pipe.
You can't get any velocity in the O
21 pipe itself.
22 MR. CONTE:
So it's a fill and drain system, and the I
23 other key point I think you are trying to make here is that 24 the source of flush water injection would not be at these j
^n j
25 river water valves, 'nhich means that would be sort of a l
l
79 1
stagnant, end of piping where the contaminant is.
Your source 2
of water is the condensate s'torage tank, which is another 3
section of piping, another part of the system which is not 4
directly flushing the contaminant.
It's a feed and bleed j
5 method.
6 So I tend to hear what they are saying, that it is 7
difficult to do an ideal flush on the system.
8 MR. PAGE:
I think that is an important detail that 9
I was asking for. That's the kind of detail that helps.
I 10 think at this point that would probably be enough on that 11 particular item.
12 MR. SHIPMAN:
We can provide the as-built piping 13 configuration, piping layout drawings to Joel that will show 14 the system fill or drain path.
15 MR. CONTE:
They already have the drawings.
I think 16 the question is put in words how you do it, and by reference 17 to these drawings, they will be able to see it technically 18 where you don't get a good flush.
19 MR. SMYTH:
Is this a question of docketing as I think we have said what we have 20 opposed to a question of 21 to say here.
Is this just a question of putting it on the l
22 record?
23 MR. PAGE:
I think earlier we-discussed the fact 24 that this urdoubtedly will result in an evolution in your 25 program, enhancing relief requests, providing little details j
80 1
like this fill and drain.
2 MR. SMYTH:
Do you feel like a footnote or 3
explanation of that program --
4 MR. PAGE:
However your program is structured. I 5
think yours is structured in terms of footnotes, where most 6
people print actually formal relief requests.
7 MR. RANSOM:
They have f a.rma l relief requests except 8
for cold shutdown justifications.
9 MR. PAGE:
Those are in terms of footnotes.
That 10 format is good.
It's just nice to include t, hose details so it 11 stands alone rather than chasing different 12 MR. SMYTH:
Assuming we had done that, you would 13 otherwise agree with our position?
I 14 MR. PAGE:
I think right now we probably have enough 15 details on what the problem is there to probably agree with j
16 you. I an only going through my level.
It's just what I have 17 heard.
But I think that most people will agree.
18 MR. THOMPSON:
So at this point we are not asking 19 for any more information from you.
20 MR. SMYTH:
Except in the form of a formal submittal 21 to tie this all together.
i e
22 MR. PAGE:
I think there will be a new submittal j
23 anyway covering many small details.
24 MR. THOMPSON:
We will clarify what submittals we
/
25 need later.
l 1
~
81 s
1 MR. PAGE:
I would like to recommend that we go to 2
lunch in about ten minutes so we can come back at 12:30.
3 Otherwise, I think it will cost you an hour and a half for i
lunch rather than an hour if you go at noon.
There are so 5
many people that go to lunch at noon in this area.
6 MR. ROCKHOLD:
Why don't we try to get K.1 knocked 7
out before we break for lunch.
8 Diesel generator jacket, sir, and gear box lube oil 9
cooler coolant system.
How are check valves 32A/A and the 10 rest of those individually verified to full-stroke exercise 11 quarterly?
12 Basically you are saying that satisfactory diesel 13 cooling during a one-hour full load test demonstrate these 14 valves full stroke.
15 MR. RANSOM:, Drawings showed two independent Jacket 16 coolers.
They are totally independent, so if one of the you wouldn't have coolant to 17 valves fails, you would still 18 one side?
Is that true?
19 MR. ROCKHOLD:
Our major concern here is that you 20 have a given check valve that has failed and goes undetected.
21 Do you have adequate instrumentation on the diesels that would l
l 22 indicate valve failure if one particular valve failed?
I l
l 23 MR. RANSOM:
During this one-hour full load test.
l 24 MR. COLITZ:
Can you tell from the prints, Henry, if l
25
,there is adequate instrumentation that if one of them failed, i
\\
82 1
we would know it by instrumentation?
2 MR. SHIPMAN:
Not individual check valves.
3 MR. COLITZ:
Not on individual check valves.
4 MR. RANSOM:
So you get enough flow through one of 5
the two valves to prevent high temperature on the diesel 6
during the one-hour test?
7 MR. SHIPMAN:
That's a design question I don't know 8
the answer to.
9 MR. BASHISTA:
Is the concern that the disk would 10 get loose and block a pipe?
11 MR. ROCKHOLD:
The concern is that if any one check 12 valve should fail, would you know it?
If you would know if a 13 given check valve failed, it would be indicated by some i
14 parameter change on the diesels, then we would find your 15 current testing acceptable; but if you can see where a given 16 check valve will fail, a redundant flow path would prevent you 17 from having any trouble and the check valve failed would go 18 undetected for a long period of time, that is our concern.
19 MR. ROCKHOLD:
Well, have we come up with anything 20 that we need to say about these or is this going to remain an 21 open item for the Licensee to further evaluate the system 22 configuration to determine if current testing verifies i
23 individual valve operability?
24 MR. COLITZ:
You know current testing doesn't 25 MR. ROCKHOLD:
You have a lot of temperature i
I
83 1
indications.
You may very well have sufficient information.
IT 2
MR. BARLEY:
There are a lot of temperature TEN 3
indications and log readings that the operator takes as a part 4
of that diesel test that we would have to look at with 5
respect to that to give you a good answer to your question.
I 6
think we will need to do that.
7 MR. ROCKHOLD:
So at this point we will leave this O
8 as an open item for the utility to determine if current system 9
configuration can positively verify operability of each check 10 valve.
11 MR. PAGE:
In addition to that, I would like to add 12 a small question.
Why are they there at all?
In looking at 13 the drawing, it doesn't look like you need them.
/, ;
' ~
14 MR. SANFORD:
That may well be the case. Part of the 15 skid design, what the skid designer had in mind is hard to 16
- tell, 17 MR. ROCKHOLD:
At this point, how about we break for 18 lunch, come back at 12:30 and pick up on Question K.27 19
[Whereupon, at 11:30 a.m.
the hearing was recessed, 20 to resume at 12:30 p.m.
the same day.]
i 21 22 23 24 h;
25 w-
84 1
AFTERNOON SESSION 2
[12:353 3
MR. THOMPSON:
Let's get back on the record.
4 MR. ROCKHOLD:
K.2 looks like it is going to be 5
quite similar.
Question K.2.
Do Valves EG-V31A and B, 47A 6
and B have a required fail-safe position?
Again, the word i
7
" required" is emphasized.
8 MR. BASHISTA:
Let's talk about these valves a 9
little bit.
They are very similar to the valve in your 10 automobile thermostat. There is a wax element that expands 11 when it is heated and allows the valve to open.
The valve 12 could probably fail either way, either open or closed.
13 MR. ROCKHOLD:
So there is no external controlling
~
14 system --
15 MR. BASHISTA:
It is all internal.
16 MR. ROCKHOLD:
It sounds very similar to the things 17 we saw.
18 MR. PAGE:
Is that a drawing of the valve?
You mean 19 different failure modes would get you different failure?
j 20 MR. BASHISTA:
Yes, just like your automobile.
Your 21 thermostat could fail closed.
22 MR. PAGE:
If they fail, they usually do fail closed 23 or as is. They don't usually fail open, I don't think.
That 24 is very unusual.
l l
l 25 MR. BASHISTA:
The bottom comes in, the bottom area
i 85 l
1 port area A, and either goes out B or C.
2 MR. PAGE:
These are the valves. These are the ones 3
on K.2, right?
4 MR. BASHISTA:
Those are K.2 valves.
5 MR. PAGE:
So I guess you are wondering what you can 6
do about testing them.
7 MR. BASHISTA:
Yes.
8 MR. PAGE:
Are there any other parameters you could 9
look at to see if they are performing their job?
10 MR. BASHISTA:
We already verify acceptable water 11 temperature.
12 MR. PAGE:
That is at full load for one hour?
13 MR. BASHISTA:
That's right.
14 MR. PAGE:
That would tell if you are at full load 15 that they are at least opening up.
Let me ask you a question 16 on your temperature test, your one-hour full load test. Do you 17 monitor the temperature at different points during the test?
18 MR. BASHISTA:
From what I can remember, there are 19 several different recordings we take.
20 MR. BARLEY:
There is a log sheet that forms a part 21 of the surveillance procedure, that the operator makes a round 22 on the diesels at various points during the operation and i
23 records the temperatures in their normal recommended position.
l 24 MR. PAGE:
At several times during the hour?
25 MR. SHIPMAN:
Every hour.
86 1
MR. BARLEY:
It is done every hour at full load, 2
ends up at full load, so you reach an equilibrium position to 3
take those readings and compare them against 4
MR. PAGE:
I guess I didn't understand.
You said 5
you run a full load for one' hour?
i 6
MR. BARLEY:
That's correct.
7 MR. PAGE:
So you have one temperature data point 8
during that one-hour run?
9 MR. SHIPMAN:
If it is a one-hour run, yes.
Of 10 those temperatures, Joel, on the jacket coolant side they are 11 measuring each coolant temperature, which would tell you 12 whether or not that control valve is functioning or whether 13 you have individual cylinder pumps.
I did call back to find 14 out on the other coolant side what temperature data we 15 collect.
At this point I don't have an answer.
We need to 16 look at that a little bit more.
17 MR. PAGE:
It looks like that may be the way to go.
18 Are you going to get back to us on that system 19 there?
l 20 MR. SHIPMAN:
Yes.
l 21 MR. BARLEY:
I think we need to revi,ew the adequacy 22 of our temperature measurements.
23 MR. PAGE:
You may want to look to see if there is 24 any kind of trending,you do over time to see if there was some 25 difference now from other times that you could attribute to o
87 1
this component or something like that if it were not working 2
as well as it used to.
That sort of thing.
I don't know if i
3 you have ever considered that.
4 How long does it usually take a diesel to stabilize 5
once you start it at full load?
6 MR. SHIPMAN:
I would say within the hour it 7
stabilizes.
8 MR. PAGE:
It takes you an hour to stabilize at room 9
temperature?
1 10 MR. SHIPMAN:
Much quicker than that.
11 MR. PAGE:
I was thinking 10 to 20 minutes.
MR. BARLEY:
It's something on that order of 12 13 magnitude.
7 14 MR. PAGE:
I guess we will talk about that again.
15 MR. CONTE:
What is the alternatives to 16 this: opening the valves up?
17 MR. PAGE:
That wouldn't really do anything for l
18 you.
You can't open them up.
I think they are self contained.
19 MR. BARLEY:
They are almost autonomous valves.
20 MR. CONTE:
If they screw up, you throw them out?
21 MR. PAGE:
If it goes, it's gone.
22 Before we leave that subject, are you familiar with 23 what the normal failure mode of that valve is?
Is that for 24 loss of the function to open?
If[f 25 MR. BASHISTA:
I don't know what the normal failure
88 1
would be.
2 MR. PAGE:
Okay.
I didn't know if it sprang to open s
3 or something.
It would be important to know which way it 4
would fail normally if it did suffer failure.
Would it fail 5
as is or would it fail open?
I would hope it failed open.
6 MR. ROCKHOLD:
Actually, that is not a valid 7
question in that it does not have an open or closed. It has a 8
Port A and Port B.
9 MR. PAGE:
What do Port A and Port B do?
10 MR. ROCKHOLD:
One bypasses through the cooler and 11 one sends it through the cooler.
12 MR. PAGE:
I would think you would want to send it 13 through the cooler.
14 MR. ROCKHOLD:
And 98 percent of the time, the valve 15 is somewhere in between.
It's bypassing some of the flow.
16 MR. PAGE:
I would think the designer would want you 17 to send it through the cooler if it failed.
18 MR. ROCKHOLD:
I would think so.
19 MR. CONTE:
What is the experience of other plants?
they must have similar.
20 Do they have similar 21 MR. PAGE:
Some of them do.
22 MR. ROCKHOLD:
D.C.
Cooke had a similar situation, 23 different valve design but basically the same thing.
No 24 external controls whatsoever.
)
25 MR. CONTE:
They monitored performance by 4
..m.
89 i
temperature indications?
2 MR. ROCKHOLD:
Yes.
Most plants have a temperature 3
contrcl valve that's electropneumatic controlled.
4 Question L.1 on penetration fluid block and i
i 5
penetration pressurisation system.
When is the fluid block 6
system expected to be disabled and the valves listed removed 7
from the IST program?
8 You say that it has now been deleted or has been 9
disabled and the valves have been deleted.
We have no problem 10 with that.
11 Item M.1, emergency feedwater.
Provide the specifio 12 technical justification for not verifying Valves 12A and B 13 closed during cold shutdown and refueling outages. What 14 alternate methods have been considered to verify operability 15 of these valves?
16 This is one that Joel needs to make a statement on, 17 I think, to see if what you have previously discussed can be 18 satisfactory.
I think this falls into the cold shutdown every b
19 30 days category, I belitve.
24 MR. PAGE:
I think that is an acceptable answer. It 21 agrees with our SSER.
Wait a minute.
I think the only 22 difference is Cycle 6.
Weren't we talking Cycle 5?
23 MR. COLITZ:
Startup Cycle 6.
Cycle 5 is the one 24 we are about to go into.
1 25 MR. PAGE:
I guess one of the problems I had is we
l 90 1
seem to get into a nomenclature problem on Cyc1'e 5,
Cycle 6.
2 Somehow it seemed like there was an extra one put in there 3
somewh*re.
4 MR. COLITZ:
Agreed basically to come up with a 1
1 5
method prior to the next cycle, which is Cycle 6.
I l
6 MR. PAGE:
That would be the next refueling outage.
7 MR. COLITZ:
Yes, next refueling outage.
We have 8
got to put it in the next refueling ' outage.
We will do it the 9
next refueling outage.
10 MR. FAGE:
Okay.
You can indicate it in the writeup 11 there. Cycle 6 is the next refueling outage.
12 MR. RANSOM:
I'm*just putting " Refer to Licensee's 13 response" on that one.
(
14 MR. PAGE:
For further clarification, clarify Cycle 4
i i
15 6 refueling outage is the next upcoming refueling outage.
16 MR. ROCKHOLD:
Why don't we proceed with Question 17 N.1.
How are the following valves fail-safe tested?
HM-V1A
)
18 and B, 2A and B, 3A and B,
and 4 A and B.
i 19 The written response is satisfactory.
20 MR. PAGE:
The read switches are verified at least is that correct 21 overy two years to verify actual position in accordance with the Code?
22 23 MR. BASHISTA:
I think on those valves what we do is 24 we leak rate test the valves in the closed position and verify
(
25 the valve is closed, indicating closed in the control room i
91 1
MR. PAGE:
Do you over verify that when it indicates 2
open, you have flow in the line?
3 MR. SHIPMAN:
We have to do a hydrogen recombiner, 4
hydrogen monitor and recombiner surveillance.
It would prove 5
that there is system flow.
6 MR. PAGE:
You do verify that the position indicator 7
is correct, at least on a two-year basis?
8 MR. BASHISTA:
That's correct.
9 MR. CONTE:
That can be verified in follow-up 10 inspections. That is sort of an indication of your test 11 parameter that needs to be calibrated in accordance with the 12 Code.
The Code says two years?
13 MR. PAGE:
At least each two yearss.
14 MR. CONTE:
We could pick that up in the inspection l
15 program.
16 MR. PAGE:
Also as an enhancement of that, the Code 17 says ones that are normally inaccessible -- we did put in an 18 inquiry on that.
They said really it means all of them.
That 19 is poorly written.
They mean all safety-related position 20 indicators, not ones that are normally inaccessible during I
o 21 plant operation.
22 MR. MC GOEY:
Question 0.1.
How are Valves HR-V22A 23 and B and 23A and B fail-safe tested?
1 i
24 MR. COLITZ:
Do you have a particular concern with 25 these?
These are the same type valves as the previous one, l
\\
l
92 1
and the answer was the same.
I just wondered what the problem 2
might be with these versus the other ones.
3 MR. ROCKHOLD:
They have read switches also, then.
4 Okay?
O.1.
5 MR. BASHISTA:
Yes, they have read switches.
6 MR. PAGE:
I have one small question on Reference 1
7 4.
Are any of these valves the same valves that were in the 8
splitted block system?
9 MR. BASHISTA:
In 0.1?
10 MR. PAGE:
In 0.1, yes.
11 MR. BASHISTA:
No.
12 MR. PAGE:
There were no tag numbers applied 13 before.
That's why I wasn't sure.
This all, in fact, stays
(-
14 the same, then?
Okay.
I 15 MR. ROCKHOLD:
Item P.1, intermediate cooling i
16 system.
What is the safety function of Valves IC-V1A and B7 17 You state that these valves do not provide an 18 essential safety function and they may be used during certain 19 normal, abnormal positions to place a second letdown cooler in 20 service.
I guess our question arose from having the valves in
~
21 the program.
22 The rerson we asked about these is the NRC has 23 stated that a utility may place nonsafety-related valves in 24 their IST program at their discretion if they would like, but 25 NRC would not review any requests for relief from the testing
(
93 1
requirements of the Code for nonsafety-related' valves. And
~
2 these particular valves are identified for cold shutdown 3
testing.
That is the only problem we had with them.f 4
MR. PAGE:
You agree that they are not 5
safety-related?
One of the things we recommend in this area 6
is to expand your legend and put like an "NSR" in there next 7
to a valve and just say not safety related. That way, anybody 8
immediately when they look at that realise what category that 9
is in in case somebody wonders why you are testing refueling 10 and no relief request, no anything, but it is obvious, then, 11 in looking at the table it is not safety related but for your 12 own reasons you want to have it in this program.
13 MR. ROCKHOLD:
One of the problems we may get into 14 is that someone later on who starts reviewing your program 15 says here is a valve not tested for the Code and it is not 16 addressed in the SER.
There is an apparent discrepancy.
17 Whereas, if you have it identified as nonsafety-related, then 18 there is no discrepancy.
19 MR. THOMPSON:
So do we want to add in some way a 20 note in the IST program that identifies on page 19 IC-V1A and 21 B as not safety related?
22 MR. ROCKHOLD:
CNodding affirmatively.]
23 MR. THOMPSON:
Did you get that, Rick?
24 MR. MC GOEY:
Yes.
We will take the action.
25 MR. ROCKHOLD:
Question P.2.
How are Valves IC-V2, u/
94 1
3, 4 and 6 partial-stroke exercised during power operation,
'?s 2
and what are the consequences of valve failure while full-3 stroke exercising these valves during power operation?
Do 4
these valves perform a containment isolation function?
5 That was kind of unnerving to us in that you have 6
some containment isolation valves that you are purposely 7
installing some mechanical blocks on it to prevent e
8 foreclosure. That kind of bothered u's.
You know, what if you 9
needed the containment isolation while those blocks were in 10 place?
11 As far as this side of the table is concerned, wo 1
12 would be more receptive to not seeing any stroke at all on the 13 valves during power operation and then performing a full h
14 stroke at full shutdown unless you have some other 15 requirements, that there are some other requirements where you 16 have to stroke.
17 MR. BARLEY:
There are other requirements to I
18 demonstrate the actuation of the engineered safeguards reactor i
building isolation signals, so that is what the blocks were 19 I
20 originally developed for, to demonstrate that the signal got I
21 to the motor operators for the valves.
22 MR. PAGE:
All the way through to the component.
l 23 MR. BARLEY:
Yes.
And we just picked up on that i
24 original testing requirement, take credit for that exercise.
- )
25 MR. SMYTH:
To kind of put your mind at ease a
95
"^
1 little bit, these particular valves are really only 2
represented, the containment isolation valve, for the systems 3
for accidents which represent large breaks in containment. The 4
systems -- they are enclosed systems which would not be open 5
to containment atmosphere and small accidents, if you will 6
So the closure signals for these valves are 30 pounds reactor 7
building pressure and line rupture detection for the system 8
that they serve.
9 So you know, your concern over blocking them 10 for shutting is somewhat tempered by the fact that the type of 11 accident they need to close for are the very, very low 12 probability type events.
13 MR. BARLEY:
They are also not normally placed 14 except during the actual test.
15 MR. ROCKHOLD:
If you are already required to do 16 this ten percent closure test, and we certainly can't argue 17 with. hat.
18 MR. PAGE:
Is this in the tech spec?
19 MR. BARLEY:
Tech spec test on the engineered 20 safeguards system.
l 21 MR. PAGE:
Do you know the tech spec number?
22 MR. SMYTH:
I will take a guess.
4.1?
23 MR. COLITZ:
It doesn't talk about blocks but gives
\\;p 24 you the requirements for testirm logic.
25 MR. ROCKHOLD:
On thtse questions where we have 1
96 1
found your written responses satisfactory, there is no sense 2
in me even reading the question, I don't believe.
3 We found Item Q.1 satisfactory.
4 Q.2 was satisfactory.
5 Q.3 we may need to talk about a little bit.
6 What alternate methods have been investigated for 7
full-stroke exercising valves MS-49A and B?
And, are these 8
valves exercised individually?
Do these valves perform a 9
safety function in the closed position?
10 MR. PAGE:
In reference 4 it indicates you were 11 supposed to supply calculations to verify-that 80 percent 12 opening on 48 percent flow rate?
13 MR. COLITZ:
Julien, did we ever supply the cales on 14 that 3 percent?
15 MR. ABRAMOVICI:
We have the calo for 48 percent 16 flow.
I thought it was originally submitted with the other 17 calos. But, I could be wrong.
I guess I have to refer to the 18 license.
19 47, 49 to be exact.
20 MR. PAGE:
I guess this would be considered an 21 appeal item, since it contradicts our SSER.
22 MR. CHERNY:
What is it exactly that is being 23 appealed?
24 MR. PAGE:
In our SSER this was the valves, these 25 are the main steam supply check valves to the aux feed pump.
l
97
'E>
1 In our final SSER we told them they were required on 2
a cold shutdown basis frequency to full stroke these valves in 3
some way.
4 They have come back with the same story we looked at 5
before, the 80 percent open based on 48 percent flow rate, 6
which was never verified.
At least not to my knowledge.
7 There was no verification of that.
8 I think we had already decided we would have 9
accepted that if they could show the 80 percent opening.
10 MR. CHERNY:
I'm just trying to figure out what is 11 the appeal they are going to state to George Lear tomorrow, 12 that he is supposed to make a decision on tomorrow.
E.
13 Are they now saying they can't provide the 14 calculations, or what?
15 MR. PAGE:
It sounds like they have disassembled the 16 valve in late '84 and found it to be in excellent condition, 17 and so they are just still saying they are going to do their 18 flow test at 48 percent flow rate.
19 That is in contradiction to what our SSER states.
20 MR. CHERNY:
We didn't have anything in the SSER 21 about calculations or anything?
22 MR. PAGE:
No.
I think we requested the the other l
23 calculations a long time ago before our original
/
24 meeting we had on this.
3 25 MR. McGOEY:
As I understand, we gave you the
o 98 1
calculation pages.
I recall the calculations were based on 2
flow rate alone in some chart that was developed by the check
)
3 valve manufacturer, which is philosophical 4
MR. ABRAMOVICI Same issue as before.
5 MR. CHEENY:
So, you are saying that we did get 6
calculations that weren't acceptable?
7 MR. PAGE:
That is right. 'No Delta P available.
8 MR. CHERNY:
What habpened with. regard to the 9
discussions about periodic disassembly on a rotating basis?
10 It says in their response that they have disassembled one.
11 MR. PAGE:
Once.
12 MR. CHERNY:
Recently, apparently.
13 MR. PAGE:
Yes.
Just one of the two valves was 14 disassembled, but there is no other discussion of any future 15 work.
16 MR. CHERNY:
Did our SER go into that at all?
17 MR. PAGE:
No, not on disassemblies.
I think this 18 was done after our SSER.
SSER went out October 23rd, 1984.
19 It just says late 1984.
~
20 MR. CHERNY:
But in effect as far as the appeal 21 tomorrow we are saying two things; or maybe even three things:
I 22 We want them either full stroked, or they should 23 verify the 80 percent, which they apparently haven't done yet.
24 Or, we want periodio disassemblies.
25 One of three things.
l 99 1
MR. ABRAMOVICI:
I think the 80 percent is y
2 incorrect.
The80 percent number in the latest submittal I 3
think is a typographical error.
4 MR. COLITZ:
It should be 36.
5 MR. ABRAMOVICI.
It should be 36 percent, if you 6
read our previous submittal.
7 MR. PAGE:
Are you talking about, the 80 percent 8
should be 36 percent?
9 MR. ABRAMOVICI; Yes.
10 MR.'COLITZ:
That's what is in the previous 11 submittal.
12 MR. ROCKHOLD:-
Is the 48 percent valid?
,,s'T 13 MR. ABRAMOVICI:
48 percent is valid, yes.
14 MR. CHERNY:
48 percent low, and 36 percent open, 15 right?
16 MR. ABRAMOVICI-In other words, the valve is a 17 bigger valve than you would normally need for this service.
18 It is an oversized valve.
19 MR. PAGE:
Is the 80 percent also incorrect in this 20 current 21 MR. ABRAMOVICI' The 80 percent is incorrect.
22 MR. PAGE:
Okay.
23 MR. CHERNY:
That drops out the calculation.
.j) 24 MR. COLITZ:
The calculation was done for that.
The 25 last submittal said 36 percent.
I don't know how we got 80 in
100 l
1 the submittal.
The previous submittal in the calos were 2
correct.
Somehow 80 got in here and it doesn't belong.
i 3
MR. COLITZ:
When I reviewed this, if you will look 4
at Exemption 4 in this submittal, okay, it was 36 percent.
I 5
didn't know.
Julien from Tech Functions provided this.
I o
6 found the discrepancy between the submittal and what is in 7
here.
I don't know which one without having the cales.
8 MR. BARLEY:
Julien has the calos.
They went back 9
and looked at it and 36 is the right figure.
10 MR. ABRAMOVICI The only thing the calo gives you l
11 is that at 48 percent flow the diso opening is 34 degrees.
l I don't have it here, but I think full 12 Okay. And I think 13 open is like the disc swings 72 or 73 degrees, something like 14 that.
15 So, if you take whatever ratio, 34/72, I hope that 16 gives us the 36 or thereabout.
17 MR. PAGE:
It is actually more than 36 but it is 18 still a smaller part stroke than originally thought.
19 MR. ABRAMOVICI-Yes.
20 MR. COLITZ:
We never really got into disassembly on 21 this. We did take one apart 22 MR. CHERNY:
You are appealing on the basis, as I 23 understand it anyway, on the basis of making plant 24 modification to do full flow testing.
Ordinarily in this 25 situation we enclose disassembly on some periodic previously,
101 1
rather than plant monitor to do full flow.
I'm finding the 2
history of this thing a little bumpy at the moment.
3 I'm trying to find out if we ever sent you any 4
kind of position on disassembly in writing.
I don't think we 5
did.
6 MR. COLITZ:
Where do we stand on this, Joel?
7 MR. PAGE:
We can leave it stand the way it is now.
8 Your latest submittal discuased plant modifications that would 9
be necessary for full flow.
10 I think what we are going to discuss is probably the 11 potential for disassembling the other valve at some interval, i
12 Then, based on the results of that,<plus the one that you have k
13 already done, which I assume is in very good condition, we can 14 try to establish some reasonable intervals, depending on what 15 the condition of the valve is.
16 MR. COLITZ:
We have already looked at one, and this 17 falls into, I guess, a lot of other ones we discussed with you 1
18 and submitted to you in our valve disassembly report.
19 That valve seemed to be in excellent condition.
20 MR.. PAGE:
This one was in the report, the MS-V9 21 MR. COLITZ:
I don't know if it was or wasn't 22 offhard.
J 23 MR. PAGE:
I don't think so.
I would have discussed 24 it in here.
25 MR. THOMPSON:
It was submitted in late
'84.
I
102 1
MR. COLITZ:
I think we did it afterwards.
But we e
2 could commit to inspecting these on the same frequency we did 3
the others, one every ten years.
If we find one bad, we go 4
into the other one.
5 MR. PAGE:
I was thinking we would be looking for 6
some results on the other valves sooner than ten years.
And 7
then, maybe based on both results, looking at something along
~
8 like that.
9 MR. COLIT2:
If we looked at the other valve as far 10 as startup from the next refueling cycle, and we found that in 11 excellent condition, wou1*d that justify the ten-year interval 12 then?
13 MR. PAGE:
I think it would. Ten years is an awfully 14 long time, as you probably know.
But, I would say it would be 15 somewhere betweer. five and ten years would be my guess on an 16 alternating basis; one each five, or something like that.
17 MR. THOMPSON:
Joe, as I understand it, I am hearing possible proposal to disassemble the other 18 a proposal 19 valve.
20 MR. COLITZ:
We could disassemble MS-V9A prior to 21 coming out of the next refueling outage.
22 MR. THOMPSON:
And then providing that has got a i
23 ten-year interval, alternating valves.
i 24 MR. COLITZ:
Yes.
25 MR THOMPSON:
Disassembly; if one is bad
~
103 1
disassembly of the second if the one looked at is bad.
j 1
2 MR. COLITZ:
That's the logic I think we used on all 3
of this.
4 MR. PAGE:
Can you supply me the disassembly 5
information on the B valve?
6 MR. BASHISTA:
It is not in the disassembly report 7
because we did it after disassembly.
But we can get you the 8
information.
It was found in excellent shape.
9 MR. PAGE:
I like the way you laid out that previous 10 report. That was pretty good.
That had some pretty decent 11 pictures in there, too.
12 MR. McGOEY:
So we are leaving this with two 13 actions items.
We have, one, to provide you with the 14 disassembly report, and you have an action to respond to our 15 proposal which we are going to probably discuss tomorrow.
16 MR. THOMPSON:
Good.
17 MR. McOOEY:
So, we can go on.
18 MR. ROCKHOLD:
Question Q.4 will be the next item.
19 Is everyone ready for that one.
20 Q.4 is, review the safety function of the following 21 valves to determine if they should be included in the IST 22 program and categorized as indicated.
23 AS-V4 we found to be satisfactory.
Needs no further 24 discussion.
25 MS-V8A and B,
your discussion states that these are
i l
1 104 1
normally open valves and not required to bring the plant to 2
hot shutdown after transient.
Do not have to change positions 3
during the transient.
4 I have a note here that says these valves should 5
have to close.
6 Let me take a look at the print and see what 7
exactly they are.
E MR. CONTE:
Are they turbine bypass 9
MR. SHIPMAN:
Yes.
i 10 MR. PAGE:
Why did you use the terminology hot 11 shutdown rather than cold shutdown?
12 MR. SHIPMAN:
I didn't hear the question.
13 MR. PAGE:
The statement for the MS-V8A and B valves 14 indicate not required to bring the plant to hot shutdown.
Why 15 did you use the term hot shutdown.
16 MR. SHIPMAN:
I'm not sure I understand the question 17 Joel.
18 The valve MS-V8 is normally open, but as the turbine 19 bypass valve is motor operated, one valve isolates three term 20 bypass valves.
When we come to hot shutdown, the turbine 21 bypass valves do function.
But does not involve a 22 manipulation of MS-V8.
23 MR. PAGE:
Someone could misinterpret that statement i
24 that he never needed any equipment except equipment to get to
\\s 25 hot shutdown.
-1 0 5 1
MR. SMYTH:
That's our licensing basis.
i i
2 MR. PAGE:
It is still your licensing basis. And if 3
the equipment says cold shutdown, it doesn't matter.
4 MR. CONTE:
They don't need these valves for cold 5
shutdown.
6 MR. PAGE:
I was wondering why they said it. This l
7 tends to indicate they aimed only at obtaining hot shutdown I
8 cond,itions.
9 MR. CONTE:
They could use the atmospheric dumps to 10 get to cold shutdown.
1 11 MR. BARLEY:
The answer to your question Joel is 12 that they do not need to close to get to cold shutdown.
13 MR. PAGE:
Either.
14 MR. BARLEY:
Either hot o,r cold.
15 MR. SANFORD:
I think the reason the response was 16 worded that way was, in just looking at your question, it 17 occurred to us that the most likely time to need them would be 18 getting to hot shutdown, not getting on down.
So, we only 19 addressed the first half of that.
20 MR. PAGE:
I'll try not to read more into it than is 21 there now.
22 MR. ROCKHOLD::
Still concerning the MS-V8s, do i
23 these valves get any engineered safety feature signals?
24 MR. COLITZ:
No.
None whatsoever, i
25 MR. ROCKHOLD::
None at all.
They are normally i
106 1
open?
2 The problem that I have with them is those 3
particular valves are in a line, that you want to have steam 4
available to the emergency feed pump turbine.
But at the 5
same time that line downstream is non-seismic.
6 Given an accident scenario, you assume the 7
non-seismic section of the piping just goes away and that 8
valve has to isolate to prevent dumping at least one steam 9
generator, if not two steam generators, and that you take 10 credit for having steam available for your emergency feed pump 11 turbine.
12 MR. SHIPMAN:
Emergency feed pump turbine, I don't t
13 believe is tied by that line.
The 8s isolate the bypass 14 valves, coming down to the bypass valves.
They do not affect 15 EFP-1.
16 MR. CONTE:
His point is if the 8s failed open they 17 would divert steam away from the turbine driven pumps.
18 MR. SHIPMAN:
The 3s would have to fail, too.
19 MR. CONTE:
The 3s are the bypass valves.
20 MR. SANFORD:
I think the one factor there, the 21 turbine on the emergency feedwater pump isn't outside.
So 22 your premise of a seismic issue 23 MR. SMYTH:
For seismic events we take credit for s
24 our two motor driven emergency feedwater pumps.
We address j
25 that in response to the UCS 2.206 petition.
107 l
1 MR. CONTE:
I think that is a correct statement, but 1
i 2
I think it might be good for you to mention what is the 3
licensing basis for the steam-driven emergency feedwater 4
ump.
Is it used to mitigate any accidents right now, or 5
relied on to mitigate any sooidents?
6 MR. SHIPMAN:
We used to manually load the t' ink the licensing basis, 7
motor-driven on the diesel.
But I h
8 as far as I understand it, is loss of offsite power.
You have 9
EFP-1, steam driven emergency feed pump.
10 MR. CONTE:
That pump seems to be a gray area with 11 respect to its safety function.
12 MR. SMYTH:
The aooident analyses don't take credit
{
13 for one particular pump versus another.
They take credit for 14 emergency feedwater and they acknowledge, you know, single 15 failure criterion which can be met, with the exception of the i
J 16 seismic event, with just your two motor driven emergency 17 feedwater pumps.
18 The only event that we specifically do not take 19 credit for the steam driven pump is to a seismic event.
20 MR. RANSOM:
In other words you can't have a loss of 21 offsite power in conjunction with a seismic event?
22 MR. ROCXHOLD: :
That's the most likely time to have 23 it.
24 MR. SMYTH:
No, that's not true either, We can 25 sustain a loss of offsite power and a seismic event.
108 j
l 1
What we can't sustain is there might be a feedline 2
break, for example.
3 MR. SANFORD:
I guess that is under some question.
4 MR. CONTE:
For blowing down the steam generator, 5
you have got the tubes that you can rely on.
The tubes are in i
6 the program.
7 MR. PAGE:
There's one, one valve.
8 MR. CONTE:
One for each generator.
i 9
MR. PAGE:
You can't take credit for these, t
to MR. CONTE:
To push the problem maybe I would 11 suggest us taking an action item, to consult with our system 12 people on the FW and ask them for a disposition on the safety l
13 function of the EFW.
14 MR. ROCKHOLD; At this point, we'll leave this as an 15 open item for the NRC to discuss any safety significance of 16 the MS-V8A and B valves.
And also on this particular question 17 concerning valves, MS-V6, does this valve have a required 18 fail-safe position?
19 MR. PAGE:
I think it does.
20 MR. BASHISTA:
Yes, open.
21 MR. BARLEY:
It fails 65 percent open.
i 22 MR. ROCKHOLD:
Okay.
We see this as one of those 23 system control valves that has a required fail-safe position.
24 Therefore, it is not erempt from the IST program for 25 IW-V1200.
It does need to be included in the IST program and l
4 n-
.~
l t
109 1
tested for code requirements.
2 MR. CONTE:
Isn't this contingent on the issue as to 3
whether there's a licensing basis for the EFW P-1 pump.
4 MR. PAGE:
It will probably all key on that, too.
5 MR. CONTE:
1 think it's related to the MS-V8 issue.
l 6
MR. ROCKHOLD:
They currently have quite a few e
i 7
valves associated with the FP-1 in there.
8 Does the utility have any response to my statement I
j 9
about MS-V69 10 MR. BARLEY:
I guess where we are is that that 11 interpretation is an interpretation we just got today.
I 12 think we're going to have to look at how we would satisfy the f,..,)
13 code testing requirements on that.
It's not immediately 14 apparent to us how we would do that test.
We have to look at 15 it.
16 MR. McGOEY:
Don't we also have to understand 17 better the licensing basis?
18 MR. BARLEY:
Yes, that's true.
=
19 MR. McOOEY:
! think also we need to better I
a 20 understand the licensing basis for EFP-1, comparing with what 21 Rick says.
l 22 MR. ROCKHOLD:
We understand that if during the 23 NRC's evaluation and further discussions of the FP-1, if it is 24 determined it's a safety-related pump or a non-safety-related i
(
I i
a lot of these valves will 25 pump, there's a lot of things l
110 1
just go away.
We would not be interested in seeing them in 2
the IST program.
3 And then again on this same question, MS-V22A and B,
4 you state that these valves prevent overpressurization of the 5
piping, and since the upstream pressure regulation valve 6 6
will self-regulate the downstream pressure at less than 175 7
pounds, 6 is adequate to protect this system.
8 But in our discussions, the 6 doesn't perform the I guess these are 9
safety function.
Whether it does or not 10 all tied together.
or at the moment, we see the MS-V22A 11 We also see 12 and B should, in fact, be included in the IST program and test k
13 the Category C relief valves for Section 11 14 MR. McGOEY:
As long as the inclusion of 6 holds 15 true.
16 MR. ROCKHOLD:
Right.
We're going under the 17 assumption that both EFP-1 is a safety-related pump.
18 MR. McOOEY:
Let's go to the next item.
19 MR. ROCKHOLD:
The next item, Section R, makeup and 20 purification system, letdown portion.
What is the safety 21 function of valves MU-V1A and Bt 22 We are in agreement with your response; however, 23 this is another one of those where we would prefer to see the 24 valve identified in the program as non-safety-related or using j
25 some kind of symbol, asterisk, abbreviation or whatever.
111 0~[g 1
MR. BARLEY:
We're agreeable to that.
..]
2 MR. ROCKHOLD:
Okay.
Question R-2, 3
MR. THOMPSON:
Let me give the reference on that.
4 That was page 23 of 37.
5 MR. ROCKHOLD:
Yes, page 23 of 37.
6 MR. THOMPSON:
Of the July 10,
'84.
7 MR. ROCKHOLD:
Question R-2, we discussed makeup 8
valves MU-V2A and B and 3, and your response is satisfactory.
i 9
In particular, the last sentence of your response where it 10 says thermai oyole considerations on the letdown coolers do l
11 not allow full closure of these valves during normal plant 12 operation.
That is the sentence we're interested in most.
13 That's what we will tend to evaluate in the SER, and that was 14 missing in the original discussion.
15 Question R-3, does partial-s_troke exercising MU-V3, 16 which normally full-strokes in less than one second, prevent a
17 any operational complications due to isolation of letdown 18 flow?
Is this another valve where you are required to put a 19 mechanical block on the valve stem?
20 MR. BARLEY:
This is the same issue that relates to r
21 the engineered safeguards system testing.
l l
22 MR. ROCKHOLD:
Okay.
Now we say attempting to 23 partial-stroke a valve that normally full-strokes in one 24 second being somewhat operationally complicated, especially if 25 the valve went all the way closed and caused other problems.
1
112 1
Question R-4, provide a detailed technical 2
justification for not full-stroke exercising valves MU-V25 and 3
26 quarterly during power operation.
The valves are in the 1
4 reactor coolant pump seal return line and are part-stroked 4
5 each quarter.
Isolation of the seal return line at power 6
risks permanent damage to the pump seals.
7 Okay, we agree with that.
But can the valves be i
8 full-stroked to cold shutdown?
9 MR. BARLEY:
I think the answer is, yes, they could 10 he full-stroked to cold shutdown.
11 MR. BASHISTA:
The submittal says we full-stroke I
12 them at cold shutdown.
( ~s
)
~'#
13 MR. RANSOM:
I think our question is the same as the 14 above.
The quarterly stroke, are they blocking it?
That's 15 what I have.
P-2 is the one where we discuss the ESAS 16 quarterly testing which resulted in the partial-stroke l
17 exercising of those valves.
That's why you had to have the 18 blocks.
l 19 MR. ROCKHOLD:
Okay.
Now it appears your written 20 response to Question E-4 is satisfactory for our need.
21 On Question R-5, what is the safety function of 22 MU-V51, again your written response is satisfactory.
23 Question R-6, review the safety function of the l
[
24 following valves to determine if they should be included in l
25 the IST program:
MU-V11A and B; provide isolation capability
I
~
113 1
for maintenance on filters.
There is no safety function 2
associated with these valves.
3 It appears to us t k.a t if 51 is safety-related, as 4
stated in Question R-5, then these its would also be 5
safety-related.
I'll get the drawing out and see what it 6
shows.
7 MR. BARLEY:
If it helps, one of the 11 valves is 8
normally open during operation.
That's all you need for that n
9 flowpath.
10 MR. SANFORD:
Either one of the 11 valves is open, 11 or the bypass is open, but something is open in the path to l
12 the makeup tank.
t l
13 MR. ROCKHOLD:
Neither of the its get any safety 14 feature signals?
15 MR. BARLEY:
No, sir.
16 MR. ROCKHOLD:
The reason we question MU-V47 was 17 that's a check valve in the direct flowpath for the boration 18 flowpath.
Does the valve perform any safety function in the 19 open position?
20 MR. SHIPMAN:
That's a manual valve.
It's normally 21 in the open position.
It's a stop check, isn't it?
A stop 22 backed all the way out to open?
23 MR. ROCKHOLD:
Therefore it acts as a check valve.
24 MR, SHIPMAN:
Yes.
r 25 MR. ROCKHOLD:
Tends to act as a simple check.
l
114 1'
MR. SHIPMAN:
Yes.
2 MR. BARLEY:
That valve is normally open and 3
constantly passing flow to the makeup tank during normal 4
operation and is also tested along with the horio acid pumps, 5
the emergency boric acid injection mode at a refueling 6
interval frequency.
7 MR. ROCKHOLD:
I guess the way we see it is, it is a 8
check valve in a required flowpath and the check valve is 9
required to open, we would see it as needing to be in the IST 10 program to verify its open capability per the code 11 requirements.
12 MR. BARLEY:
I guess we're agreeable to adding that 13 one to the program and adding a sign-off to the procedure for 14 it.
That's on a refueling interval 15 MR. ROCKHOLD:
Aren't you verifying its opening 16 MR. BARLEY:
We could sign off every quarter, too.
17 We can sign it off quarterly and refueling.
18 MR. ROCKHOLD:
Is it time for a break?
19 MR. THOMPSON:
Let me make some comments.
20 MR. COLITZ:
That one was left that we would add it 21 to the IST program?
22 MR. ROCKHOLD:
Right, 51.
MU-V47 to be added to the 1
23 program.
24 MR. THOMPSON:
Before we break here, maybe we could 25 just talk about scheduling, so that various parties can plan
115 1
things.
It's now 2:00 o' clock.
We have about five hours into 2
this effort so far, and my guess is, it looks like we're about 3
halfway through, which leaves us another five hours, which 4
would give us, if we work until 5:00 tonight, three hours left S
today and a couple of hours in the morning to put us through 6
the run-through around 9:30, 10:00 o' clock tomorrow.
7 Then we would have perhaps a couple of hours for you 8
and for us to pull together what we need to do, get together 9
in the afternoon and come to resolution on what is not yet 10 resolved.
11 Does that sound like a workable program, at least 12 tentatively, so we can tell management and other people that 13 might be involved what to expect?
That's going to impact 14 having Wilson here, because he's available from 8:30 until 15 about 11:00.
4 16 MR. McOOEY:
8:30 to 10:00, that's it 17 MR. COLITZ:
Let's go to 5:00 and get started maybe 18 7:30 again tomorrow.
I don't know how many really hard ones i
19 there are here.
We may be able to, like you say, finish at 20 9:00, 9:30 tomorrow.
21 MR. THOMPSON:
The problem is, Joel needs to get 22 together with his management.
23 MR. PAGE:
I think I've figured that out.
What I'm 24 going to do is, I'll probably leave at 4:30 today and meet 25 with Frank.
Anything you somehow t'e e l you need me for, just
116 1
kind of waylay it until the morning, and we'll try to resolve 2
it at that point.
Just go through whatever you can.
Then i
3 I'll try to discuss with him some of these basic conceptual 4
issues, which I think he'll need to convey to George Lear and 5
try to get him on board.
6 We have some that are kind of general and conceptual 7
in nature that it's important to think about overnight.
So it I
8 will work out, I think.
We'll pick up at 7:30.
9 MR. THOMPSON:
We would then shoot for about 9:00 1
10 o' clock tomorrow morning to have issues that Dick Wilson needs 11 to be involved in, to discuss?
Is that what we're shooting i
12 for, then?
13 MR. COLITZ:
As far as a break for a ocuple of 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />. I'm not sure we're going to need a couple of hours.
15
'Some of these, like on the diesels, where we need to go back 16 and really look, we need to go back to the plant really and 17 get into some of it.
So I'm not sure i
18 MR. PAGE:
There are some others, though, that I 19 think ycu would be able to think about during that period.
20 That dne is longer-term, I think.
21 MR. THOMPSON:
That may not be such a hard one to j
22 resolve, once the understanding of the system is clear.
l 23 think some of these others where they've been around, we've 24 already been through them.
We've been through backfit appeal,
)
25 now technical appeal.
I think those are the ones that we want
)
~. -.
117 1
to bring out for Yilson.
2 So if we can get those together by 9:00 o' clock, 3
let's shoot for it.
4 Okay.
Let's take a little break.
5
[Brief recess.3 6
Let me go back to question R.5, MU-V51 is to be 7
included in the program and on R.6, MU-V11A and B are 8
not? MU-V47 will be included?
9 MR. BARLEY:
51 is included at present in the 10 program.
11 MR. THOMPSON:
Oh, it is. All right.
.s 12 It is and will stay so.
The R.5 response is 13 acceptable.
14 MR. BARLEY:
Yes.
15 MR. THOMPSON:
R.6 response is revised to include 16 MU-V477 17 MR. BARLEY:
Yes.
18 MR. ROCKHOLD:
Okay.
Moving to Question S.1, 19 under the Make-up and Puriftoation System - Make-up Portion.
20 Provide a more detailed technical justiftoation for not 21 full-stroke exercising valves MU-V14A and B open quarterly and 22 during cold shutdown.
23 And I have a note to myself, besides your written n
24 response, saying we need more detail for the quarterly and 25 cold shutdown relief.
Valves in question are the make-up pump
118 ja 1
suction from the borated water storage tank isolation valves.
2 MR. BASHISTA:
Can we start by saying that these are l
3 stop check valves.
The stop function is stroke timed each 4
quarter.
The category C portion, check valve test, is a 5
refueling test where we inject borio acid from the BWST to the 6
reactor vessel.
7 MR. ROCKHOLD:
Listening to you, and trying to 8
digest what I just read, and in light of this I think we have 9
sufficient justification.
Okay.
10 MR. THOMPSON:
The response to S.1 is acceptable?
11 MR. ROCKHO,s Right.
12 When we went over your responses here we did not 13 have reference 4 at our disposal.
We just got it today.
So, 14 I'm kind of blending things together.
15 Question S.2, we found that your written response 16 acceptable.
17 Question S.3.
Provide a more detailed technical 18 justification for not full-stroke exercising valves MU-V73A, 19 B,
and C quarterly during power operation and cold shutdown.
20 We don't disagree with what you are doing.
I think 21 we just don't have suffiotent technical justification written 22 down on your part.
23 MR. SHIPMAN:
The issue on the full stroking would el 24 he the same as that of the check valve 14, where we checked on
.,'s
/
25 a refueling interval, system design flow.
1
119 1
MR. ROCKHOLD:
What we usually see here is during 2
power operation the pumps are physically incapable of 3
providing the design accident flow rate at rate of reactor 4
coolant system pressure.
5 In addition, you don't have anyplace to put the 6
water, even if you could put it in there with the pumps since 7
you don't have letdown capability to make up the excess.
8 During cold shutdown conditions when reactor coolant 9
system pressure is low enough where the pumps could develop 10 the flow necessary to demonstrate full stroke capability of 11 these check valves, if you attempted at do that the resulting 12 influx of water into the reactor coolant system would result i
1 13 in low temperature overpressurization again because you don't 14 have letdown capability for the flow required to str'oke the 15 check valve.
16 MR. BARLEY:
That is also true.
Also the arguments l
17 that we have seen in the past from other utilities have been 18 real strong arguments for not performing full stroke testing 19 of these valves during power operation and shutdown.
20 MR. THOMPSON:
Does the Licensee then affirm that 1
21 those are valid for TM!-1?
22 MR. BARLEY:
Yes.
23 MR. SANFORD:
Yes.
k 24 MR. ABRAMOV!CI Go S.3 is acceptable?
qj 25 MR. THOMPSON:
Yes.
I h
i 120 i
1 MR. PAGE:
That was my oversight, in that I did not
~:
2 include those two details in my writeup here.
I just wanted 3
it to be complete here as to why if somebody comes along and 4
says, great, why, you know.
S MR. ROCKHOLD:
Ready for Question S.4.
l 6
Provide a more detailed technical justification for 7
not full stroke exercising the following valves quarterly 8
during power operation and cold shutdown.
Do any of these 9
valves perform a containment isolation or pressure boundary 10 isolation function?
11 Okay.
Just to understand what we are talking about 1
12 1
13 MR. PAGE:
These are on leak testing the valves, 14 right?
15 MR. COLITZ:
Two here. Full stroke on a quarterly 16 basis.
And then P!V function was the other side of the issue.
17 MR. ROCKHOLD:
Okay.
The 107s are the HP!
18 injection checks for the four loops.
The second valve out 19 from the reactor coolant system.
20 The 86s are the first valve for loop B.
21 94s and 95 are same loop.
First check valve out.
22 And 2201s another injection check for the normal 23 makeup line.
24 For the containment isolation function, none of the 25 valves perform a containment isolation function, or at least i
121 1
are not leak-rate tested for Appendix J.
That is a true 2
statement.
3 MR. BASHISTA:
That is correet.
4 M F., ROCKHOLD:
For pressure boundary isolation 5
function you are saying these valves are not required to be 6
tested as pressure boundary isolation valves right now.
But 7
they are identified in an appeal.
8 Okay, so there is no sense in us discussing that 9
particular issue either.
10 The point in question here then is primarily the 11 full stroke exercising of these check valves during power 12 operation and cold shutdowns.
13 MR. BARLEY:
Again the same arguments that applied 14 to the ME-V73 pump discharge check valves would apply here for 15 these valves as well if MR. PAGE:
You indicated relief was previonaly 17 granted.
I think that is true for all except the 220.
I 18 can't seem to find the 220 in reference 4.
i 19 MR. BASHISTA:
220 is a new valve.
It has been 20 added with the HP! oross connector.
21 MR. ROCKHOLD:
We agree with the testing that you 22 are currently performing.
It is just the details of why you 23 can't do the test quarterly in cold shutdown is not provided 24 in any of the paper that I have.
If it was included in the 25 relief request discussion, it would be much better for us.
122 1
Or, I guess if the same conditions apply, we can evaluate that 2
in the SER.
3 MR. THOMPSCH:
So what do you need to have on that, 4
Herb?
5 MR. ROCKHOLD:
Just maybe them making the statement 6
that these are in the 2me category as questions in S.3.
7 MR. PAGE:
There should be a relief request 8
indicating these details, that you can'-t full strcke at power i
9 because you can't overcome reactor coolant system pressure for 10 full flow and 11 MR. ABRAMOVICI:
You already have them in S.3.
12 MR. PAGE:
Is it in the relief question?
(.
13 MR. ABRAMOVICI:
No, no.
You already have it in 14 S.3.
15 MR. PAGE:
I'm saying it is important though, in 16 your own program, to be complete there should be a relief 17 request that states those itens in there.
18 MR. ROCKHOLD:
Okay.
Are we ready for S.5 then?
19 Question S.S.
What is the safety function of valves 20 MU-V116 and 2197 Does valve MU-V219 perform a containment 21 isolation function?
22 Okay.
You response is the safety function of both 23 valves is to perform a containment isolation.
24 Then I further asked how is it exercised?
Or, how 25 are they exercised closed quarterly?
123 1
MR. BASHISTA:
Makeup 116 is not exercised closed 2
each quarter.
It is exercised open each quarter.
On a 3
fueling interval they test, verify the valve will close and is 4
olosed.
5 MR. ROCKHOLD:
The way we interpret the valve 6
table is that 116 is being full stroke exercised shut 7
quarterly.
8 MR. BASHISTA:
The L symbol applies to R for 9
refueling.
And F applies to Q symbol, which is quarterly, 10 which is a'n open test.
11 MR. ROCKHOLD:
The F symbol I thought was 12 interpreted to be, you functionally stroke the valve to its 7,
I 13 safety position.
And in this case it would be closed.
14 Symbol F stands for fu'11 stroke functional check of 15 valve operation.
16 MR. BASHISTA:
Which could be either open or closed.
17 MR. ROCKHOLD:
Yes.
We interpret the safety i
18 function of that valve is closed and not open.
l 19 MR. BASHISTA:
The safety function is checked at 20 each refueling outage.
Then we day test.
I 21 MR. ROCKHOLD:
I guess what we are saying is we j
i 22 are going to need a relief request saying that the valve j
j 23 cannot be exercised closed quarterly or closed shutdowns.
l
'(,)
24 Will be leak tested during refueling outages to verify its 25 olose capability.
124 h
1 219 is going to fall in the same category no.
s.
2 Okay, for 219 you state that its safety function is 3
to perform containment isolation.
However,it is exempt from 4
Appendix J testing requirements.
You are not currently 5
required to Appendix J 1eak rate test this particular valve.
6 Correct?
7 MR. BASHISTA:
That's right.
8 MR. ROCKHOLD:
And the only safety function that it 9
performs is containment isolation.
There is no injection flow 10 path to take credit through that valve.
So at this point we 11 are not going to require any changes in MU-V219.
12 Are we ready to go on to Question S.6 then.
13 What is the safety function of MU-V217?
14 You have indicated the valve has no essential safety 15 function.
16 If it is going to be in the program we would like 17 to see it identified as non-safety related, however you elect 18 to do that.
l 19 MR. BASHISTA:
We can do that.
O 20 MR. ROCKHOLD:
Question S.7.
21 Review the safety. function of valve MU-V112 to 22 determine if it should be included in the IST program.
We l
(
23 agree with your written response.
Valve will not be included l
l 24 in the IST program.
25 Ouestion T.1.
~
125 1
Is there another containment isolation valve 2
associated with NI-V27 on the nitrogen line at penetration 3
307?
4 The response is yes, NI-V26 manual lock closed 5
isolation valves located outside of reactor building.
o 6
Is NI-V26 going to be included in the isolation 7
program as a category A passive valve?
8 MR. BARLEY:
I think we can answer that question if 9
we look at the tech specs and the requirements of the Appendix 10 J 1eak testing on that valve penetration.
11 MR. ROCKHOLD:
You don't have that presently 12 available, today, at this meeting?
13 MR. BARLEY:
I don't think we do at the moment.
14 You may have a copy of tech specs, so we can look at them.
15 MR. THOMPSON:
We can check that after the meeting 16 today Rick, if you want to.
17 MR. McGOEY:
We will bring it in at a break.
18 MR. BARLEY:
Or, we could call back to the plant and 19 get an answer as to whether we test the 26, or whether that 20 would require some flange and we test the flange.
21 MR. ROCKHOLD:
The way we would see it is if the 22 valve is currently leak rate tested for Appendix J we would 23 expect to see it identified in the IST program.
4 24 If it is not identified in your Appendix J testing 1
25 program, we would not expect to see it in your IST program.
)
i
~
126 1
Are we ready for River Water System.
Question U.1.
2 What is the safety function of valves NR-V4A and B?
3 Your written response is satisfactory for our needs.
4 Question U.2.
5 Review the safety function of the following valves 6
to determine if they should be included in the IST program and 7
categorized as indicated.
8 We agree with everything you have written, with the 9
exception of NR-V18.
Let me get the drawing out and figure 10 out more of what I'm talking about.
11 What kind of' valve is 18?
Is it just a simple 12 motor-operated
(
13 MR. SHIPMAN:
It's a jog-controlled valve, 14 motor-operated jog.
It means you have a button that you can 15 mid-position it.
You can position it wherever you want.
16 MR. ROCKHOLD:
Motor-operated valve with throttling 17 capability.
18 MR. SHIPMAN:
Yes.
19 MR. ROCXHOLD:
The function of the valve is just for 20 an operator to monitor pressure in the system and to establish 21 a desired backpressure to the pumps?
22 MR. SHIPMAN:
Yes.
23 MR. ROCXHOLD:
It has no automatic f unc t i onis l
24 whatsoever?
j 25 MR. SHIPMAN:
No.
127 1
MR. ROCKHOLD:
It would fail as is?
2 MR. SHIPMAN:
Yes.
3 MR. ROCKHOLD:
Thw part that bothered me is, the 4
valve is in the direct flow path for the nuclear service water 5
system and if the valve were in the closed position you 6
essentially would not have any nuclear service water, correct?
7 MR. BASHISTA:
If the valve was closed then we would 8
have 19 open.
We would be diverting water elsewhere.
We 9
always have an open flow path with either 18 or 19.
10 MR. ROCKHOLD:
But the valves are not operated by 11 the same switch or controlled together other than the operator 12 knowing that if he opens one he has got to close the other, 13 and vice versa?
14 MR. BASHISTA:
Correct.
15 MR. SHIPMAN:
Normally that 19 valve, which is, I
16 believe, a de-ice valve, that is a normally closed valve.
17 Anyway we don't normally have flow in that line unless we want 18 to remove the ice in the river in front of the screen house.
19 Just because I move 18 does not necessarily mean I 20 will move the 19.
21 MR. ROCKHOLD:
The problem I have is I see one valve 22 that can be out of position to defeat the entire system and it 23 is a normally operated valve.
Or, it appears to me that it is 24 a valve that is fairly frequently manipulated.
25 And if the valve were inadvertently closed it
128 1
couldn't fail closed, but if it were closed you oculd defeat 2
the entire nuclear service. water system.
3 MR. SHIPMAN:
Once the back pressure is established 4
there would be no need to move 18 at all, except during the 5
winter when we move 19.
6 MR. ROCKHOLD:
With discussions at this end of the 7
table, it is our opinion that NR-V19 is a convenience valve.
8 It's a nice valve to have.
We would not expect to see it in 9
the IST program.
However, 18, we feel, is a valve that 10 performs an important function and should be included in the 11 IST program and periodically exercised to demonstrate its 12 operability.
h'T 13 MR. BASHISTA:
Isn't NR-V18 just a passive valve; 14 once it is open, it stays open?
15 MR. PAGE:
Once it is open.
What if you 16 inadvertently close it like they did at Davis-Besse and then 17 couldn't get it open?
18 MR. BASHISTA:
You are assuming that we close it.
did 19 MR. PAGE:
What if for some reason 20 something.
That's one way for it to fail.
That's one way for 21 it to fail. That is one that is recent on everybody's mind.
I 22 don't want to name that as the only possibility.
23 MR. ROCKHOLD:
A failure mechanism for that would be 24 since it is a jog-type pump, that you do periodically change 25 the position of the valve, if the contacts stick, you go to
l 129 1
close and it goes all the way closed.
2 MR. BASHISTA:
What type test are you looking at on 3
a quarterly basis?
4 MR. ROCKHOLD:
We treat it the same as any other 5
active valve.
You can at full stroke and stroke time the 6
valve quarterly, which you may have an argument for.
7 MR. SHIPMAN:
Herb, those pumps are in operation 8
essentially 100 percent of the time.
We don't shut that 9
system down even when we are in cold shutdown.
To stroke 10 NR-V18 presents two problems.
One, you want to keep that 11 flow.
If you stroke it open, you are going to violate the 12 pump head.
You are going to have problems with the pump.
And
,s i
13 if you close it and open 19, you are going to have problems 14 with other regulations with the state environmental protection 15 agency concerning delta T and the river because that opening l,
16 19 bypasses the mechanical drive cooling towers and puts l
l 17 heated discharge directly into the river.
I 18 MR. PAGE:
Just for the length of time that you are 19 doing the test.
O 20 MR. BARLEY:
Long enough to have a violation.
21 MR. PAGE:
That would do it?
22 MR. BARLEY:
Yes.
The transient of switching over, 23 if not extremely carefully controlled, then you have got to 24 control it under four seasons of the year.
It could-involve 25
-- we are talking about a 3 degree rise?
I
130 1
MR. SHIPMAN:
The delta T limits are higher than i
2 that.
There is another stipulation on our PDS permit which 3
says your heated waste can affect your inlet temperature 4
measurement.
We have modified our inlet temperature detector 5
and put it out into the river, but as it turns out, we can 6
still affect it by de-icing. We have got an agreement with the 7
state that will limit that effect to 3 degrees, and it is 8
admi'nistratively written in our procedures, so that if you are 9
de-icing, your inlet temperature can't go any higher than 35 10 degrees.
4 11 MR. BARLEY:
The other problem that the test poses 12 is it puts you in the scenario that we discussed the failure
,~
13 mode. In order to stroke it, you have to fully close the 18 14 valve, which puts it in the position where it could stay 15 there.
16 MR. PAGE:
It is not going to be an easy one, is 17 it?
Do you have mechanical control of the valve, meaning hand 18 wheel or anything that the person could at the valve 19 manipulate it?
O 20 MR. SHIPMAN:
[ Nodding affirmatively.]
21 MR. PAGE:
Wouldn't that enable you to do a test, 22 maybe less frequently than quarterly, without seriously 23 getting into any state regulations?
/..
M 24 MR. SHIPMAN:
The state regulations would be l
25 affected if the valve travels, if I travel or make it travel l
I
131 1
by hand or by motor.
I'm not sure what kind of testing you 2
have in mind.
3 MR. PAGE:
Wanted a stroke in stroke time?
4 MR. SHIPMAN:
You want to stroke it all the way 5
closed and stroke it all the way open.
I don't think the 6
system performance will allow you to do that.
You don't want 7
it to fully open or you lose the bac'kpressure requirement.
1 8
You run the pump out and vibrate.
9 MR. ROCKHOLD:
You commented earlier that o n c'e the 10 backpressure is set, then you don't mess with it any more.
l 11 Prior to that you also said you periodically change the 12 position of the valve. Can you give me a feel
(
i
~
13 MR. SHIPMAN:
In the wintertime when we are 14 de-icing, we will job open 19 in order to provide us some 15 water out to the intake screen house.
When we jog open 19, we 16 must jog closed 18.
17 MR. ROCKHOLD:
Is that the only times that you 18 operate 18?
Can you think of any other situation where you 19 would be operating 18?
=
20 MR. SHIPMAN:
Operationally I don't have any.
21 MR. BASHISTA:
There is a testing. We throttle 22 closed a little bit on 18 to get a reference value for the l
I 23 pump up testing. We don't go near closed. Close a little bit 24 to meet our reference values.
It sure doesn't defeat the 25 system.
~
132
.\\ '
1 MR. PAGE:
Let me expand this a little bit.
You are 2
talking about jogging this thing back and forth.for pump 3
backpressure.
How would this affect any aooident scenarios?
4 Doesn't the flow rate stuff on this nuclear service water 5
oculdn't that change during these aooident scenarios where you l
6 would need to jog this further?
7 MR. BASHISTA:
Further which way?
8 MR. PAGE:
I don't know.
9 MR. SHIPMAN:
! think, as we stated, we don't 10 believe we have got to change 18 for any accident.
11 MR. PAGE:
Say you have to jog it now for the 12 various reasons.
(
13 MR. BARLEY:
For de-ice and for testing.
14 MR. PAGE:
What testing?
15 MR. BARLEY:
Section 11 pump testing to return to 16 the reference.
17 MR. BARLEY:
One possibility, I guess, is we could 18 change our reference.
19 MR. ROCKHOLD:
Why don't we leave this particular 20 item open for us to digest tonight.
Maybe if you can think 21 about it a little more to come up with any more information 22 for us.
I think we can appreciate the problem, but at the same 23 time, we are having a hard time just throwing it out.
So let 24 us digest it for a while, think about it overnight.
We will 25 discuss it in the morning.
l i
o 133 l
.I, 1
Question V1 under Nuolear Service Closed Cycle 2
Cooling Water System.
Provide the specific technical 3
justification for not full-stroke exercising valve NS-V4, 15 4
and 35 during power operation.
5 We find your written response satisfactory.
6 Question V2.
How is valve NS-V11 full-stroke 7
exercised closed quarterly during power operation?
8 We find your written response satisfactory.
9 Question V3.
Are valves NS-V52A, B,
C, and 53A, B,
10 C leak tested to Appendix J requirements to demonstrate the 11 containment isolation function?
12 Your response is satisfactory.
(.s\\
13 Question V4.
Do any of the following valves have a
~
14 required fail-safe position: NS-V55A and B, and 48A and B.
15 We agree with your note in that 48A and B as we have 16 identified it should be valve numbers 108A and B.
We got some 17 more legible prints in the meantime and we agree 108 is the 18 valves that we were looking at.
But the basic question still 19 remains: do these four valves have a required fail-safe i
20 position?
Again emphasizing " required."
1 21 MR. BARLEY:
I guess again we are at the same point 22 here where we were not aware of your interpretation.
The 23 valves apparently fail open by design, and that is how we
-~,
j 24 would go about doing a test on that.
Whether the design s
1 25 mandates that they have to fall in that position to 1
(
i 134 1
successfully cope with an accident we would have to look at in 2
more detail.
3 MR. PAGE:
That is a longer-term item.
4 MR. BARLEY:
Yes.
I don't think we are going to 5
solve that one today or tomorrow.
6 MR. RANSOM:
On V1 and V2, you are going to include 7
those valves on the IST program, aren't you?
You say 8
MR. SHIPMAN:
Which valve?
9 MR. RANSOM:
The valves involved in questions V1 and 10 V2.
11 MR. COLITZ:
They are in the program.
12 MR. BARLEY:
Page 37 of 47 lists those valves as
(
13 being in the program.
14 MR. ROCKHOLD:
Are we ready for river water system, l
15 Question W1?
Review the safety function of Valves RR-V10A and 16 B,
and 12A and B to determine if they should be included in 17 We found your written response to be satisfactory.
18 Nuclear Services Closed Cycle Cooling Water System, 19 Question X1.
Review the safety function of the following 20 valves to determine if they should be categorized "A."
21 Your written response was satisfactory.
22 Question X2.
Provide more detailed technical 23 justification for not full-stroke exercising the following 24 valves quarterly during power operation and cold 25 shutdown: RR-V8 and 9.
135 1
We agree with your written response on Question X2 i
2 and some other paper.
3 Question X3.
Your written response was 4
satisfactory.
5 Question X4.
The written response for Question X4 6
was satisfactory for NS-V12; however, on RR-V6, again we make 7
the statement, does the valve have a required fail-safe 8
position?
9 MR. BASHISTA:
That is one we will have to go back 10 and look*at.
11 MR. ROCKHOLD:
- Okay, 12 Item Y1, What is the purpose of the system?
p.,
13 It was confusing with the typographical errors in 14 there, but we agree with your written response.
15 We are ready for Question Y2.
Is Valve RB-V7 motor 16 operated as indicated in the IST program, or pneumatic as i
17 indicated on the ISI boundary sketch?
18 The response is satisfactory.
O 19 Question Y3.
Provide the specific technical
~
20 juctification for not full-stroke exercising Valve < RB-V7 and I
21 2A quarterly during' power operation.
22 The written response is satisfactory.
23 Y4.
Review the safety function of Valve RB-V2 to l
.s j
xgj/
?4 determine if it should be included in the IST program.
25 The written response is satisfactory.
136 1
Reactor building spray system. Question Z1 Review i
2 the safety function of the following valves to determine if 3
they should be categorized as indicated: BS-V1A and B, 4
Category A; BS-V30A and B, Category A and C.
5 Licensee's written response is satisfactory.
6 Question 22.
How are valves BS-V30A and B 7
partial-stroke exercised quarterly?
8 In reference to full-stroke exercising these valves, 9
the NRC position is a sample disassembly program of inspection 10 is an acceptable means of full-stroke exercising check valves 11 and should be performed at each refueling outage.
Joel is 12 looking right now to see what the SSER says about these J
13 particular valves.
14 MR. PAGE:
You accepted the additional caveat that 15 was in the SER there.
16 MR. BASHISTA:
That if one valve was found l
17 defective, we would look at the other one?
18 MR. PAGE:
I don't mean defective in terms like seat 19 leakage, but in terms of full stroke, you know, loose parts, 20 things like that.
21 MR. BASHISTA:
We accept that.
22 MR. ROCKHOLD:
so the response to Question 21 is or Z2 is satisfactory.
23 satisfactory 24 Question Z-3, how are valves BS-V23A and B j
25 full-stroke exercised quarterly?
We find the utility's
137 l
1 written response satisfactory.
2 Question Z-4, in reference to valves BS-V52A and B,
3 the NRC's position is that a sample disassembly program of 4
inspection is an acceptable means of full-stroke exercising 5
6 We are reading this correctly in that every ten o
7 years you will take apart both valves, both 52A and B, each 8
ten years, and not one each ten years?
9 MR. BASHISTA:
[ Nodding affirmatively.3 10 MR. ROCKHOLD:
Okay.
So long as we're reading what 11 you wrote down correctly.
( -,
12 MR. BARLEY:
Page 11 of 13 in Tape B-2 of our 4
13 submittal says we will do each of these valves either at or 14 near the end of the ten-year interval.
15 MR. COLITZ:
Page 12 of 13, you say you will 16 continue to disassemble either of these static valves during i
17 each ten-year inspection interval, alternating between A and 18 B.
19 MR. ROCKHOLD:
Where are you reading this?
O 20 MR. COLITZ:
On page 12 of 13.
21 MR. BARLEY:
Now you're on the BS-V30s.
22 MR. COLITZ:
I'm sorry.
i 23 MR. BARLEY:
Page 11 of 13 addresses the BS-52s.
_j 24 MR. COLITZ:
What page is that under?
25 MR. ROCKHOLD:
11 of 13.
I
138 i
MR. COLITZ:
- Both, 2
MR. ROCKHOLD:
Okay.
Then on to Question 2-5, are 3
there any vacuum breakers that perform a safety function 4
installed on the sodium hydroxide tank?
5 Okay, we find your written response satisfactory.
6 MR. ABRAMOVICI:
For clarity, "BS-V123" should read 7
BS-V12B.
8 MR. RANSOM:
What was that again?
9 MR. ABRAMOVICI.
"BS-V12s' should read BS-V12B.
10 MR. ROCKHOLD:
Okay.
Ready for Question AA-1 on 11 reactor coolant syst'em, what is the safety function of valves 12 RC-V1 and 3?
(
13 We agree with the Licensee's written response; 14 however, we would like to see an NSR or some kind of 15 non-safety-related indicator next to those valves in the valve 16 table.
17 MR. BASHISTA:
Okay.
18 MR. ROCKHOLD:
Question AA-2, review the safety 19 functions of valves RC-V4 and 23 to determine if they should 20 be categorized A and A/C respectively.
These valves are not 21 currently identified as pressure boundary isolation valves in l
22 your technical specifications.
23 We see the potential there for PIV function.
We 24 have included those in our PIV list, I believe, PIV candidate 25 list.
139 1
And we also agree that these valves do not perform 2
containment isolation functions.
3 1s this a point where everyone wants to take a 4
break?
5
[Brief recess.]
6 MR. THOMPSON:
Back on the record.
7 MR. ROCKHOLD:
Question AA'-3, is RC-RV2 utilized for 8
low-temperature overpressurization protection of the RCS at 9
TMI-17 And your response is that it is utilized for 10 low-temperature overpressurization protection.
11 I'm sure you're all well aware of some of the 12 problems associated with testing of PORVs.
I have here a list 13 of general considerations, is what we call them.
It's a 14 section that will be included in the SSER that your receive.
15 Do you have any problems if I read this?
16 MR. THOMPSON:
No.
Do you want to read it into the 17 record, or do you want to give a copy 18 MR. ROCKHOLD:
I have about six copies.
I don't 19 have enough for everybody.
20 MR. THOMPSON:
I think if you give one to the*
21 Licensee, that's all they need, and we can run some copies 22 after the meeting.
23 MR. ROCKHOLD:
I have it marked as a draft.
Read it j
24 and see if there's any problem with it.
the NRC 25 Basically, it states that the Licensee
140 1
does not want you to test PORVs during power operation.
2 Typically, the situation for PORVs, where you are utilizing 3
them for low-temperature overpressurization protection is that 4
you test the valve prior to placing it in service when it is 5
- required, i.e.,
the approach to cold shutdown.
And it also 6
discusses the block valves, says the PORVs should be 7'
full-stroke exercised each cold shutdown, or as a minimum, 8
once each refueling outage.
Stroke timing should be performed 9
at each cold shutdown, or as a minimum, once each refueling 10 outage.
This is the PORV.
11 MR. THOMPSON:
Why don't you go ahead and describe this is going to be Staff's 12 13 MR. ROCKHOLD:
This is the Staff's position on 14 testing of PORVs and their associated block valves.
15 MR. THOMPSON:
Tentative Staff position.
This has 16 not been approved at the management level, so we can't say 17 it's the Staff's position, I don't think.
18 What it is, it's some ideas on testing on FORVs and 19 block valves that has not been blessed at the higher 20 management levels.
21 MR. ROCKHOLD:
Actually, these have actually gone 22 out to D.C.
Cook in an SER, so it may not be blessed for 23 TMI-1.
24 MR. THOMPSON:
This is an example that was sent out 25 to D.C.
Cook.
l
141 1
MR. ROCKHOLD:
It is in their SER.
2 MR. RANSOM:
Plus the same words have been in other 3
SERs, too, that have been issued by the NRC.
4 MR. ROCKHOLD:
Actually this talks about nine 5
different generic topics.
6 MR. BASHISTA:
Have you determined whether we can 7
have a copy of this or not?
8 MR. THOMPSON:
Okay.
What we are providing to you 9
to correct the previous statement is copies of part of an SER 10 that went out to D.C.
Cook.
11 MR. ROCKHOLD:
These nine general topics are just 12 that, general discussions of NRC positions that have in the 13 past had some misinterpretation, so the NRC has taken a 14 position on these nine general topios and has stated their 15 position in this " General Consideration" section.
16 Like I said, this is out of a D.C.
Cook SER.
You 17 can expect to see the same discussion in the SER that you 18 receive, to the best of my knowledge.
19 MR. RANSOM:
In most of the low-temperature 20 overpressurization SERs several years ago when they were 21 discussing that topic, one of the things that the NRC in 22 general required was, the PORVs, when used for low-temperature 23 overpressurization mitigation, have a requirement that they be i
. j 24 tested every time you shut down to make sure that they would
, s 25 operate to mitigate an overpressurization.
That's normally a l
142 1
requirement every shutdown, and it's included in most plant 2
technical specifications.
3 MR. ROCKHOLD:
The reason we brought this up is, 4
your PORV is identified in your IST program as a Category C 5
relief valve, and you're going to do the relief valve test on 6
it once every five years.
That is not what the NRC's position 7
is on PORVs.
That's the reason that I want you to read this.
8 MR. SHIPMAN:
The NRC would have us create a LOCA 9
each transition to cold shutdown?
10 MR. ROCKHOLD:
No.
You have a block valve, correct?
11 MR. SHIPMAN:
It doesn't full-stroke if the block 12 valve is closed.
It doesn't open if the block valve is k
13 closed.
14 MR. ROCKHOLD:
So your PORV is, in fact, a relief 15 valve?
16 MR. SHIPMAN:
It's a pilot-operated relief valve.
17 It takes system pressure to open it.
18 MR. ROCKHOLD:
So in light of that, then this 19 general discussion may not apply to you.
In most plants, it's it's an air-operated control valve.
So in 20 just simply j
21 light of that, maybe what you are currently doing is all that 22 can be done.
23 Joel, I'm glad you're back.
The discussion is on
(,'t' 24 the PORV.
I had them read the section in here on PORVs.
/
1 25 They say their PORV is a pilot-actuated relief valve; it's not l
143 i
~
1 an air-operated control valve.
The valve will not stroke with 9
2 the block valve closed.
4 3
MR. PAGE:
That's right.
You can have air pressure 4
during cold shutdown.
5 MR. ROCKHOLD:
Their comment was, do you want us to 6
initicto a small-break LOCA going into every 7
MR. FAGE:
What do you propose to do for the valve?
8 MR. ROCKHOLD:
In their program right now, they have 9
it identified as a Category C safety relief valve, and they're 10 doing a test every five years.
11 MR. PAGE:
The N over 60 stuff?
That's not going to 12 he good enough.
My management wen't accept that, and that's 13 right in the ORCS manual I hope TMI understands the 14 importance of it.
15 MR. SMYTH:
How do we do it?
There's no way to time j
16 it.
17 MR. PAGE:
How do you do it every five years?
If 18 you do that, you're only doing a setpoint test, PTC.
19 MR. SMYTH:
Right.
20 MR. PAGE:
What is the normal stroke time on the 21 valve; does anyone know?
You've never ever stroked.
22 MR. ABRAMOVICI When the valve is tested, we get an a time to open, you know, to full blowdown.
But that 23 open
[
24 is done at Wylie, I guess.
25 MR. BASHISTA:
We do stroke the solenoid to make
144 1
sure the solenoid moves.
2 MR. PAGE:
That's important, because one of the big 3
failures that would occur would be in the solonoid.
4 MR. BASHISTA:
We do check the setpoints for the 5
solenoid.
6 MR. PAGE:
I really feel it's important to stroke.
7 MR. SMYTH:
I don't know what stroke time means on r 8
relief valve.
This isn't a valve that powers open.
This is a 9
valve, a little pilot opens.
The system pressure lifts it.
10 MR. BARLEY:
It's a fast acting valve.
11 MR. PAGE:
If the test is identical every time, 12 won't it repeat every time, whatever it is?
13 MR. BARLEY:
You're talking less than two seconds.
14 MR. BASHISTA:
You couldn't measure the stroke time.
15 MR. PAGE:
It's that fast?
16 MR. BASHISTA:
Yes.
17 MR. PAGE:
It might fall into the rapid-acting 18 thing.
Just make sure it meets some limiting time, some very 19 short limiting time, as opposed to trying to trend changes and 20 stroke time and things like that.
But if it was hanging up or 21 something like that, then you'd probably pick it up just by 22 doing that sort of a test, or if it was having some sort of a l
23 problem.
24 We've had a lot of problems with PORVs, as you are l
m 25 probably aware.
You are just one of the many.
You suffered
~
145 3
1 more than others did, but other people have had problems with
^
i 2
their PORVs also.
3 MR. SMYTH:
Keeping them closed is the problem, not 4
opening them.
5 MR. PAGE:
Opening them is safety-related in 6
low-temperature overpressurization, so it's important to be 7
able to open.
8 MR. SMYTH:
I don't deny that.
But the problems 9
have been in keeping it closed, as opposed to opening it.
10 MR. PAGE:
I think the closure position is more 11 dedicated to the block valve.
I believe the block valve is 12 really the dedicated valve for closure.
Even though it's nice
(;
t 13 to be able to close a PORV, I think it's important to close 14 it, but a block valve is really supposed to save you.
You 15 stroke the block valve quarterly, right?
16 MR. SMYTH:
Yes.
17 MR. BARLEY:
In addition, there are some instrument 18 control surveillances that check the setpoints, circuitry, and 19 logie more frequently than the every five years.
~
20 MR. PAGE:
How many PORVs do you have?
21 MR. BARLEY:
One.
One installed.
One installed and 22 one spare.
23 MR. PAGE:
One installed and one spare.
So it
)
24 wouldn't be possible to do that each refueling and swap them 25 out, would it, to send it to Wylie, let them do the test, and l
l
146 1
then put that one on each refueling?
2 MR. BARLEY:
Such things are possible.
3 MR. PAGE:
Let me rephrase that.
Is it impractical?
4 MR. SANFORD:
It's undesirable for us to be without 5
the spare valve.
If it's not necessary to be without the 6
spare valve.
We routinely spin the valve offsite.
To change 7
out a valve that doesn't need to be changed out and send it 8
offsite is not desirable'.
9 MR. PAGE:
You're assuming it doesn't need to be 10 changed out.
11 MR. SANFORD:
That's right.
12 MR. PAGE:
So you assume a valve is operable if you 13 never test it, is that right, because you didn't prove it was 14 inoperable?
That's what I'm hearing.
What I'm hearing, 15 because it's not tested, it's automatically operable; 16 therefore, it's a good valve, and you don't want to replace a l
17 good valve.
That's what it sounds like.
18
,MR.
THOMPSON:
Does the Staff have a position on a 19 configuration such as 1
20 MR. PAGE:
This is our standard write-up.
21 MR. THOMPSON:
What I'm hearing Herb say, it's a 22 different configuration at TMI.
Do you have a Staff position 23 for testing PORVs in a TMI-type configuration?
24 MR. PAGE:
We don't have a special 25 MR. ROCKHOLD:
The closest thing I can think of, the
~
147 their ADS valves are pilot-action y -
1 boiling water plants have 3
2 release, and they ship them off to the lab for bench t>.. t i n g 3
every refueling outage.
4 MR. THOMPSON:
So there is a precedent for that.
5 MR. SANFORD:
A sample of those valves, not the 6
entire set of valves.
7 MR. PAGE:
You only have one.
8 MR. SANFORD:
We only have one.
According to the 9
BWR analogy, all of the BWR valves are not shipped out every 10 r e f u e l l'n g.
11 MR. PAGE:
I think it's a good portion of them.
12 MR. SANFORD:
It depends on the results of the ones
(.,..'\\
J 13 that are inspected.
14 MR. THOMPSON:
I would suggest that we need to get 15 our position clear on that and get back to you.
16 MR. PAGE:
I'll discuss that with Frank in just a l
17 few minutes and see if we can come up with something.
18 MR. CONTE:
One related question:
Are you sure that 19 you don't do the actual functional check on relief at the 500 20 point setpoint?
When you're in a refueling interval that does l
21 the~ calibration on the instrumentation, that also causes the 22 valve to actuate.
23 MR. BARLEY:
Causes the pilot valve to actuate, (j
24 the solenoid-operated pilot valve to actuate.
25 MR. CONTE:
The main disk isn't moved.
148 6
1 MR. SANFORD:
We have recently done those special v
2 tests.
The specials actually open the valve, the tests new 3
indications of the flow, vibration of temperature.
4 Mk. CONTE:
That's not part of your normal 5
surveillances?
6 MR. BARLEY:
No, that's not part of our normal 7
surveillances.
8 MR. CONTE:
I just looked at that area.
I guess 9
what I saw was the pre-op test.
10 MR. ROCKHOLD:
I guess question AA.3 is still an 11 open item for the NRC action right now.
12 We will proceed on with spent fuel coolant system,
- )
13 Question BB.1.
14 Review the safety function of the following valves 15 to determine if they should be included in the IST program.
l 16 And the category C valves, where it says SF-47 and 17 48, there is a typographical error.
It should be SF-V7 and i
18 V8.
It was an error that we have subsequently found.
7 and 19 8,
I believe those are the pump discharge. check valves.
The 20 spent fuel coolant pump discharge check valves.
21 Are we ready to discuss item BB.1?
j l
22 Okay.
The category B valves that I have indicated l
l l
23 there, 1 through 6 and 11 through 16, you state that these are 1
24 strictly maintenance only valves used for system alignment.
N _,
25 They do not perform any safety function.
I l
149 1
Do we agree that the system does perform a safety 2
function?
The pumps are currently included in the IST program 3
and tested to Section XI pump testing requirements.
That you 4
feel these isolation valves on the suction and discharge of 5
the pumps do not perform any safety function.
They would be 6
passive control valves.
't MR. BARLEY:
Yes.
8 MR. BASHISTA:
Part of the justification we gave you 9
is the number of redundant flow paths we have there.
)
10 MR. ROCKHOLD:
Okay.
11 MR. BARLEY:
Once established, they are mainly for 12 operator convenience lining up the system.
13 MR. ROCKHOLD:
Okay.
I can go along with what you 14 say o*
the s'x control valves, or the twelve control valves.
15 However, have you had a chance to take a second look 16 at SF-V7 and 8,
the pump discharge check valves?
17 MR. BARLEY:
In effect, those valves are tested by 18 the test of the spent fuel cooling pumps quarterly.
They are I
l 19 a necessary part of the flow path which required flow pump i
20 tests.
21 MR. ROCKHOLD:
That's the way we see it, too.
They 3
22 do perform a safety function for closing to prevent diversion 23 of cooling flow through an idle pump.
They must open to 24 permit the cooling flow.
25 However, your current testing verifies the valves
I
~
150 1
do, in fact, close when required and open when required.
We 2
are just asking to see them included in the IST program as 3
Category C valves and tested quarterly.
4 MR. COLITZ:
We test the pumps quarterly if they 5
open.
You are not testing if the close.
6 MR. SHIPMAN:
(Shaking head negatively) 7 MR. ROCKHOLD:
You normally run both pumps?
8 MR. SHIPMAN:
Just one pump.
9 MR. ROCKHOLD:
You think if one of those check the flow 10 valves failed in the open position it would not 11 from the running pump would not spin the idle pump?
12 MR. SHIPMAN:
No.
The way those controls are set 13 up, the pump that is operating gets the suction and discharge 14 valve open, and the idle pump, all the suction valves are I
\\
i 15 olosed.
16 MR. RANSOM:
So safety position would be in the r
i 17 open?
18 MR. ROCKHOLD:
Safety position would in the open 19 position only if the isolation was closed.
20 MR. BARLEY:
If it helps resolve your issue for us 21 to add a document for those valves in the program in our 22 procedures, from a completeness standpoint, we can add 7 and 8 l
23 check valves in the open direction since we already test l
l 24 those with the pump test anyway.
25 MR. ROCKHOLD:
Okay.
15f 1
MR. THOMPSON:
Do you want that done?
2 MR. ROCKHOLD:
Yes.
3 Rick, did you say you would include the two check 4
valves, but not include the air-operated control valves?
Or, 5
did you say you would include them all?
6 MR. BARLEY:
What I said is, we would include the 7
check valves, pump discharge check valves.
8 MR ROCKHOLD:
Okay.
9 Joel has a comment that the control valves on the 10 suction side of the pump, do they have a required fail safe 11 position?
And, if the suction isolation valves are not 12 included in the IST program, then you can't take credit for 13 them closing. And maybe you do need to verify closure 14 capability of the discharge checks.
15 MR. BARLEY:
We could verify the idle pump is not 16 windmilling during the performance of the quarterly pump 17 tests.
That wouldn't be difficult to do.
l 18 MR. ROCKHOLD:
Did you say that would be difficult?
19 MR. BARLEY:
That would not be difficult to do.
20 MR. ROCKHOLD:
Okay.
21 So it is my understanding now that the spent fuel 22 coolant pump discharge check valves SF-V7 and 8 will be 23 included in the IST program.
And both opening and closing 24 will be verified at lost quarterly.
j 25 And the suction isolation valves for the pumps will
152 1
not be included in the IST program.
However, you will have to 2
verify at least one of those isolations open to verify the 1
3 closure capability of the check valve.
4 MR. SHIPMAN:
I'm not sure we can do that aspect of 5
it very easily, because it is all involved in the control 6
switch, which pump you are selecting to run.
Those controls 7
come off, those valves would normally be closed.
8 MR. ROCKHOLD:
Are the suotion cross connect 9
isolation valves SF-V62 and 63 normally opened?
There appears 10 to be a cross connect between the suction and the pumps, 11 between the isolation valves and the pumps themselves.
12 MR. COLITZ:
That's for rad monitor.
13 MR. BARLEY:
That's only on a one-gallon-per-minute 14 flow rate to rad monitor.
15 MR. GHIPMAN:
The safety function for not short 16 circuiting flow through the pump could be verified.
I'm not 17 sure which valve it is that is functioning for you, but the 18 safety function is there.
19 MR. CONTE:
It sounds like the ease of testing for 20 the closure function of the idle pump, you would have to rely 21 on the MOVs.
22 MR. BARLEY:
You have the same problem in either 23 case.
Then you can't individually test one valve, either the 24 check valve or the MOV, because they are both closed.
25 MR. SHIPMAN:
Because they are air-operated valves.
153 1
MR. BARLEY:
Air motor operated.
2 MR. ROCKHOLD:
You could verify the air-operated 3
valve was in fact closed by just looking at the valve stem.
4 MR. BARLEY:
That we can do.
5 MR. SANFORD:
But then you can't tell which one is 6
keeping the flow from going back through the non-operating 7
pump.
8 MR. SHIPMAN:
You can't tell whether the val've is 9
closed or the check valve.
It still could be the check valve.
10 MR. BARLEY:
You have the same problem in either 11 direction there on the two valves.
12 The one thing you do do is you measure the flow to 13 the spent fuel pools on the discharge pipe downstream of all 14 that, to satisfy the performance requirements of the pump 15 test.
That flow has to be 1000 gallons a minute, or 16 approximately, which does in some fashion tell you that you 17 don't have a significant bypass stream.
18 It does not necessarily tell you that the idle pump 19 is not windmilling.
20 MR. PAGE:
Do you know whether these control valves 21 would fail if you were to deenergize it?
22 MR. BASHISTA:
Offhand I don't know which way they 23 fail We have to look at it.
l
._)
24 MR. PAGE:
It seems like there is a potential 25 there.
If one of them even fails in the open position, it
154 1
might be easy to run your backflow test from a control panel.
3 2
MP. CONTE:
Related to these valves, I have a 3
question about the generic reliance on the fact that you have 4
redundant flow paths as 4.
reason for not testing any 5
individual.
6 That is what it seems like we are buying, we are 7
attempting to buy off here.
8 MR. COLITZ:
Rich, that plus the fact that NIA can 9
assist in enough time to do maintenance before you get in any 10 kind of trouble with those pools.
Right now I could knock off 11 spent fuel pooling and not do any for two months and not have 12 a problem.
7 13 That is not true, of course, during a core 14 offloading.
But that is another thing.
15 I'm hesitant to sign up for a lot of testing here 16 which we may have to defeat interlocks and so forth and sc on 17 when we are also looking at a system where there is not only a 18 lot of redundancy, but if everything fails on me, I do have l
19 time to do a fair amount of maintenance.
l 20 You know, it is not like a PORV or something.
l l
21 MR. BASHISTA:
I think we need to point out every i
l 22 quarter we verify the design flow rate for these pumps of 1000 23 gallons a minute goes to the pool.
1000 gallons goes in the gh
' yjf 24 pool, and that is the design flow rate.
25 I think that proves the check valve opens, and also
l I
155
/71 1
proves a significant amount of flow rate is not going through 2
the idle pump.
i i
3 MR. SHIPMAN:
Or any other hole in the pipe 1
l 4
someplace.
5 MR. BASHISTA:
That ought to be enough to close it.
1 6
MR. PAGE:
We could go through several scenarios 7
here when you don't have those valves.
8 MR. BASHISTA:
the point is every three months we do 9
verify 1000 gallons to the pool.
10 MR. McGOEY:
That is sufficient a flow capacity to 11 maintain the so-called cooling required.
l I...
12 MR. PAGE:
You are starting to use systematic 13 arguments to verify component operability.
I i
14 MR. BASHISTA:
Don't you believe the flow meter?
15 MR. PAGE:
I believe the flow meter completely.
i 16 MR. BASHISTA:
Doesn't that put 1000 gallons to the l
I 17 pool check valve open?
I 18 MR. PAGE:
Systematic argument to verify individual 19 components, which it is not doing.
It is not verifying.
e 20 MR. BASHISTA:
Hasn't the check valve opened?
21 MR. PAGE:
It appears the check valve also has to 22 close.
23 MR. SHIPMAN:
I think we can make the argument that
. l1.,
g;)
24 it doesn't have to go closed as long as I I don't care l
25 wher'e else the water is going as long as I can verify there is
)
~
156 1
1000 gallons going to the pool, there is no other safety
^^
2 function within the rest 3
MR. PAGE:
On that test there is 1000 gallons.
4 There may be a day that it isn't going there.
5 MR. BASHISTA:
It requires a test every three 6
months.
Haven't we done a test every three months?
If we 7
verify 1000 gallons to the pool every three months, that is a 8
normal IST test.
9 MR. PAGE:
It shows you something is keeping you 10 from backflowing through the other side.
But it could be it is more likely it could easily be something 11 something 12 that is not ever tested in the IST program, ever.
And it 13 would be acre than subject to failure.
i I guess I am 14 MR. BASHISTA:
Doesn't the test 15 missing something.
Doesn't 1000 gallons to the pool prove f
16 whatever needed to function has functioned?
17 MR. PAGE:
It proves that something out of four l
18 things functioned.
One out of four, or one out of two, excuse 19 me.
And there is three different groups of two for each pump.
20 MR. BARLEY:
The other point I think to be made to 21 build on that is that the system is normally in operation 24 i
l 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> a day, and is alarmed and instrumented to tell when it 23 is not performing.
And there are no automatic start signals l
24 to standby pumps or valves to realign the system to provide l..,
25 any automatic.
That is strictly an operator action in any
157
.TN 1
event.
2 ME. PAGE:
Operator action you can count on 20 l
3 minutes or so, or less than an hour for a person to respond.
4 How long are you going to take to go down and rebuild a valve 5
or figure out exactly which one isn't working and then 6
actually get into the system to get it?
That is not going to 7
happen in 20 minutes.
8 MR. BARLEY:
But there are a number of flow paths 9
that you have to do that.
There is no division in effect 10 between the A and B pools.
They are common pools.
11 MR. PAGE:
So if that check valve went away and just 12 dropped the diso right in the bottom of the old valve body, e'.
13 and all that time you are doing a testing these valves over 14 here have been isolating, then there comes the day that one of 15 those didn't close when the pump went off, what would happen 16 then?
17 MR. SANFORD:
Start the second pump.
18 MR. SHIPMAN:
Then we have 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix whatever 19 is the problem.
But we have tested that system quarterly.
20 MR. PAGE:
The system --
21 MR. SANFORD:
Why can't we just start the other 22 pumps along with the check valves?
Just run that pump and the 23 other one does fine.
24 MR. McGOEY:
There is only about a total of three 25 days maybe where that would be a problem:
4 158 1
Immediately after full core offload, after a lot of 2
concerted assumptions where the decay heat is large enough, 3
that you would start boiling after, you know, a 24-hour 4
period.
You don't have significant release.
All you do is 5
start losing activity out of the fuel pool.
It is not a 6
significant release.
7 I'm sure from a safety point of view you would have 8
valve repair or else problem detecting and go to the alternate 9
flow pattern.
10 There is plenty of time.
Like Joe said, it is nbt 11 an immediate type of response.
12 MR. CONTE:
I guess that is an academic question as 13 to whether we could rely on time as a means of positive 14 control.
15 MR. PAGE:
I don't know if we can or not.
I guess I 16 am not familiar enough with that scenario.
17 MR. THOMPSON:
That's not your need.
18 MR. PAGE:
That's true.
We look at it from the 19 standpoint, is it safety related.
If it is safety related it 20 is in the program, what can you do?
21 But here we are getting a systematic accident 22 scenario type argument as opposed t o vih a t we are normally used 23 to discussing.
24 MR. THOMPSON:
I think you need additional 25 assistance from some systems people and they may want to hear
159 t
i more of the story from the Licensee.
2 I'm hearing a number of arguments here that haven't 3
been documented yet.
The time factor, the potential for 4
running a second pump if one line started to reciro.
5 We will get some aid from some system types.
If you o
6 could though, please study those inlet valves and see if you 7
can figure out what their failure modes and stuff are.
That a
way, the next time we talk on that subject at least we will be 9
able to know the details of how they work.
10 MR. COLITZ:
How are we leaving that item?
Both you 11 and us look at it?
12 MR. PAGE:
Yes, open to both sides.
I am going to ki
~
13 contact the Systems Group.
I don't think that will be done by i
14 tomorrow morning, so we can keep that a little longer term.
15 MR. ROCKHOLD:
Before we go to the next question, we 16 may have a brief discussion about 50 and 51 You state they 17 do not provide a safety function?
My opinion is yes, they do 18 provide a safety function in the open position.
That is the 19 only return flow path back to a pool.
Check valves have to 20 open to admit spent fuel pool cooling water back into the fuel 21 pool. They do not provide a safety function because of the 22 piping configurations where you can't siphon the pool level 23 below a safe level.
I can agree with that.
1 24 Does the discussion of SS-V50 and 51 tie into the 25 same discussion with 7 and 8,
or do you agree that they do
160 1
perform a safety function in the open position?
2 MR. COLITZ:
No. 7 and 8 perform a safety function 3
in the open position; 50 and 51 do also, except right now I 4
guess they said during our quarterly surveillance we only 5
maybe pumped through one of them, and you get into you 6
start getting into various system alignments to do them both 7
on a quarterly frequency. So I think we need to look at 8
that. I think this whole BB.1 we need to look at along with 9
the NRC.
10 MR. ROCKHOLD:
Okay.
The entire thing is an open 11 item, both parties.
12 MR. RANSOM:
Okay.
So until we resolve this, you
(
13 are not going to add SF-V7 and V8 to the program and exercise 14 them open quarterly?
15 MR. COLITZ:
I think I want to take this whole issue 16 as one issue and resolve it all rather than say we are going 17 to add a segment and then find out we look at it further, the 18 NRC looks at it further.
I think the best thing is understand 19 the whole issue and make one scenario of what is going to be 20 in the program.
i 21 MR. MC OOEY:
We are still asking the NRC to look at 22 it from the system approach.
23 MR. COLITZ:
They are.
The System Group is going to f
24 review it.
25 MR. ROCKHOLD:
Okay.
Are we ready to proceed with
161 1
river water system, Question CC.17 The question is: Review 2
the safety function of the following valves to determine if i
3 they should be included in the IST program and categorized as 4
4 indicated.
Now, the eight valves listed we agree with, 23A 5
and B,
6A and B, and 8A and B.
However, on SW-V24A and B, we 6
are concerned about a required fail-safe position.
That is 7
very similar to a lot of questions we have had before on these 8
control valves.
1 9
MR. COLITZ:
I think we have to put them in the 10 category that we go back and look at those.
11 MR. ROCKHOLD:
Certainly.
12 Question DD.1.
Provide a more detailed technical 13 justification for not full-stroke exercising the valves and 14 testing the pumps identified in Relief Request IV and Pump 15 Note 12, respectively, during cold shutdown.
l 16 I didn't fully understand all the information I had 17 while we were doing the review concerning these topios, and it 18 appears to me that you have currently got something in the 19 works right now concerning all these WDL valves or WDL pumps 20 and CA pumps.
It's an appeal item right now so I don't really 21 see where we can discuss it that much.
I think the SSER had a 22 discussion of it and the utility is currently appealing that 23 discussion.
24 MR. ROCKHOLD:
I think the item DD.1 is just you
-f 25 have your position, the NRC has theirs.
I guess it is going 1
l i
i 162 i
1 1
to require a management decision, so why don't we defer this 2
one until tomorrow morning to be discussed when Joel and Frank 3
Cherny 4
MR. RANSOM:
I don't think our position is do a 5
quarterly.
6 MR. ROCKHOLD:
It is.
7 MR. RANSOM:
I thought they agreed with --
8 MR. SHIPMAN:
My understanding from our last meeting 9
is the NRC accepted a refueling test of these emergency 10 boration sources. We first took a position that these are not 11 even required bedause it's a backup to a backup.
Your 12 position was that they required to be tested, but I thought
\\
13 that you accepted at the refueling interval.
14 MR. ROCKHOLD:
Well, that's not the way we are 15 reading the SSER.
16 MR. THOMPSON:
Look at the October 23rd Safety i
17 Evaluation, Item A.2.
Do you have that?
On page 2.
18 MR. SHIPMAN:
Just to review, what we just read was 19 your rejection; that the pumps have to be tested in response 20 to our request that they be deleted from the program.
21 MR. THOMPSON:
Raght.
22 MR. SHIPMAN:
Now the question is can we test them 23 quarterly in accordance with the Code, and we don't feel that I
24 we can.
25 MR. THOMPSON:
Right.
So the appeal issue is the
163 1
last sentence: "Therefore, they are required to be tested in 2
accordance with the Code," and that is what you are 4
3 appealing.
You say that that is impractical because of the i
4 generation of rad waste.
5 MR. SHIPMAN:
It it will cause a plant transient in 6
that you will pump baron into the makeup tank, which will go 7
into the raaotor coolant system, which will change reactivity 8
in, parallel.
9 MR. THOMPSON:
I don't have your response to your 10 appeal letter.
Your solution would be to put in reciro lines 11 at some rather exorbitant oost.
12 MR. SHIPMAN:
Yes.
13 MR. MC GOEY:
Wait a minute. Is that right, Mark?
14 MR. THOMPSON:
$500,000?
15 MR. MC GOEY:
That is a solution, but that is part 16 of our appeal, so it's not justified to do that.
17 MR. SANFORD:
That's right.
18 MR. THOMPSON:
Good. We will leave that as an appeal l
19 issue for tomorrow.
l l
{
20 MR. SHIPMAN:
I just wanted to make sure everybody 21 understood where we were with that.
I wasn't clear myself.
22 MR. ROCKHOLD:
Okay.
Your Question DD.2, where we l
23 ask for you to provide an explanation of the alternate test 24 methods that have been investigated to verify operability of 25 main feedwater check valves at W-V12A and B.
i 164 1
Your response referred to Question M.1.
The 2
response appears to be okay.
3 I have got the next four questions as " discuss with 4
Joel," so maybe we should just leave all those.
I think maybe 5
we should leave all those for the morning.
6 MR. COLITZ:
Which ones do you want to let go till 7
the morning?
DD.3, 4 and 5?
8 MR. ROCKHOLD:
DD.3, 4,
5, and pump testing question 9
1 1
10 MR. COLITZ:
A couple of these look pretty simple 11 and straightforward.
t 12 MR. ROCKHOLD:
Which ones do you think look simple 13 and straightforward?
14 MR. COLITZ:
B1, C1.
15 MR. RANSOM:
On the pump program?
i 16 MR. COLITZ:
Yes.
17 MR. THOMPSON:
I think it would be helpful probably l
18 for the Licensee's people if you could at least express some i
l 19 concerns and just leave them with a thought or two for the i
u 20 night.
Would that be helpful, Rick?
21 MR. MC GOEY:
Yes.
A thought would be helpful, as i
22 well as if you could just identify do you know already now 23 which ones are not a concern.
I 24 MR. THOMPSON:
I suggest we go on and go through, 25 and what you can't complete because Joel wasn't here, we will
~
165 1
complete tomorrow.
2 DD.3.
3 MR. CONTE:
What was the resolution of DD.27 Refer 4
to M.17 5
MR. ROCXHOLD:
Yes.
DD.2 refers back to the 6
response to M 1 as satisfactory.
7 DD.3.
The basic question discusses toch spec 8
testing which is typically system operability testing versus 9
Section XI testing, which is component testing.
The reason I 10 wanted to delay that one for Joel is Joel has a short 11 discussion of this topic that he likes to express to all the 12 utilities, and it is basically a discussion where a lot of k
13 your tech spec testing is performed for system operability and system capabilities, whereas 14 system functional testing 15 Section XI is written towards individual component operability i
16 and the focus is more on component testing than system 17 testing.
18 Now, knowing that a lot of component testing i
i l
19 requires operation of a system to perform the component 20 testing, but just because a system performs to tech spec 21 requirements does not necessarily prove that individual 22 components in the system are satisfactory to the Section XI 23 testing requirements.
That was just a general discussion of l
24 that topic is one item that Joel likes to try and convey to 25 the utilities.
So I really don't think it is going to cause i
166 1
any problems other than a couple of relief requests.
2 You made a generic statement where you say that 3
since this testing satisfies tech speo requirements, it should 4
he satisfactory for Section XI.
I believe Relief Request 3 5
was one of those.
Yes.
Since this test frequency is adequate 6
for tech speos, it should be adequate for Section XI Now, as 7
a blanket statement, the NRC has not been accepting that.
i 8
In your example you go on to say that for example, j
9 using Relief Request 3 for the HPSI check valves 10 MR. COLITZ:
On those cases I think we gave the I think we threw those words in, 11 additional justification 12
" adequate for tech specs," you know, as additional 4
\\ ~'
13 justification that there is a system test which is getting 14 some component testing done also.
I think for these 14 and 16 15 in these cases we gave additional justification.
This was 16 what, for the full stroke on a quarterly basis?
17 MR. ABRAMOVICI.
For HPI.
)
18 MR. ROCKHOLD:
In that particular instance we 19 discussed the specific reasons for not testing those 20 particular valves.
Like I said, we added that question just 21 for this general statement that Joel likes to put out to the 22 utilities about tech spec testing versus individual component 23 testing per Section XI, It was basically to get us talking 7.g 24 about the topic.
- 7j I
25 MR. MC GOEY:
So we can wait for Joel's talk
167 1
tomorrow.
2 MR. ROCKHOLD:
Yes.
As a matter of fact, I might 3
tell him I discussed it with you, and that might be 4
satisfactory.
Understanding the two concepts there is the 5
important part, I think.
6 MR. BARLEY:
I think there is also a point to be 7
made from our perspective, that there are toch 8
spoorequirements on systems that sometimes are specified at 9
different frequencies, slightly different requirements than 10 what the Section XI requirements are.
We only have one plan.
11 MR. ROCKHOLD:
I understand that.
-~
12 MR. BARLEY:
And we desire to see those testing 13 requirements that come out of different arms of the NRC to 14 ocnform to where they are consistent and make sense.
If it is if the S-fety Evaluation says it is 15 acceptable to test 16 acceptable to test the system on a certain frequency and that 17 provides an adequate measure of safety, then to us it seems i
18 also that in those instances where system tests also are 19 necessary to perform the component tests, those test 20 frequencies should naturally by the same logic extension also 21 be of a frequency that would support safety.
22 MR. CONTE:
And there seems to be only one problem 23 in that regard, namely, the emergency feedwater system, or
\\,j 24 have you identified other systems where there is an 25 inconsistency, a frequency of testing versus i
~
168 MR. BARLEY:
The example that we chose in the 1
2 response to DD.3 dealt with the HPI levels.
There are a 3
number of mainly ES systems in emergency feedwater where that 4
becomes a problem, and boric acid injection is another one.
5 MR. ROCKHOLD:
Okay.
Are we ready to move to 6
Question DD-4, then?
7 A r e-the boric acid recycle pumps and/or boric acid 8
pumps utilized to establish the proper baron concentration in 9
the RCS when approaching cold shutdown conditions?
10 This particular question was aimed more at the 11 frequency of testing of CA-P1A and B or WDL-P13A and B.
I 7.
12 believe your program stated that you test these valves during 13 a refueling outage, and we were wondering if they were, in 14 fact, utilized during cold shutdown conditions to see if the 15 testing of the associated valves could be performed then?
16 So your response is, they may or they may not be 17 used each cold shutdown.
18 MR. BASHISTA:
I think one of the four will.
One of 19 the four pumps will be used.
l 20 MR. BARLEY:
But not necessarily.
21 MR. ROCKHOLD:
If that's the care, then, I'm not 22 really sure we can say there's a justification for delaying l
23 the testing until a refueling outage frequency, if it's 24 possible to do it during cold shutdowns.
25 MR. BARLEY:
It's not possible to do all the pumps
~
169 i
during cold shutdown.
One of the pumps is used, depending on 2
which tank contains boric acid of the proper concentration to 3
effect the cold shutdown.
4 We are not required necessarily to have any water in 5
the recooling borio acid tanks, if they are not the tech speo 6
tanks, for example.
So those tanks may be empty throughout a 7
complete operating cycle.
8 MR. COLITZ:
We have a choice of tanks for our 9
tech specs.
We could throw one system away tomorrow, as long 10 as we have the borio acid mix tank.
To inspect the toch speo 11 tanks, we don't need a reclaimed borio acid tank, since we 12 have both tanks.
We've taken the flexibility in the tech 13 specs to claim either one as a tech spec tank.
14 MR. BASHISTA:
We've used one of the four pumps, but 15 we necessarily would not have the time or have the i
16 inclination, nor would it be reliable, to do the complete IST 17 test.
Starting a pump and using it to inject some boric acid 18 and running the entire IST test is two different items.
l 19 MR. ROCKHOLD:
These are the pumps you say you i
20 evaluate at the installation of reoire piping, and it's rather 21 expensive, the item you mentioned a few minutes ago?
22 MR. COLITZ:
Right.
23 MR. ROCXHOLD:
So it appears that this one is s
24 going to be discussed again tomorrow also, in conjunction with 25 DD-1, and Question 5 is also tied into that They are all l
l
~
170 1
valves that are tested during the pump test, currently 2
identified through refueling outage.
3 MR. ROCKHOLD:
Pump testing program, Question A-1, 4
emergency feedwater system:
Is instrumentation available to 5
allow measurement of flow while testing the EFW pumps, and 6
note 9 does not agree with Section XI, 1980 edition?
7 I think the program was originally written based on 8
the 1974 through sum &er of '75 code, and subsequent codes have 9
deleted that footnote where it gave you the option of only to measuring one of the flow or delta-P parameters for pump' 11 testing, and the current NRC position is, during pump testing, 4
12 both parameters will be measured. Both flow and differential
(
13 pressure will be measured for pumps.
14 MR. BARLEY:
We understood the NRC Staff position 15 was, in lieu of measuring one of those variables, you could 16 perform a fixed resistance test that is, one where the 17 piping configuration limited the flow, and it was repeatedly 18 used in the IST testing, that that was an acceptable way of 19 meeting that test requirement, 20 MR. ROCKHOLD:
When I first started doing this work, 21 that was an acceptable way of doing the pump testing.
22 However, the newer editions of the code have deleted the 23 footnote, and I have subsequently talked to Joel, who has 24 talked to oode people about that, and they have concluded that 25 the NRC's position now is that the code requires measurement
171
'~'
1 of both flow and differential pressure for all pumps that are 2
tested.
3 MR. BASHISTA:
Have you deleted the Staff position?
4 Has that paper evaporated?
5 MR. ROCKHOLD:
I'm not sure it was ever written.
6 MR. BASHISTA:
It's in the meeting minutes.
7 MR, THOMPSON:
Can you identiff whnre that is?
8 MR. BASHISTA:
Not right this moment.
9 MR. CONTE:
Where what is?
10 MR. THOMPSON:
They're making reference to a Staff 11 position, measuring flow in a restricted system is an f
12 acceptable alternative to measuring flow
!.(
~~
13 MR. BARLEY:
There was a significant amount of 14 discussion in the meeting'that was held on the first ten-year 15 submit 41 with the NRC contractor at that time, which we were 16 told that fixed resistance testing was an acceptable option or 17 alternative.
I 18 MR. ROCKHOLD:
As it turns out, during that e
19 timeframe, you were using a code that said it was acceptable.
20 The code that you are currently using does not say that that's 21 acceptable.
So 1980 through winter of
- 77 through the 22 winter of '80 code is the one you're currently using?
23 The '80 edition, through winter of
'80, that option 24 is not available in that edition of the code.
s,,
25 This is another item we can discuss with Joel in the
172
,j?h 1
morning, if you like.
% ?'
2 MR. BARLEY:
May I ask, is it now the NRC Staff the existing 3
position not to grant relief where the design 4
plant design does not provide for the level of instrumentation 5
to satisfy the 1980 code requirements, not to accept fixed 6
resistance tests?
Is that the Staff's position?
7 MR. THOMPSON:
Let me make a comment.
I'm not sure 8
what the regulations are regarding backfitting in that 9
regard.
The regulations that endorse various codes are
.i 10 approved by the Commission, and they are backfits, but they I
11 are approved backfits, and Licensees are required to comply 12 with those.
G.,
13 I think this falls into that category.
But then 14 there is some question about whether or not plant 15 modification: were anticipated in those regulations.
We will 16 need to get some legal clarification on that, perhaps.
Maybe i
17 we can resolve it technically, but if not, we can get legal 18 advice.
e 19 MR. BASHISTA:
On the technical side, you have to 20 understand that we are on a reciro flowpath, and there's only i
21 so much water we can put in that reoiro flowpath, and whether 22 we measure flow or not, it's not going to change.
And that 23 information is academic in nature, and it doesn't do anything
<~
24 as far as pump operability.
It doesn't improve or help us in j
25 any way.
)
173 1
MR. SHIPMAN:
Would it help if we asked for relief, 2
now that we understand the code?
Can you just grant us relief 3
for that particular item?
1 4
MR. THOMPSON:
Well, when it comes to granting 5
relief, the way I understand it is, the relief is granted 6
based on some equivalent or compensatory procedure.
~
7 MR. SHIPMAN:
In fact, we do measure flow.
8 MR. THOMPSON:
It seems to me that there might be 9
some basis for saying, the compensation is that you have got 10 constant flow because of the 11 MR. SHIPMAN:
We do measure the flow in the EFW 12 system.
I think the problem is, it doesn't meet the code s
I i
13 requirement for three times the range.
'~~
14 MR. BASHISTA:
We do measure flow rate in the 15 procedure.
It is recorded.
But the flow rate is constant.
16 It's something like 90 or 80 gallons for your motor-driven 17 feedpumps and 180 gallons for the EFP-1 The flow rate is 18 constant from test to test.
e 19 MR. CONTE:
Is there an instrument in the recire 20 line?
i 21 MR. SHIPMAN:
On the suction side, there's a flow 22 instrument, and the scale of that instrument is for the design 23 flow into the generators, I guess.
24 MR. BASHISTA:
That's right.
25 MR. SHIPMAN:
For that small recirc flow, you're
)
174 1
more than three times the reference flow that you're looking 2
for.
3 MR. BASHISTA:
Maybe you could grant us relief on 4
the scale range.
5 MR. ROCKHOLD:
That particular relief, I have seen full-scale 6
granted in the past where the scale 7
instrumentation is more than three times the reference value.
8 A lot of times on the charging pumps, that's the same 9
situation.
Charging pump test flow is significantly lower 10 than the rated flow of the instrument.
We've seen that 11 before, and we'O. seen that granted.
12 So again, this is an item we will discuss in the
( '
13 morning, if we need to.
14 Okay.
Question B-1, do plant heat loads during 15 cold shutdown require operation of more than one nuclear 16 service water pump?
Can individual pump flow rates be 17 measured at that time?
18 Your response had the phrase, " cold shutdowns of I
l 19 short duration."
I'm not sure I understand what a cold 20 shutdown of short duration is.
21 Is it a variable, depending on time of year?
22 MR. SANFORD:
It's a variable depending on the 23 timing of the shutdown and the other occurrences that have proceeded in the plant, the need to process radwaste more than 24 25 any other issue.
i i
175 1
The concern was that if the shutdown is of a 2
sufficiently short duration that we don't have the liberty to 4
3 stop decay or stop the processing of radwaste during that 4
period, then the answer is, no, we have to have two nuke 5
service pumps going.
We're into other conditions of the 6
plant where v'e can isolate some of the larger loads during the 7
program.
During these shutdowns, it may be possible to drop 8.
to one pump.
i 9
It's really a probability.
A longer cold shutdown I
10 gives us a larger chance of being able to get down to one 11 pump.
Ambient temperature is also a factor.
l 12 MR. THOMPSON:
What about shutdowns greater than 30 13 days?
Are you normally down to one pump at that time?
14 MR. SHIPMAN:
Thirty days isn't that long for a 15 maintenance outage.
During a maintenance outage of 30 days, 16 the leak rate testing alone requires to drain all sorts of 17 systems to test.
That's just an example.
If I was going to i
18 do it on this cold shutdown, that's the type of maintenance 19 that would generate a lot of radwaste.
That would require 20 evaporator runs to pumps.
21 MR. SANFORD:
The point we were trying to bring up 22 here is that the ability to drop to one pump is not associated specifically with the length of time or the duration 23 with 24 of shutdown.
It's the other systems that are contributing the l
25 heat load.
~
176 1
MR. BARLEY:
I think the other point to keep in mind 2
in this is, in normal operation when you're running this 3
system with two pumps, the normal heat load during operation 4
is much more than the heat load that is required to be removed 5
during any aooident.
So, in effect, this system is tested in 6
excess of its requirements functionally during normal 7
operation at power every day.
8 It has been a special evolution for us to get down l
9 to one pump on the nuke service systems.
10 MR. ROCKHOLD:
1 don't think we're going to have any i
11 problem with that, though.
Just reading your relief request 12 again, seeing what you're currently doing, a whole series of 13 two pump tests quarterly.
It's not as if you're not doing 3
14 anything during quarterly or full shutdown conditions.
15 Question C-1 is also a similar argument to that that 16 you're doing on the nuclear services closed cooling water 17 system.
18 MR. COLITZ:
See Note 10.
It's the same logic.
e l
19 MR. ROCKHOLD:
I guess I was reading Note 10 for I
20 Question B-1.
I should have been reading Note 6.
21 MR. COLITZ:
- Six, 22 MR. ROCKHOLD:
So are you doing these two pump tests 23 quarterly for the nuclear service river water pumps, or is 24 that strictly a pump flow test during refueling outages?
4 25 MR. BASHISTA:
It's a pump test.
Two puAp tests are f
1
177 1
correlated.
2 MR. ROCKHOLD:
Okay.
I have no problem with Item 3
B-1 or C-1.
4 Item D-1, reactor building emergency ocoling system, 5
provide the P&ID
, a 6
MR. COLITZ:
Let me back up.
Is B-1 and C-1 okay?
7 MR. ROCKHOLD:
Yes.
8 Item D-1, provide the P&ID that shows the flowpath I
9 utilized during reactor building emergency cooling pump 10 quarterly testing.
And your response is, you indicate what 11 the flowpath is, and this produces a fixed flow rate through 12 RR-V10A and B.
i 13 I think the only real problem we have with that one 14 is, again you are measuring either flow or differential 15 pressure during this pump test, correct?
16 MR. BASHISTA:
Measuring delta-P.
17 MR. ROCKHOLD:
You are measuring delta-P and not 18 measuring flow, then.
e 19 Mk. BASHISTA:
That's right, r
20 MR. ROCKHOLD:
We don't have any problem at all with i
21 that.
22
+ MR. CONTE:
Just a comment here.
Can a calculation l
23 of fixed resistance correlated to a pump head with a l
24 calculated flow rate on rectroulation provide, via 25 compensation, as Owen was saying, for the lack of measured
)
l
178 1
flew instrumentation on some of these tests?
l i
2 MR. ROCKHOLD:
Say measuring pump delta-P?
3 MR. CONTE:
Calculating pump resistance, going to a 4
pump head curve for the pump, coming up with a number.
This 5
is what the reoiro flow is, based on the fixed resistance, o
6 Could that be construed as a measured flow rate?
~
7 MR. ROCKHOLD:
I don't be1ieve so.
8 MR. RANSOM:
Joel's argument on that is, a pump head 9
ourve is derived from an ideal, brand-new pump.
That's going 10 to change over life.
I just wanted to pose 11 MR. CONTE:
I just thought 12 that as a question, because you guys are probably looking for 13 alternate exceptions or alternate solutions.
14 MI. McGOEY:
That's back to Question A-1, I think.
15 MR. CONTE:
Yes.
i 16 MR. SHIPMAN:
You can correlate the pump flow ourve 17 that we have to the flow conditions that exist for that system 18 once a year, and then on a quarterly basis, do a one-point a
19 check on reotro with fixed resistance, and correlate that to 20 the head flow ourve as well.
21 MR. CONTE:
You might want to save that for Joel 22 tomorrow.
23 MR. ROCKHOLD:
I think so.
24 MR. RANSOM:
A-1.
On this one, D-1, I think we have 25 agreed that -- with your response.
179 1
MR. CONTE:
Let me ask that.
Let me play devil's 2
advocate here.
Why is D-1 acceptable, because there are only they have a fixed flow rate.
Are they measuring that flow 3
4 rate?
We said they're not measuring flow rate.
5 MR. RANSOM:
They're measuring flow rate on a e
6 refueling outage frequency.
' fixed flowpath.
That's a 7
MR. BARLEY:
That's not a 8
diffetent flowpath.
l 9
MR. ROCKHOLD:
That's also a flowpath.
We're not 10 going to ask you to increase the frequency of testing.
11 MR. CONTE:
So at some point in the cycle, there is 12 a measured flow rate.
(
13 MR. ROCKHOLD:
Question D-2, provide the specific 14 technical justification for not performing the reactor 15 building emergency cooling pump complete Section XI testing 16 during cold shutdowns instead of refueling outages.
And we l
17 agreed with your response.
18 And then the last question on the screen wash a
l 19 system.
In reference to pump flow measurement, the present
'O 20 NRC position is that lack of installed instrumentation is not 21 suffiotent justification for not performing the required 22 Section XI testing.
23 That's similar to A-1.
24 What size pumps are these screen wash pumps?
25 MR. BASHISTA:
We can tell you the piping size.
180 1
MR. ROCKHOLD:
Do you know which P&ID clearly shows t;
2 the pumps themselves?
they're on 3
MR. BASHISTA:
Either on 201 or 202 4
- 203, 5
MR. BARLEY:
The FSAR probably tells you what the s
6 flow rate size is, but I don't think we have that information 7
at our fingertips here.
8 MR. ROCKHOLD:
Why don't we save this discussion for 9
Joel in the morning also?
I'm sure he'll have some comments 10 about lack of installed instrumentation.
It might be I
l 11 acceptable for this particular application, but I'll have to 12 let him make a decision on it.
13 MR. COLITZ:
We decided 8:00 tomorrow morning here?
l 14 MR. THOMPSON:
8:00 tomorrow morning, and we will be l
15 in the room originally scheduled, P-114, which is next door.
~
l 16 We'll verify that in the morning when we get here.
There 17 should be a published schedule of rooms that will be up in the 18 morning.
Eight o' clock, that sounds good.
And I will call l
e 19 this meeting closed.
20
[Whereupon, at 5:25 o' clock, p.m.,
the meeting was 21 recessed, to resume at 8:00 o' clock, a.m.,
- Thursday, I
22 September 5,
1985.3 i
23 c.
24 q;,
25 l
L
1 CERTIFICATE OF OFFICIAL REPORTER 2
3 5
This is to certify that the attached proceedings 6
before the United States Nuclear Regulatory Commission in the 7
matter of' 8
9 Name of proceeding: Meeting on TMI 1 In-Service Testing - Pumpo and Valves Review of Second 10-Year Program 10 11 Docket No.
12 place: Bethesda, Maryland 13 Date: Wednesday, September 4, 1985 14 15 were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 17 Regulatory Commission.
13 (Signature)
.. f g
y, f
i (Typed Name of Reporter)
Mimie Meldzar 20 21 22 23 Ann Riley & Associates. Ltd.
24 25
.