ML20210N687

Summarizes 861209-10 Meetings W/Util & Eg&G in Bethesda,Md Re Pump & Valve Inservice Testing Program.Encl Eg&G Trip Rept Discusses Conclusions

ML20210N687
Person / Time
Site:	Clinton
Issue date:	02/06/1987
From:	Butler W Office of Nuclear Reactor Regulation
To:	Spangenberg F ILLINOIS POWER CO.
References
NUDOCS 8702130190
Download: ML20210N687 (44)

Text

'

. o February 6, 19G7 Docket No.: 50-461 Mr. Frank A. Spangenberg Manager-Licensing and Safety Clinton Power Station P.O. Box 678

-Mail Code V920 Clinton, Illinois 61727

SUBJECT:

INSERVICE TESTING PROGRAM (IST) MEETING

SUMMARY

As you are aware on December 9 and 10, 1986, the NRC staff, NRC contractors from EG&G and Illinois Power Company staff met in Bethesda, Maryland to discuss questions resulting from the staff's review of the Clinton Power Station pump and valve IST program.

The conclusions reached at this meeting are contained in the enclosed trip report which was prepared by our EG&G contractors.

If you have any questions related to this trip report please contact the Project Manager for your plant, Byron Siegel (301-492-9474).

Sincerely, Orldnal. Signed by

} R Oarus o l Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing

Enclosure:

As Stated cc w/o enclosure: HShaw BDLiaw DISTRIBUTION JDocket File BGrimes NRC PDR ' JPartlow Local PDR NThompson PDf4 Rdg. BSiegel RBernero M0'Brien Pirfo, 0GC ARCS (10)

EJordan ,A PD#4/P BSieg 1:ca P

E6/d

,"WBb t'l'e r 02/rf,/87 02/ 87 8702130190 DR 870206 ADOCK 05000461 PDR

c . -

l Mr.' Frank A. Spangenberg- Clinton Power Station Illinois Power Company Unit 1

-cc:

Mark Jason Mr. R. C. Heider Assistant Attorney General Project Manager Public. Utilities Division Sargent & Lundy Engineers

~0ffice of the Attorney General 55 East Monroe Street State of Illinois Center Chicago, Illinois 60603 100 West Randolph Street - 12th Floor Chicago, Illinois 60601 Mr. L. Larson Project Manager Mr. D. P. Hall General Electric Company Vice President . 175 Curtner. Avenue, N/C 395 Clinton Power Station San Jose, California 95125 P. O. Box 678

.Clinton, Illinois, 61727 Regional Administrator, Region III 799 Roosevelt Road Mr.~ John Greene Glen Ellyn, Illinois 60137 Manager-Nuclear Station Engineering Dpt.

Clinton Power Station Richard B. Hubba'd P. 0.~ Box 678 Vice President

-Clinton, Illinois 61727 Technical Associates 1723 Hamilton Avenue - Suite K Sheldon Zabel, Esquire San Jose, California 95125 Schiff, Hardin & Waite 7200 Sears Tower Chairman of Dewitt County 233 Wacker Drive c/o County Clerk's Office Chicago, Illinois 60606 DeWitt County Courthouse Clinton, Illinois 61727 Resident Inspector U.-S. Nuclear Regulatory Commission Illinois Department of Nuclear Safety RR 3, Box 229 A Division of Engineering Clinton, Illinois- 61727 1035 Outer Park Drive, 5th Floor Springfield, Illinois 62704

EGsG id:ha NOTEGRAM Ce value inteytty and spea communicaten.

,["j " Date January 9. 1987 g Horace Shaw From C. B. Ransom M Org, NRC/ DBL /EB org.

Addr:ss Reth.ea2 un Address

• TRIP REPORT FOR THE PUMP AND VALVE INSERVICE' TESTING PROGRAM WORKING MEETING FOR THE CLINTON POWER STATION On December 9 and 10, 1986, a working meeting was held at the NRC offices in Bethesda, Maryland with Illinois Power Company, NRC, and EG8G Idaho, Inc. representatives to discuss the questions resulting from the review of the Clinton Power Station pump and valve inservice testing (IST) pogram.

Attached is a list of the meeting attendees, the questions that served as an agenda for the meeting, and the responses to those quotions as taken from the meeting minutes and the written responses provided by Illinois Power Company. The utility representatives were given a brief introduction outlining the agenda and the methods used for the documentation of questions and responses. This was followed by detailed .

discussions concerning specific pumps and valves in the Clinton Power Station IST program.

Those discussions resulted in an action item for the NRC staff and 16 action and 2 open items for Illinois Power Company (action items are areas where the utility and the NRC are in agreement but additional action is required in order to close out the item). These action and open items are identified in this trip report. There are several additional items where the utility has agreed to make corrections or changes to their IST program as indicated in the responses to the questions, tjs

Attachment:

As Stated cc: E. C. Anderson J. J. Lombardo, NRC/ DBL /EB H. L. Magleby C. F. Obenchain C. B. Ransom H. C. Rockhold B. Siegel, NRC/ DBL /PD4

i 1

l ATTENDANCE LIST CLINTON POWER STATION l PUMP AND VALVE INSERVICE TESTING PROGRAM WORKING MEETING Dates: December 9 and 10, 1986 Name Representing Horace Shaw NRR/ DBL /EB Jim Lombardo NRR/ DBL /EB Byron Siegel NRR/ DBL /PD4 Doyle Wilson Illinois Power Company Jeff Weaver Illinois Power Company Roger Morgenstern Illinois Power Company Richard Bichel Illinois Power Company Mirza Baig Illinois Power Company ,

Robert Kerestas Illinois Power Company Partho Raysiccar Illinois Power Company Herb Rockhold EG&G Idaho Inc.

Clair Ransom EG8G Idaho Inc.

I I

l l

- ~ -- . . . . ...... . .. .

CLINTON POWER STATION PUMP AND VALVE INSERVICE TESTING PROGRAM OUESTIONS AND COMMENTS I. VALVE TESTING PROGRAM A. General Ouestions and Comments

1. Provide a listing of the limiting values of full-stroke time for all power operated valves in the Clinton IST program for our review.

Response: A table with limiting values of full-stroke times has been provided for all power operated valves in the Clinton IST program.

2. Are all valves that are Appendix J. Type C, leak-rate tested included in the Clinton IST program?

Response: All valves that are Appendix J. Type C, leak-rate tested (except vent valves, drain valves, manual isolation valves, etc. which are exempt per Section XI, Paragraph IWV-1200) will be included in the Clinton IST program as Category A or A/C valves. Some containment isolation valves are leak-rate tested with water (Type 8) and will also be included in the IST program.

3. The NRC has concluded that the applicabie leak test procedures and requirements for containment isolation valves are determined by 10 CfR 50 Appendix J, however, the licensee must comply with the Analysis of Leakage Rates and Corrective Action Requirements paragraphs of Section XI, IWV-3420 (f) and 3420(g). Does the current Clinton IST program meet this NRC staff position?

Response: Clinton Power Station (CPS) will comply with the Analysis of Leakage Rates and Corrective Action Requirements of Section XI IWV-3426 and 3427 (1980 Edition of the Code) except as modified 1

,, f.

a by'reitef request 056. Request 056 seeks relief from the i requirement to assign a leak-rate limit to each sp'ecific  ;

containment isolation valve and proposes instead to assign a i limit to each penetration. The staff finds the basis for requesting this reitef and the proposed alternate testing to be acceptable. l 4

4. Do the following valves receive an Appendix J 1eak rate test to verify their ability to perform a containment isolation function 7 If so, they should be categorized A or A/C as appropriate and be identified in the IST program as receiving a valve seat leakage test (Method of Testing 3 from Table 3.3-1).

System Valves Component Cooling Water System ICC049 1CC050 ICC053 1CC054 1CC057 1CC060 ICC071 1CC072 1CC073 1CC074 1CC127 1CC128 Containment Monitoring System ICM011 1CM012 1CM022 1CM023 1CM025 1CM026 ICM047 1CM048 Cycled Condensate System 1CY016 1CY017 Control Rod Drive System 1C11-F083 1C11-F122 Residual Heat Removal System 1E12-F004A 1E12-F0048 1E12-F011A 1E12-F0118 1E12-F021 1E12-F024A 2

. .z. .

, 9 System Valves Residual Heat Removal System 1E12-F0248 (continued) IE12-F027A 1E12-F0278 1E12-F028A 1E12-F0288 IE12-F037A 1E12-F0378 IE12-F046A IE12-F0468 IE12-F046C IE12-F064A 1E12-F0648 IE12.F064C IE12-F074A 1E12-F0748 1E12-F105

. Low Pressure Core Spray System 1E21-F001 1E21-F012 1E21-F303 IE21-F340 High Pressure Core Spray System 1E22-F012 1E22-F015 IE22-F023 1E22-F304 Leakage Detection System 1E31-F014 1E31-F015 IE31-F016 1E31-F017 IE31-F018 1E31-F019 Reactor Core Isolation Cooling System 1E51-F019 1E51-F031 1E51-F063 1E51-F064 IE51-F068 1E51-F076 IE51-F078 1E51-F316 fuel Pool Coo 11ng and Cleanup System IFC007 IFC008 1FC036 1FC037

. . 3

j System Valves Fire Protection System 1FP050 IFP051 1FP052 IFP053 IFP054 1FP092 Reactor Water Cleanup System 1G33-F028 1G33-F034 1G33-F039 1G33-F040 1G33-F053 1G33-F054 Combustible Gas Control System 1HG001 1HG004 1HG005 1HG008 Instrument Air System IIA 005 IIA 006 11A012A 11A0128 11A013A 11A0138 11A042A 11A0428 Makeup Condensate System OMC009 OMC010 Process Sampilng System IPS004 IPS005 1PS009 IPS010 1PS016 IPS017 IPS022 IPS023 IPS031 iPS032 IPS034 IPS035 1PS037 IPS038 19S047 4

IPSO 48 1PS055 19S056 1PS069 1PS070 1

i 4 i

o ,-

System Valves Breathing Air System ORA 026 ORA 027 ORA 028 "

ORA 029 Equipment Drain System 1RE021 -

1RE022 -

Floor Drain System 1RF021 1RF022 Service Air System ISA029 1SA030 Suppression Pool Cleanup System ISF001 -

ISF002 ISF004 Shutdown Service Water System ISX088A ISX0888 ISX089A ISX0898 ISXO96A ISX0968 ISX097A ISX0978 Drywell Cooling System IVP004A IVP0048 IVP005A IVP0058 IVP014A IVP0148 IVP015A IVP0158 Orywell Purge System '1VQ004A IVQ0048 IVQOO6A IVQ0068 Containment Ventilation System IVR001A IVR0018 IVR002A 1VR0028 IVR035 IVR036 IVR040 IVR041 5

'e ' -

. , - .- l System _ Valves l

Chilled Water System 1W0001A 1W00018 IW0002A  !

IW00028 Solid Radwaste System IWX019 IWX020 Response: As stated in the response to I.A.2 above, all valves that are Appendix J, Type C, leak-rate tested will be included in the IST program as Category A or A/C valves (except those valves that are exempt per IWV-1200). This applies to all of the above listed valves except the following, which are not I currently tested as containment isolation valves.

ICC057 IE21-F303 1E31-F014 1CC128 IE21-F340 IE31-F015 1E12-F046A 1E22-F304 1E31-F017 1E12-F0468 IE51-F316 1E31-F018 -

1E12-F046C ORA 028 ORA 029

5. Are any valves at Clinton Power Station currently leak-rate tested to verify a pressure boundary isolation function? Those va'1ves that serve both a pressure boundary isolation function and a containment-isolation function must be leak tested to both the Appendix J and  ;

Section XI requirements.

, Response: All valves that are identified in the Clinton plant Technical Specifications as pressure boundary isolation valves are included in the IST program as Category A or A/C valves. Any of these valves that also perform a conta. ament isolation function are leak-rate tested to both the Appendix J and the Technical Specification requirements for pressure isolation valves.

6

o o* .

6. The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise during plant operation and these valves are specifically identified by the licensee and are full-stroke exercised during cold shutdowns. The staff requires that the licensee provide a technical justification for each valve that cannot be exercised quarterly during power operation that clearly explains the difficulties or hazards encountered during that testing. The staff will then verify that it is not practical to exercise those valves and that the testing should be performed during cold shutdowns. Cold shutdown testing of Valves identified by the licensee is acceptable when the following conditions are met:

a. The licensee is to commence testing as soon as the cold shutdown condition is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or the plant is ready to return to power.

b. Completion of all valve testing is not a prerequisite'to return to power.

! c. Any testing not completed during one cold shutdown should be performed daring any subsequent cold shutdowns starting from 1

the last test performed at the previous cold shutdown.

l d. for planned cold shutdowns, where ample time is available and testing all the valves identified for the cold shutdown test frequency in the IST program will be accomplished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.

j Does the Clinton IST program conform to this staff position for all valves tested on a cold shutdown frequency?

Response: Valves that cannot be exercised during power operations which ar'e tested during cold shutdowns will be specifically identified in the IST program and a justification for this test l

7 C-

frequency will be provided. Clinton will perform the cold shutdown testing in accordance with the above guidelines. When valve testing cannot be performed during power operations or cold shutdown, a specific request for relief will be provided.

7. The Clinton IST program valve listing table does not identify the -

testing frequency for each individual valve. Therefore, it was assumed that unless indicated otherwise in a comment or a relief request, the tests are performed at the Code specified frequency of once every 3 months for tests 1, 2, and 7; at refueling outages but not less than once every two years for test 3; and in accordance with Table 3510-1 for test 5. Does the Clinton IST program conform to these Code requirements?

Response: Revision 1 of the Clinton Power Station Inservice Pump and valve Testing Program, dated November 1985, clarified that the valve testing frequencies are in compliance with the Section XI requirements.

8. Many Clinton IST program relief requests specify that the valves will be exercised "during cold shutdown or refueling outages." The use of the word "or" implies that an option exists for the frequency of performing the testing. for valve testing purposes, the NRC differentiates between the cold shutdown mode and the refueling cutage mode. That is, for valves identified for testing during cold shutdowns, it is expected that the tests will be performed both during cold shutdowns (in accordance with the Staff positions in A.6 above) and during each refueling outage. However, when relief is granted to perform tests on a refueling outage frequency, testing is expected only during each refueling outage. .a addition, for extended outages, tests being performed are expected to be maintained as closely as

, practical to the Code-specified frequencies.

8

for the purposes of this review, when the alternate testing specified

" cold shutdown or refueling outages" it was assumed that the testing was to be performed on the cold shutdown frequency and the word "and" was substituted for "or" in the relief requests. Specifically identify any cases where this assumption is not correct and provide a technical justification for not exercising the involved valves during cold shutdowns.

4 Response: Revision 1 of the Clinton IST program deleted the usage of the phrase "during cold shutdowns or refueling outages" in the i program relief requests.

I~

9. Are remote position indicators being verified in accordance with the requirements of Section XI, IWV-3300 for all applicable valves. in the l Clinton IST program?

Response: All remote position indicators will be tested every 2 years as required by the Code.

i

10. When flow through a check valve is used to indicate a full-stroke exercise of the valve disk, the NRC staff position is that verification of the maximum flow rate identified in any of the plant's -

safety analyses through the valve would be an adequate demonstration of the full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differential pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve. Does the

1inton IST program conform to this staf f position?

Response: Where flow through a check valve is utilized to verify full-stroke capability, the maximum flow rate uttitzed in the safety analysis will be the flow rate used. Where this flow rate cannot be achieved, the valve will be considered to be 9

= - - .

, n -

. n; - - -

-- 77

, 7 partial-stroke exercised. Mechanical exercising of a check valve-is also an acceptable method for full-stroke verification either by utilizing a mechanical exerciser or by disassembly and inspection. CPS will review all instances of proposed partial-stroke exercising of check valves and modify the affected relief requests where necessary.

11. If a manual operator is used to full-stroke exercise check valves that cannot be full-stroke exercised with flow, is the force or torque that is applied to the mechanical exerciser measured to assure compliance with IWV-3520(b)(2)7 Response: When a manual operator is used to full-stroke exercise a check valve, the torque or force required to stroke the valve will be measured and compared to acceptance criteria.

4

12. The NRC staff position is that the emergency diesel generators perform a safety-related function and that the appropriate valves in the emergency diesel air start, cooling water and fuel oil transfer systems should be included in the IST program and be tested in accordance with the Code. Engine mounted pumps are considered to be l part of the diesel and need not be tested separately.

Response

Revision 1 of the Citnton IST program included the following emergency diesel generator system valves:

1 10G007E 10G008E 100001A

!~

10G007F 10G008f 1000018 10G008A 10G008G 100001C

! 10G0088 10G008H ISX006C 10G008C 10G008J ISX063A 10G0080 10G008K ISXO638 i

Section H of this report contains specific questions and responses concerning diesel generator subsystem valves.

10

- r -e. -.--.m. , --, ..%.,yy,- ,. - __.w,--,e y,,--.._n.--..,-,.-- ,.,.,~,w ,wr,.- y-,w _,,,,,y-e-, ym_ , -e-.--%,,, , .. . ,g- ,- ,-._,w ,,--w,--

13. Do the valves identified in Table 200-1 in relief request 200 perform safety related functions? If they do, they should be included in the valve listing table of the IST program and be tested in accordance with the Section XI requirements (stroked, stroke timed, fail-safe -

tested, position verification tested, etc., as applicable) unless

. specific relief is requested for individual valves or groups of valves in similar applications.

Response: Revision 1 of the Clinton IST program deleted relief request 200. Some of the valves on Table 200-1 were included in the valve listing table of Revision 1 of the Clinton IST program. Some of the valves from Table 200-1 perform no safety function and were deleted from the Clinton program in Revision 1. The following valves perform a safety function and will be included in the IST program.

1FC018A IFC020A IFC022A 1FC0188 1FC0208 1FC0228 1FC073 IFC077 IFC096

14. IWV-3412 states that if only limited operation of a valve is practical during plant operation, the valve should be part-stroke exercised during plant operation and full-stroke exercised during cold shutdowns. Does the Clinton IST program comply with this Code requirement? If so, identify. those valves that receive a partial-stroke exercise. For valve testing purposes, the NRC differentiates between the cold shutdown mode and the refueling outage mode. That is, for valves identified for testing during cold shutdowns, it is expected that the tests will be performed both during cold shutdowns (in accordance with the Staff positions in A.6 above)

! and during each refueling outage. However, when relief is granted to i perform tests on a refueling outage frequency, testing is expected only during each refueling outage. In addition, for extended outages,

tests being performed are expected to be maintained as closely as practical to the Code-specified frequencies.

4 i

11 i

-. -- c_---..-...--,_.ww..-w..,,..i_..-..._.. ,-m~, .m,,,, .,.w -,- -- ..--....m,-,~,,.

.. ..

. -. .. ~ , . - . .

Response: Clinton Power Station will review their valve testing program to verify that this Code requirement and staf f position is met or specific relief will'be requested.

B. Main Steam System

1. Are valves F022A through 0 and F028A through D full-stroke exercised quarterly during power operations? If not, describe the testing that is performed and provide either a cold shutdown justification or a relief request for these valves.

Response: These valves cannot be full-stroke exercised quarterly during power operation since repeated closure during plant operation would result in degradation of the seating surfaces of these containment isolation valves. Also, closure during ft11 power operation could result in a plant trip due to steam flow imbalance. Thes'e valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdowns.

2. Do valves F022A through D and F028A through 0 have a required fail-safe position? If so, their fail-safe operation should be verified quarterly by performing test 7.

Response: These valves are fail-safe tested during the cold shutdown exercising mentioned in the response to question 8.1 above.

3. Define what is meant by " extended cold shutdown" in relief requests 015 and 016. If these valves are not tested on a cold shutdown frequency as described in A.6 and A.8 above then the detailed technical justifications for not testing these valves during cold shutdowns should be included in the relief requests.

Response: Revision 1 of the Clinton IST program deleted the phrase

" extended cold shutdown."

12

^

4. Provide the detailed technical justification for not exercising the valves listed in relief request 042 during cold shutdowns.

Response: Relief request 042 will be revised to discuss the consequences of failure of these check valves during power operation. These valves will be exercised closed during cold shutdowns.

5. The safety relief valves that also perform the ADS function should be categorized 8/C in the IST program and be exercised in accordance with Section XI as Category 8 power operated valves to verify their ability to perform the ADS function as well as the safety relief valve

[ function. Which main steam safety relief valves perform the ADS function 7 Response: The ADS valves are 1821-F0418, C, D, and F; 1821-F047A and C; and 1821-F051G. These valves will be categorized 8/C and will be full-stroke exercised on a refueling outage frequency.

These valves,cannot be exercised quarterly during pow'er operations because failure of a valve in the open position a

would place the plant in a LOCA condition. These valves should not- be exercised during cold shutdowns in order to reduce the number of challenges to safety / relief valves as recommended by i NUREG-0737 and a recent study on the subject (8WR Owners Group Evaluation of NUREG-0737 Item II.K.3.16 Reduction of Challenges f and failure of Relief Valves).

i It is ACTION ITEM for CPS to determine if repeatable and representative stroke times can be measured for the ADS valves which would allow for evaluation of valve degradation.

l i

j 6. Since the upstream MSIVs are exercised quarterly, provide the l justification for not exercising valves 1821-F098A, 8, C, and D

\

quarterly during power operation.

l w 13'  ;

1 i_ _ . _ _ _ _ _ _ _ _

Response: Revision 1 relief request 053 states that the MSIVs will be b partial-stroke exercised quarterly during power operations and full-stroke exercised quarterly during cold shutdowns.

Valves 1821-F098A, 8, C, and 0 are not designed to be partial-stroked.

These valves will be full-stroke exercised i-during cold shutdowns for the same reasons as given for the i- MSIVs in relief request 053. These valves are currently being reviewed to determine if they perform any safety function.

7. Do valves 1821-F021, F033, F068, and F069 (M05-1002/2 Coordinates 8-4, C-4, 0-4, and 0-4 respectively) perform any safety related function?

Response: Valves 1821-F021, F033, F068, and F069 do not perform any safety function and need not be included in the Clinton IST

! program.

8. Relief request 001 identifies the reason that it is impractical to exercise the listed valves during plant operation and then states that j the valves are to be exercised during refueling outages. IWV-3412(a) l requires that valves that cannot be exercised during plant operation should be specifically identified by the owner and should be full-stroke exercised during cold shutdowns. Unless a specific l technical justification is provided for not exercising these valves l during cold shutdowrs, they must be exercised at that frequency as descrised in IWV-3412(a) and in A.6 above.

i i

Response: This is an ACTION ITEM for CPS to determine if valves 1821-F010A, F0108, F032A, and f 0328 can be exercised closed

, during cold shutdowns.

4

9. Are valves 1821-F001 and F002 ever required to change position in

order to mitigate the consequences of an accident, shutdown the

[ reactor to the cold shutdown condition, or to perform any other safety

! related function? If so, they are active valves and must be exercised i

a

{

14

,,--n-- - - . - - -.--. .,we -. .,,-w,-mvewn. .,~.,.r. ,--rn.,awwm.--,-,----_

and have their stroke times measured quarterly in accordance with the Code. If not, they should be identified as being passive valves in the IST program.

Response: These are passive valves that are not required to change position in order to perform any safety function. These and all other passive valves will be specifically identified as being passive in the IST program.

10. Provide the technical justification for not exercising the valves listed in relief request 003 during cold shutdowns.

Response: Valves 821-F037 A-H, J-N, P, R, S; B21-F078 A-H, J-N, P R S; 821-F379 A-H, J-N, P, Q, R and 821-F040, the safety relief valve discharge and vent line vacuum breakers, are inside containment and cannot be exercised during plant operations.

It is an ACTION ITEM for CPS to determine if these valves can be exercised during cold shutdowns.

11. Provide the technical justification for not exercising valves 1821-F065A and 8 during cold shutdowns (see relief request 004).

Response: It is an ACTION ITEM for CPS to determine if valves 1821-F065A and 8 can be exercised during cold shutdowns.

C. Reactor Recirculation System

1. Do valves 1833-F019 and F020 have a required fall-safe position? If so, the fail-safe position for these valves should be verified in accordance with IWV-3415.

Response: Valves 1833-F019 and F020 will be fail-safe tested to the Code requirements.

15

. .; ,, . ., . . - . = . - - u -

2. Are valves 1833-f 013A, f 0138, f 017A, and f 0178 Appendix J 1eakrate tested? If so, they should be included in the IST program as Category A/C valves.

Response: These valves are not currently Appendix J, Type C, leak-rate tested and need not be included in the IST program.

D. Component Coolina Water System

1. What is the safety related function of check valves 1CC188A and 18887 If the safety function is to close, how are these valves verified in the closed position quarterly?

Response

Valves 1CC188A and 1888 do not perform a safety function and need not be included in the IST program.

2. Do valves ICC065, 067, 068 and 070 perform any safety related function? If so, they should be included in the IST program as Category 8 valves.

Response: Valves ICC065, 067, 068, and 070 do not perform any safety function and need not be included in the IST program.

3. Provide the technical justification for not exercising the valves Itsted in reitef request 019 during cold shutdowns.

Response: It is an ACTION ITEM for CPS to determine if the valves in relief request 019 can be exercised during cold shutdowns.

4. Provide the technical justification for not exercising the valves listed in relief request 036 during cold shutdowns.

Response: The valves identified in reitef request 036 perform no safety function and need not be included in the IST program. Relief request 036 will be deleted.

i 16

..; 1 . , - .- .=.. - . ..

o'- .-

5. Provide the P&IO (M05-1032/2) that shows valves 1CC075A, 0758, 076A, and 0768 for the staff's review.

Response: P&ID M05-1032/2 was provided.

E. Containment Monitorina System

1. How are excess flow check valves ICM002A, 0028, 003A, and 0038 tested and at what frequency are they tested?

Response: Excess flow check valves 1CM002A, 003A, and 0038 are exercised quarterly using an air flow test to verify that they will close to restrict excessive flow. Valve ICM0028 will be tested during refueling outages because this valve is 8 feet below I-normal suppression pool level and testing would require a diver l to enter the suppression pool or lowering the pool level 8 feet, either of which cannot be performed quarterly during power operations and is not practical to accomplish during cold shutdowns (Refer to relief request 037).

2. Are the valves listed in relief request 032 passive valves as defined l in IWV-21007 If so, they should be identified as such in the IST

! program. If not, thay should be exercised and have their stroke times measured in accordance with the Code.

i The purpose of measuring valve stroke times in the'IST program is to detect valve degradation to allow for repairs of degraded valves prior to their failure, and not for any functional or accident mitigation reasons as indicated in relief request 032.

Solenoid operated valves are not exempted from the stroke time I measurement requirements of Section XI: their stroke times must be measured and corrective action taken if these times exceed the limiting value of full-stroke time. The NRC staff will grant relief

(

i l

17 l

l

,1 _

from the trending requirements of Section XI (Paragraph IWV-3410 (c)(3)] for these rapid acting valves, however, in order to obtain this relief the licensee' must assign a maximum limiting stroke time of 2 seconds to these valves.

i Response: A request for relief from the stroke time trending requirements for rapid acting solenoid valves which have a limiting value of full-stroke time of 2 seconds or less will be submitted (Relief request 058). The stroke times of these rapid acting valves will be measured, but need not be trended. If the 2 second li.aiting stroke time is exceeded, the degraded valve must be declared inoperable and corrective action taken. Relief request 032 will be deleted from the IST program.

3. Provide a more detailed technical justification for not exercising valves ICM066 and 067 quarterly or during cold shutdowns. Also, provide the P&ID that shows valve ICM067 for the staf f's review.

Response: The reitef request for ICM066 and 067 will be deleted. Valves 1CM066 and 067 will be exercised quarterly, or a cold shutdown justification will be provided and the valves tested during cold shutdowns. The P&ID was provided.

F. Cycled Condensate System

1. Review the safety related function of valves 1CY020 and 02) (P&ID M05-1012/6 coordinates 0-3 and D-2, respectively) to determine if they should be included in the IST program and be categorized A.

Response: Valves 1CY020 and 021 are drywell isolation valves and are included in the IST program as category 8 valves. Their safety function is to close on a containment isolation signal.

18

. ,, x .. :

e

\ r

. ~

G. Control Rod Drive System e

1. It is the NRC staf f position that ,the hydraulic control unit air operated valves 126 and 127 and check valves 114, 115, and 138 (145 of S. ii each valve) perform a safety related function and must be included in the IST program and be tested in'accordance with the requirements of Section XI.

t Response: Hydraulic control unit valves 126,127,114 and 138 (145 of each) will be included in the IST program and be exercised as stated in relief request 059.

It is an OPEN ITEM for CPS to further evaluate the safety function of hydraulic control unit valve 115 (one valve in each of the la5 Hcus) tofdetermine if they should be included in the IST program. ,

i

2. Provide the P&ID that showr.,the scram discharge volume piping. Any 5

v .

valve that is required to operate in order to allow rapid insertion of the control rods must be included"in the IST program.

i Response: The P&ID was provided. There are no additional valves associated with the scram discharge volume that affect insertion of the control rods.

1 i 3. Provide the P&l0 that shows valves IC11-F010 F011, F180, and F181 for the staff's review. i i

^

( i l

Response: The P&ID was provided. The stroke times will be measured for these valves. ,

4. Provide the technical justification for not exercising valves 1C11-F083 and F122 during cold shutdowns (see relief requests 008 and 010).

l 19 0

Response: Valve 1C11-F083 will be exercised and have its stroke times measured during cold shutdowns and relief request 008 will be j modified. l It is an ACTION ITEM for CPS to determine if valve 1C11-F122 can be exercised during cold shutdowns. CPS will provide a detailed justification for not exercising this valve to the Code requirements.

H. Standby L'iouid Control System

1. Define " extended cold shutdowr," as used in relief request 011.

Response: Revision 1 of the Clinton IST program deleted the phrase

" extended cold snutdown." CPS will modify relief request 011 7 by adding a discussion of the consequences of testing these valves during cold shutdowns and injecting boron into the reactor vessel. Valve IC41-F336 will also be included in this j relief request.

2. Provide P&ID M05-1077 for our review.

J J

Response: P&ID M05-1077 was provided.

Are any of the valves in the standby liquid control system leak rate l 3.

1 tested in accordance with Appendix J requirements to verify their +

ability to perform a containment isolation function?

Response: The only valves that are Appendix J 1eak-rate tested in this -

system are vent and drain valves which are exempted from the

-IST program by IWV-1200.

! 4. Does valve 1C41-F007 receive an Appendix J 1eak-rate test? If so, It should be included in the IST program as a category A/C valve.

Response: Valve IC41-F007 is not Appendix J, Type C, leak-rate tested.

0 20

~ ~ ~... .

a . . . . :. . . . - - . . . . . . .  :..

I. Diesel Generator Startina Air System

1. Do valves 10G007A through 007K have a required fall-safe position? If not, they may be exempt from Section XI testing per IWV-1200(a).

Response: Valves 10G007A through 0 and G through K have been removed from the system. Valves 10G007E and F are exempt from IST testing per IWV-1200(a) and, therefore, need not be included in the IST program.

2. Review the safety related function of the following check valves to determine if they should be included in the IST program.

Valve P&ID Coordinates Valve P&IO Coordinates l

10G168 M05-1035/1 E-7 10G171 M05-1035/2 C-7 10G169 M05-1035/1 C-7 10G172 M05-1035/3 E-7 10G170 M05-1035/2 E-7 10G173 M05-1035/3' C-7 i

Response: It is an ACTit1 ITEM for CPS to evaluate the safety function of these check valves to determine if they should be included in the IST program.

3. The pump and valve in-service testing program is set up to test individual components in order to provide a reasonable assurance of their capability to perform thelf safety related function. A system ,

test provides information about a system's performance, but may not -

provide information about degradation or failure of individual components in that system where redundant flow paths exist.

Therefore, the individual component test is necessary, in addition to l the system testing, unless the system testing is set up to individually check the operation and condition of the various system components.

l 21 l

. ~ ^ 1..

~ ~

,. . - - . , _ . . . , . Z:

Does the diesel generator surveillance test verify operation of each individual air start valve or are they tested in pairs? Does the proposed alternate testing provide a quantitative means to determine ,

individual valve degradation?

Response: It is an ACTION ITEM for CPS to further investigate a test method for verification of operability of the diesel air start-valves.

NOTE: It is an ACTION ITEM for the NRC to provide written direction to CPS for inclusion of emergency diesel generator subsystems in the IST program.

J. Residual Heat Removal System

1. How is check valve lE12-F098 full-stroke exercised open quarterly l

during power operation 1 Response: Check valve IE12-F098 is exercised quarterly using a mechanical j

exerciser in accordance with the Code.

2. What is the safety related function of check valves lE12-F103A, F1038 F104A, and F10487 If these valves perform a safety function in the closed position, how is each valve individually verified to close?

l Response: Check valves 1E12-F103A, F1038, F104A, and F1048 provide vacuum relief on vent paths to the suppression pool for portions of systems in which condensing or cooling of a fluid can cause a l

negative pressure, but they do not perform a safety function in l

' the closed position.

l

3. Is credit taken for the RCIC steam condensing mode of operation in any of the Clinton accident analyses? Review the safety related function of valves IE12-F051 A, F0518, F052A, F0528, F065A, and F0658 (P&ID M05-1075/4) to determine if they should be included in the IST program and be categorized 8.

l 22

7 .. . . . . - . - . . . _ . . ..

Response: The steam condensing mode of operation is not used for safety grade shutdown at Clinton. Valves IE12-F051A, F0518, F052A, F0528, F065A, and F065B perform a safety function in the closed  :

position to allow LPCI operation and will be included in the i IST program as category B valves. Valves 1E12-F087A and F0878  !

i will also be included in the IST program as category B valves. l

4. Review the safety related function of solenoid operated

• valve IE12-F095 to determine if it should be included in the IST program. ,

Response: The safety function of valve 1E12-F095 is to close on an open signal to valves 1E12-F094and F096 and it, therefore, will be included in the IST program'.

5. How is cneck valve 1E12-F019 full-stroke exercised quarterly during power operation?

Response: Valve 1E12-F019 is full-stroke exercised during cold shutdowns utilizing a mechanical exerciser. A cold shutdown justification will be provided to explain why this valve cannot be exercised quarterly during power operations.

6. Will the air operators full-stroke exercise testable check valves 1E12-f041A, B, and C7 If not, how are these valves full-stroke exercised?

I Response: The air operators on valves 1E12-F041A, 8, and C do not full-stroke exercise the valve disks. It is an ACTION ITEM for CPS to determine a method and frequency for full-stroke exercising these check valves.

7. How are valves 1E12-F046A, B, and C verified to full-stroke exercise during the quarterly testing?

I r

l

23 l

^ ~

. . . . . . . . .. .. - . . _ . . .~

Response: Valves 1E12-F046A, B, and C are full-stroke exercised utilizing a mechanical exerciser in accordance with the Code.

't

8. Do check valves 1E12-F084A, F0848, F084C, F085A, F0858, and F085C perform a safety related function in the closed position? If so, how are these valves individually verified to close?

Response: Valves 1E12-F084A, 8, C, and 1E12-F085A, 8, C perform safety related functions in both the open and the closed positions.

The open requirement is to allow the water leg pump to fill the discharge lines of the RHR pumps and the closed requirement is to protect the low pressure piping of the water leg pump during operation of the RHR pumps. The open requirement is verified by observation'that the " low discharge pressure" alarm on Panel 1H13-P601 is cleared. It is an OPEN ITEM for CPS to further I evaluate a method and frequency for individually verifying .

closure of these valves.

4

9. Provide the P& ids that show valves 1E12-F052A, F0528, F100A, and F1008; they do not appear in the P&IO locations indicated in the l

Clinton IST program on the drawings provided.

Response: Valves 1E12-F100A and 8 have been replaced by valves 1E12-F110A and 8. The P&ID that shows these valves and valves 1E12-F052A f

l and 8 was provided.

I

(

10. Review the safety related functions of valves 1E12-F301A, 8, and C to determine if they should be included in the IST program.

Response: Valves E12-F301 A, 8 and C do not perform any safet*j function.

These valves need not be included in the IST program.

(

11. Provide a more detailed technical justification for not exercising the valves listed in relief request 054 quarterly during power operations or during cold shutdowns.

f

24

s..

. ..- , . , . . . . . . . ~ . -----~ --- ----- :; . T.;, .: :

Response: It is an ACTION ITEM for CPS to further. evaluate the valves identified in relief request 054 to determine if they can be exercised during cold shutdowns.

12. Review the safety related function of valves lE12-f037A and F0378 to determine if they should be included in the IST program.

Response: Valves 1E12-f037A and 8 will be included in the IST program as Category B valves and tested to the Code requirements.

13. Relief was requested from measuring stroke times for the solenoid operated valves listed in relief request 045, but no alternate means of quantitatively determining valve degradation has been proposed.

Solenoid operated valves are not exempt from stroke time measurements, however, some allowances are made for these rapid acting valves as explained in item E.2.

Response: The valves listed in relief request 045 will be identified as

[ rapid acting valves in relief request 058 and will have their stroke times measured. In accordance with the NRC staff's position on rapid acting valves, these valves have been assigned limiting values of full-stroke times of 2 seconds and will be exempt from the stroke time trending requirements.

K. Low Pressure Core Sprav System

1. Will the air operator on testable check valve lE21-f 006 full-stroke exer:1se the valve? If not, how is this valve full-stroke exercised?

Response: The air operator does not full-stroke exercise this testable check valve, however it will be used.to partial-stroke exercise this valve during cold-shutdowns. It is an ACTION ITEM for CPS to determine a method and frequency to full-stroke exercise this check valve.

25

^^'

- . . . ... : -... .- c . . . . , - . ~ . . . . . . .

4

2. Are there any interlocks (i.e. RCS pressure >135 psig) that would prevent a full-stroke exercise of valve IE21-F005 quarterly during power operation?

, Response: This valve performs a pressure boundary isolation function and cannot be opened during power operations due to a pressure interlock with the RCS (It cannot be opened when RCS pressure is above 484 psig). CPS will further evaluate full-stroke exercising this valve during cold shutdowns.

3. How are valves 1E21-F033 and F034 individually tested to verify their safety related function in the closed position?

Response: IE21-F033 and F034 are series check valves in the water leg keep fill lines which are similar to the valves discussed in Item J.8. It is an OPEN ITEM for CPS to further evaluate a method and frequency to individually verify closure of these valves.

4. Review the safety related function of valve 1E21-F340, the air operated bypass valve around 1E21-F006 (P&ID M05-1073 coordinates 0-2), to determine if it should be included in the IST program.

Response: This valve does not perform a safety function and is exempt

, from IST testing per IWV-1200.

5. Provide a more detailed technical justification for not exercising valve 1E21-F306 quarterly during power operations and during cold -

shutdowns (see relief request 041).

Response: Valve 1E21-F306 does not perform any safety function and may be deleted from the IST program.

d 26

a.

~ ^ ^

.. . . T......:

~

4 L. Hiah Pressure Core Spray System

1. Will the air operator on valve IE22-F005 full-stroke exercise the valve? If not, how is this valve full-stroke exercised?

Response: The air operator does not full-stroke exercise this valve. It is an ACTION ITEM for CPS to determine a method and frequency to full-stroke exercise this valve.

2. Does valve IE22-F006 perform a safety related function in the closed position? If this valve performs a safety related function in the closed position, how is it individually verified to close?

Response: There are two series check valves in the heter leg keep fill lines which are similar to the valves discussed in Item J.8.

It is an OPEN ITEM for CPS to further evaluate a method and

frequency to individually verify closure of these valves.

3. How are excess flow check valves 1E22-F330 and F332 being tested?

Response: These valves will be tested using an air flow test. Valve 1E22-F330 will be exercised quarterly and 1E22-F332 will be exercised during refueling outages for the reasons provided in relief request 037.

( 4. Review the safety related function of valve 1E22-f304, the bypass i around valve 1E22-F005, to determine if it should be included in the l IST program and be categorized A.

l Response: Valve 1E22-F304 does not perform any safety function and need l not be included in the IST program.

27 l

. . . _ _ _ _ _ _ .m. _, .-. _ _ _ _ . - ._

- - - ^ ~ ' '

.. a: -: .. .. a:.. :.. . ..

M. Leakage Detection System

1. Are 1E31-F016 and F109 passive valves as defined in IWV-21007 If so, they should be identified as such in the IST program. If not, they should be tested as active valves in accordance with the Code.

Response: These valves do not perform any safety function and need not be included in the IST program.

2. Provide a more detailed technical justification for not measuring the ,

stroke times for the rapid acting valves listed in relief request 033.

Response: The valves listed in relief request 033 will be identified as rapid acting valves in relief request 058 and will.have their stroke times measured in accordance with the Nor etaff's 3 position on rapid acting valves.

N. MSIV leakage System

1. What ~1s the safety related function of the following valves? If they perfor:n a safety function in the closed position, how are these valves exercised closed?

1E32-F010 1E32-F315A 1E32-F315C

, 1E32-F011 1E32-F3158 1E32-F3150 Response: These valves close to allow the MSIV leakage control blowers to e obtain the required negative pressure on the MSIV headers.

l These valves will be verified to close during the system f operability test performed during cold shutdowns.

28

.s u. , . . - . . . . .. ~ ~ ~ . . . ... .. .

0. Reactor Core Isolation Coolina System

1. Does valve 1E51-F062 perform a safety related function in either the open or closed position? How is valve 1E51-fG61 tested to individually verify its ability to perform its safety related function l in the closed position?

Valves 1E51-F06) and 1E51-F062 perform a safety function in the

Response

open direction to allow the waterleg pump to fill the RCIC piping. There is no safety function in the closed direction to ,

protect low pressure piping since the waterleg pump discharges to the suction piping of the RCIC pump. Valve 1E51-F062 will be added to the IST program as a Category C valve.

2. How are check valves 1E51-F065 and F066 full-stroke exercised? Can 1E51-F065 be exercised with a ditterential pressu're equivalent to operating reactor pressure across the valve disk?

Response: The air operator does not full-stroke exercise IE51-F066. It is an ACTION ITEM for CPS to determine a method and frequency of full-stroke exercising this valve.

Exercising 1E51-F065 with a differential pressure across the disk equivalent to reactor pressure may result in damage to the actuator. This valve will be exercised during cold shutdowns utilizing the mechanical exerciser, j 3. How is valve 1E51-F030 full-stroke exercised quarterly? If this valve

! is full-stroke exercised using a manual operator, provide a valve drawing that shows how the mechanical exerciser actuates the valve disk. ,

Response: Valve 1E51-F030 will be exercised quarterly utilizing the mechanical exercise arm. A drawing of the valve was provided.

29

a2 s...<.~ :L.. .:-. ... ... ,,. 'a.. . . . -

I

.? o .

1

4. Review the safety reltted function of valve IE51-F316 to determine if this valve should be included in the IST program and be categorized A.

l Response: 1E51-F316 is exempt from testing per IWV-1200. This valve does l not perform a CIV or PIV function.

5. Does valve 1E51-F015 have a required fall-safe position? If not, it may be exempt from Section XI testing per IWV-1200(a).

Response: Valve E51-F015 1s a pressure control valve that may be deleted from the IST program per IWV-1200(a).

6. Review the safety related function of valves 1E51-F004, F005 and F047 1

to determine if they should be included in the IST program (in the case of IE51-F004 and F005) or ret!!ned in the IST prc ram (in the case of 1E51-F047).

Response: It is an ACTION ITEM for CPS to determine if valves 1E51-F004 and F005 should be included in the IST program. Valve 1E51-F047 performs a safety function and will remain in the IST program.

P. Fuel Pool Cooling and Cleanup System

1. Is credit taken for the RHR system supplying cooling water flow to the fuel pool? If so, all applicable system valves should be included in the IST program (may include check valves 1FC018A, 0188, 020A, 0208, 022A, and 0228).

Response: Yes, the RHR system can be used to supply cooling or makeup to the upper containment pools if the pool temperature exceeds 105'F or if pool level cannot be maintained. The following check valves have a safety function in the open position to 30

+, ,. . c

.i.. .~.: . s . , . . .

. o .

allow cooling and nukeup water flow to the fuel pools and will be included in the IST program and exercised quarterly.

1FC018A IFC020A 1FCO22A 1FC0188 1FCO208 1FCO228 1FC077 1FC073 IFC096

2. Are the fuel pool cooling and cleanup pumps (lFC02PA and 1FCO2PS) supplied from an emergency power source? If these pumps perform a safety related function, they should be included in the IST program along with valves 1FC022A and 0228.

Response: Before irradiated fuel is placed into the fuel pool the applicable fuel pool cooling system pumps and valves will be:

included in the Clinton IST program and will be tested to the Code requ1(es.e6Li uleless specific reiter has been requested and approved.

3. What are the safety related functions' for the following valves?

i l 1FC004A 1FC016A 1FCO24A 1FC017 1FC0048 1FC0168 1FCO248 1FC023 4

i Response: These valves receive a containment isolation signal and will be included in the IST program as category 8 valves, however, these valves do not recieve an Appendix J, Type C, leakrate test. $

r Q. Reactor Water Cleanup i

1. What is the safety related function of valves 1G33-F051, F052A, and F05287 Response: It is an ACTION ITEM for CPS to evaluate any safety function

, that these valves may perform.

31

S v,. . _ - . . . . . ~ - . ~ ~ ~ ~ ~ '

R. Instrument Air System

1. Provide a more detailed technical justification for not exercising valves ll A005, 006, 007, and 008 quarterly during power operation.

Response: These isolation valves are within the nornal flow path between the instrument air system and various valves located inside the containment /drywell. Exercising these valves will isolate the air supply to various instrumentation and safety related valves and a failure of the air supply could realign the valves to positions that may cause a plant trip. CPS will further evaluate whether these valves can be exercised during cold shutdowns.

It should be noted that the control schete fse these valvos is such that IIA 005 and 008 stroke together and IIA 006 and 007 stroke together when operated by the control switch.

2. Define " extended cpid shutdowns" 'as used in relief requests 028 and 029. Explain how a failure of valves IIA 012A, 0128, 013A, and 0138 to return to their original positions would cause a loss of operating air to SRVs.

Response: Relief requests 028 and 029 will be deleted. Valves lIA012A, 0128, Ol3A, and 0138 will be tested on a quarterly basis since the configuration of the instrument air system can support this test while maintaining air to the SRVs.

t

3. Do check valves 11A042A, 0428, 076A, and 0768, perform a safety 1

I related function in the close position? If so, how are these valves verified in the closed position during valve testing?

Response: Valves IIA 042A and 0428 perform safety functions in the closed position and valves IIA 076A and 076B do not perform a safety related function. Relief request 042 has been changed to test 32

2 L ..c'_-._... _---- .  ;  : _. . 1. . . . ._ .1

-~

~11A042A and 0428 during cold shutdowns and a discussion of the

consequences of valve failure during quarterly testing will be added. Valves IIA 042A and IIA 0428 are tested by an air leakage test.

4. Provide the technical justification for not exercising the following valves during cold shutdowns.

IIA 012A IIA 013A lIA042A 11A043A IIA 0128 IIA 0138 IIA 0428 IIA 0438 Explain how a failure of valves 11A012A, 0128, 013A, and 0138 to return to Original position would cause a loss of operating air to SRVs.

Response: Valves 11A012A, 0128, 013A, and 0138 are addressed in the response to R.2 above. Valves lIA042A and B are addressed in the response to R.3. Valves 11A043A and 8 do,not exist and were erroneously referenced in the IST program; the reference i to these valve numbers will be deleted.

5. What is the safety related function of valves IIA 044A and 04487 Oo i these pressure regulating valves have a required fall-safe position?

I l Response: 11A044A and 8 are pressure regulating valves which are exempt from testing per IWV-1200(a),

i S. Process Samplina System-

1. Provide a more detailed technical justification for not measuring stroke times for the solenoid operated valves in this system (refer to i relief request 034 and comment E.2).

Response: These solenoid operated valves will be identified as rapid l acting valves with a limiting value of full-stroke time of 1

i i

33

- - - ~ ' ~ --

.s . .>. , . . . . . . ~ . _ . . , _

." F,*

2 seconds. These valves will be included in relief request 058 and will be tested in accordance with the NRC staff's position for rapid acting valves.

2. Is any credit taken for the operation of this. system? If so, review the safety function of the following valves to determine if they should be included in the IST program.

IPSO 41 1PS013 1PS029 iPS050 1PS019 IPSO 46A j' 1PS006 1PS025 1PSO468 Response: The process sampling system is not required to perform a safety t

related function other than containment isolation. These l

valves are not containment isolation valves and, therefore, they need not be included in the IST program.

T. Breathina Air System

1. Provide a more detailed technical justification for not measuring the stroke times for the solenoid operated valves in this system (refer to relief request 027 and item E.2).

Response: These solenoid operated valves will be tested as rapid acting valves in accordance with the NRC staff's position on this topic.

U. Emergency Air System

1. What is the safety related function of valves 1RA017A and 01787 Do

, these pressure regulating valves have a required fail-safe position?

Response: 1RA017A and 8 are pressure regulating valves which are exempt from testing per IWV-1200(a).

34

.. . . . . . . . - r

. t V. Suppression Pool Makeup System

1. How are excess flow check valves 1SM008, 009, 010 .and 011 tested?

Response: These excess flow check valves are being tested with an air flow test. ISM 008 and 011 are tested during refueling outages ,

l as discussed in relief request 037. ISM 009 and 010 are tested I quarterly.  !

W. Shutdown Service Water System

1. Provide a more detailed technical justification for not measuring stroke times for the valves listed in relief request 048 Table 48-1.

Stroke times are measured for IST purposes to detect valve degradation instead of determining if the valve can meet an operational time requirement.

Response: All of the valves listed on relief request 048 except 1SX025A, 8, and C will have their stroke times measured in accordance with the Code requirements. Valves 1SX025A, B, and C are exempt from IST testing per IWV-1200 and need not be included in the program. ,

! 2. Should the valves identified on the valve listing table (Table 3.3.1) as 1SX0120, 012E, and 012f be changed to 1SX0130, 013E, and 013f ?

Response: Yes; this correction was made in Revision 1 of the IST program.

3. Provide a technical justification for not exercising the valves listed in relief requests 017 and 030 during cold shutdowns.

Response: Testing of valves ISX016A and B will allow lake water into the fuel pools thereby af fecting the chemistry of the water in the pools. Cleanup of the fuel pool water will generate additional 35 i

^ '

' ~. .. l .

~

, w .- .- ~ ~ - ~ ~ " - - - - - ' ' ' ' ' ~ ~ ' ~ ~ '

." e ,

' i

. i solid radioactive waste. Testing of valves 1SX012A and 8 and ISXO62A and B will allow lake water into the fuel pool cooling heat exchangers. Flushing the heat exchangers and cleanup of the fuel pool water could delay startup from down.

It is an ACTION ITEM for CPS to further investigate a test method and frequency for full-stroke exercising these valves.

t 4.

How are check valves 1SX083A and 0838 full-stroke exercised quarterly during power operation.

Response

Check valves 1SXO83A and B do not perform an isolation function, the upstream valves ISX082A and 8 perform that function, and, therefore, ISX083A and B need not.be included in the IST program.

, Valves 1XS082A and B are included in the IST program and are tested to the Code requirements.

5. The valve listing table indicates that a loss of power test will be perforned for valves 1SX025A, 0258, and 025C. Do these motor operated 4

valves have fall-safe actuators?

Response

Valves 1SX025A, 8, and C are exempt from testing per IWV.1200 4

and may be deleted from the IST program.

6. Review the safety related function of the following valves from P&IO M05-1052/5 -

to determine if they should be included in the IST program.

1SX072A 1SX106A 1SX073A 1SX0728 ISX1068 ISXO738 l-

Response

Revision 1 of the IST program incluced' these valves and they will be exercised during refueling outages. Relief request 050 will be expanded to include a discussion of why these valves cannot be exercised during cold shutdowns.

I

\

l 36

.. . x - . ....n. . . . . . - . . . . . . . . _ . - . . . . . - .

L, a

7. Provide a more detailed technical justification for not exercising valves ISX0130, 013E, and 013f as required by the Code.

Response: It is an ACTION ITEM for CPS to determine if valves 1SX0130. E, and f perform any safety function.

8. What is the safety related function of the valves listed in relief request 0517 If these valves are not safety related, they should be identified as such in the IST program. Relief requests will not be evaluated for nonsafety related valves.

Response

All valves in relief request 051-are Unit 2 cross connect valves and Unit 2 has been canceled. These valves do not perform a safety function.

X. Control Room HVAC System

1. Provide P&ID M05-1102/1 for the staff's review.

b Response: The P&ID was provided.

2. Do valves OVC010A and 022A have a required fail-safe position? If so, they should be included in the IST program and be full-stroke exercised.

5 Response: Valves OVC010A and 022A are required to " fall-open." These valves will be included in the IST program as Category 8 valves n

and will be exercised in accordance with the Code or relief will be requested.

3. What is the safety related function of check valves OVC020A and 032A7 If these check valves perform a safety related function in the closed position, how are they verified in that position quarterly?

i e

37

u .-

-^

. ...:a -...:,.... .. . - . . - - . ~ . . . . . -..

. ; . . o -

Response: OVCO20A and 8 prevent the loss of control room HVAC system

, chilled water. OVC032A and 8 preclude loss of ventilation cooling in case of loss of service air. These valves will be i

included in the IST program and will be exercised quarterly. l i

4. What is the function of valves OVC001A and 002A? Is this a safety related function?

Response: These valves are used to prevent freezing of the HVAC cooling coils. These valves will be included in the IST program and exercised to the Code requirements.

5. Provide a more detailed technical justification for not measuring stroke times for the solenoid operated valves listed in relief request 055.

Response: These rapid acting solenoid operated valves will be included in relief request 058 and will have their stroke times measured in accordance with the NRC staff's position on rapid acting valves.

Y. Containment Ventilation Systes 4

.1. Provide the P&ID that shows valves IVR006A, 0068, 007A, and 0078 for

{ the staff's review.

Response: The P&ID was provided.

2. How are excess flow check valves IVR016A, 0168, 018A, and 0188 tested?

Response: These valves are tested quarterly utilizing an air flow test.

l

3. Provide a more detailed technical justification for not measuring stroke times for valves IVR035, 036, 040, and 041.

38

a - .

, --~;_. .m.- .. . .: a...

Response: These valves will be included in relief request 058 and will have their stroke times measured in accordance with the NRC staff's position on rapid acting valves.

2. Chilled Water System

1. Provide the P&ID that shows valves lW0001A. 0018, 002A, and 0028.

They do not appear on M05-ill?/9 as indicated in the valve listing table.

Response: The correct P&ID was provided.

2. Define " extended cold shutdown" as used in relief request 021.

Response: Revision 1 of the IST program deleted the phrase " extended cold shutdown" from relief request 021.

3. Provide the justification for not exercising the valves list'ed in relief requests 021 and 052 during cold shutdowns.

Response: Relief requests 021 and 052 will be modified to include a discussion of why the referenced valves cannot be exercised during cold shutdowns, or the valves will be exercised during cold shutdowns.

39

I,A 4, , ....m'. .....~..4

.;...;.. ' . u.4. ......G..v . .

-,q,. -

2. PUMP TESTING PROGRAM

1. Provide a more detailed technical justification for not measuring pump bearing temperatures yearly (refer to pump relief request 001).

Response: Pump relief request 001 will be modified to include additional information justifying the deletion of annual pump bearing 3

temperature measurements.

2. What is the maximum expected variance in lake level (refer to relief-request 004)? Could this level be measured during pump tests to allow calculation of the pump inlet pressure?

Response: CPS will further evaluate the availability of pump inlet pressure measurements or calculations of inlet pressure.

I 40