ML20211H777

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Forwards Responses to RAIs 650.1 Through 650.8 Re Generic Issues & Generic Communications on Valve Testing & Valve Qualification.Westinghouse Status for Subject Issues Will Be Confirm W Pending Rev to Ssar & WCAP-13559
ML20211H777
Person / Time
Site: Indian Point, 05200003  Entergy icon.png
Issue date: 10/02/1997
From: Mcintyre B
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Quay T
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-87-06, GL-87-6, NSD-NRC-5359, NUDOCS 9710070126
Download: ML20211H777 (10)


Text

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-Westinghouse - Energy Systems Box 35h Pittsburgh Pennsylvania 15230 0355

__ Electric Corporation DCP/NRC1064 NSD NRC-97-5359 l Docket No.i 52-003 <

- October 2,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: T.R. QUAY

SUBJECT:

RESPONSE '10 RAls RELATED TO GENERIC COMMUNICATIONS De, r Mr, Quay:

1 2 Attached are the responses for RAls 650.1 through 650.8 (OITS # 5758 through f 765). These RAls

[ are related to generic issues and generic communications on valve testing and valve quali6 cation. The Westinghouse status for these issues will be ConGrm W pending revision to the SSAR and WCAP-13559. The SSAR changes will be included in Revision 17.

ii Please contact Donald A. Lindgren at (412) 374-4856 if you ha've any questions.

4ff Brian A. McIntyre, Manager W

Advanced Plant Safety and Licensing jmi- Y

---U Attachment

/V ec: J. M. Sebrosky, NRC (w/ Attachment)

N. J.- Lipurato, (w/o Attachment)

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9710070126 971002 "f PDR ADOCK 052000031 A PDR f 3414e wp

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NRC REQUEST FOR ADDITIONAL INFORMATION sp Question 650.1-Issue ll.D.l: Performance Testing of PWR Safety and Relief Valves As discussed in NUREG-0933, Issue II.D.1, addressed the requirements in NUREG-0737 for qualifi-cation testing of RCS safety, relief, and block valves under expected operating conditions for design-basis transients nd accidents, including ATWS. This issue was resolved by requiring licensees to conduct testing to qualify reactor coolant relief valves, safety valves, block valves, and associated discharge piping.

A safety and relief valve test program was conducted by the EPRI for a group of PWR licensees to respond to the staff recommendations in NUREG-0587 and as clarified in NUREG 0737. De purpose of the program was to develop sufficient documentation and test data so that the participating licensees could demonstmte compliance with the II.D.1 requirements. De results were documented in the EPRI repon, EPRI NP2628 SR, "EPRI PWR Safety and Relief Valve Test Report," December 1982. EPRI l also published a guide on how to apply the test results to the evaluation of plant specific valves. De

! staff used the test results documented in EPRI NP 2628 SR as a part of its acceptance criteria in its evaluations of the resolution of issue II.D.I for all current operating plants.

In Section 1.9.3 of the SSAR, item (2)(x), Westinghouse states that the AP600 design does not include power-operated relief valves and their associated block valves on the RCS He safety valve and discharge piping used will either be of similar design as those valves tested and documented in EPRI Repon NP 2770-LD_("EPRI/CE PWR Safety Valve Test Repon," December 1982), or will be tested in accordance with the guidelines of Issue II.D.1 in NUREG-0737.

In DSER Open Item 20.411, the staff requested that Westinghouse clarify an apparent inconsistency in the references to the EPRI test data in Sections 1.9.3 and 1.9.7 of the SSAR.- ne reference in both of these sections should be EPRI NP-2628-SR, which is the latest report that documents the EPRI test data. Westinghouse has not yet responded to this request through Revision 12 of the SSAR, -Here-fore, Issue II.D.I is not resolved t~or the AP600 design.

Response

The DSER write-up for the response to 10 CFR34.f.(2)(x) (NUREG-0737 Item II.D.1) in Section 20.4 states that reference to NP 2770-LD is acceptable. EPRI Report NP 2770-LD documents the specific test results of a number of valves from different valve manufacturers. Included in these reports is an identification of the valve designs tests. His is an appropriate reference for the commitment in the SSAR. A reference for the repon will be provided in the SSAR. EPRI repon NP2628-SR is more of a summary of the program.

650.M T Westinghouse

NRC REQUEST FOR ADDITIONAL INFORMATION

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SSAR Resision:

Revise the ikst paragraph of the response for (2)(x)in subsection 1.9.3 as follows:

The AP600 reactor coolant system design does not include power operated relief valves and their associated block valves. However, the safety valve and discharge piping used in the AP600 design will be either of design similar to those items tested by EPRI and documented in EPRI Report EPRI NP.

I 2770-LD (Reference 2) or will be tested in accordance with the guidelines of Item [lI.D.1] or l NUREG.0737.

l Revise Reference 2 in subsection 1.9.6 as follows:

1 2. Report NP 2770-LD, "EPRl/CE PWR Safety =d Rc!!cf-Valve Test Pregra n Safc:y =d Rc!!cf l Valw-Test Report," December 1982. !r.:c:i- Report, Apri! 1982, l

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  • NRC REQUEST FOR ADDITIONAL INFORMATION ar 9.

Question 650.2 GL.87-06: Periodic verification of leak tight integrity of pressure isola' ion valves.

WCAP 13559, Revision 1. states that this generic letter is addressed in LCOs 3.4.8 and 3.4.9 of the plant TS in SSAR Chapter 16. Amendment 0 of SSAR Chapter 16 delded LCO 3.4.8. "RCS Pressure Isolation Valve (PlV) Leakage." LCO 3.4.9 is not applicable to PlV leakage. The staff has determined that the resolution of GL 87-006 will ultimately depend upon the resolution of issues identified in a May 28,1997, letter to Westinghouse entitled " Comment on the AP600 Technical Specifications related to pressure isolation valves".

Response

Letter DCP/NRC1009 dated August 29,1997 provided the response to the May 28,1997 NRC letter.

LCO 3.4.16 has been added in SSAR Revision 16 to provide for testing of pressure isolation valves PlVs in the technical specifications. Subsection 3.9.6.2.2 of the SSAR identifies that there is no '

maximum leakage requirement for AP600 PlVs. The AP600 includes design features to preclude a rupture in connecting systems due to pressurization through a closed isolation valve.

SSAR Revision: NONE WCAP 13559 Revision:

Revise the Comment for Generic Letter 87-M as follows:

I SSAR Chapter 16, LCO 3.4.16 3.4.8 r.d 3.4.9 -

T Westinghouse

NRC REQUEST FOR ADDITIONAL INFORMATION Question 650.3 GL-95-07: Pressure locking and thermal binding of safety related power operated gate valves.

WCAP 13559, Revision I states that this GL is not applicable because it is a procurement / surveillance issue. The staff does not agree. Although this GL was addressed to licensees of operating plants and plants under construction, the staff's position is that the concerns in this GL should also be addressed during the design stage. Therefore, the staff requests that if the AP600 design contains any safety-related power-operated gate valves, Westinghouse should add a discussion in the SSAR and WCAP-l'4559 to explain how the Requested Actions in GL-95-007 will be implemented.

Response

l SSAR Subsections 5.4.8.1.2 and 5.4.8.2 identify design provisions and qualification requirements to address pressure locking and thermal binding in gate valves. For example, solid wedge designs are

( not used and provisions for venting of heated, trapped fluid are provided when overpressurization of gate valves can result.

SSAR Resisiont NONE l WCAP 13559 Pevision:

l l Revise the Comment for Generic Letter 95-07 a* follows:

1 Net-AppheaNe-Procuitment S=ci!!=ce Issue SSAR Subsections 5.4.8.1.2 and 5.4.8.2 3-94-3 3 Westinghouse

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e NRC REQUEST FOR ADDITIONAL INFORMATION-jit "if Question 650.4 GL 96-05: Periodic verification of design-basis capability of safety related motor-operated valves.

This GL is not addressed in WCAP 13559 Revision 1. Since the staff has included GL 96-05 as a part of its evaluation of the AP600 inservice testing program, this GL should be added to WCAP.

13559, in a letter dated March 19,1997, in response to RAI 210.229, Westinghouse agreed to revise

- WCAP 13559 to add GL-96-05. Updating of WCAP 13559 is also tied to the resolution of DSER Open item 20.71.

Response

The inservice test plan for AP600 is outlined in subsection 3.9 ..d the requirements for preoperational testing is outlined in subsection 5.4.8.5 SSAR Revision: None WCAP 13559 Revision:

Add an entry for Generic Letter 96-05 as follows:

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Number Title Comment I 96 Periodic Verification of Design Basis SSAR subsections 3.9.6.2 and 5.4.8.5 i Capability of Safety-related Motor operated i Valves I

e T Westinghouse

- 1 NRC REQUEST FOR ADDITIONAL INFORI AATION i

Question 650.5 BL 81-02: Failure of gate-type valves to close against differeatal pressure.

In WCAP 13559 Revision 1. Westinghouse states that this bulletin is not applicable to the AP600 design because the issues involved procurement. The staff agrees that this bulletin was addressed to operating plants and plants under construction in 1981. However, since the subject of this bulletin led, in part, to the issuance of Generic Letter (GL) 89-10. " Safety-Related Motor Operated Valve Testing and Surveillance," the staff's position is that the basis for disposition of this issue should be the information in SSAR Section 3.9.6 relative to GL-8910. The staff has concluded that the commit-ments in SSAR Section 3.9.6 r.lative to inservice and qualification testing of motor-operated valves provides an acceptable basis to resolve this issue. Therefore, the Comment for Bulletin 81-02 in WCAP-13559 should be revised to reference the commitments to GL 8910 in SSAR Section 3.9.6.

Response

Bulletin 81-02 was written in response to results of tests of valves used as power operated relief valve block valves. The AP600 does not have power operated relief valves or associated block valves.

SSAR Subsections 5.4.8.1.2 and SA8.2 identify design provisions and qualification requiren.ents for safety related valves. These valves are shown by test, analysis or combination of both to operate over the range of design conditions. This includes opening or closing against pressure or flow as applicable. Schsection 3.9.6.2 outlines the inservice test plan requirements for valves.

In some cases the system design also minimizes the loads on the gate valves during closing. For example, as noted in subsection 6.3.2.2.8.5, the isolation valve in each pair of valves in the first three stages of the automatic depressurization system is sequenced to open before the control valve opens so that the gate valve does not open against full flow conditions. The control valve in each pair is not a gate valve.

SSAR' Revision: None WCAP.13559 Revision:

Revise the Comment for Bulletin 8102 as follows:

I Net-AppheuW-Procurement and Surveillance issue SSAR Subsections 3.9.6.2, 5.4.8.1.2 and 5.4.8.2 f3 Westinghouse

e I

NRC REQUEST FOR ADDITIONAL INFORMATION l

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Question 650.6 BL-88-08: Thermal stresses in piping connected to reactor cooling systems.

WCAP-13559 states that this bulletin is addressed in Sections 3.9.3.1.2 and 5.4.10.1 of the SSAR.

Sec: ion 5.4.10.1 does not contain this information and should be deleted from the " Comment" column for BL 88-003 in WCAP 13559. However, the staff has concluded that the information in SSAR Section 3.9.31.2 provides an acceptable basis for resolving BL 88-008 for the AP600.

Response

Section 3.9.3.1.2 includes a discussion of the issues raised in Bulletin 88-08 and the Supplements to Bulletin 83-08.

SSAR Revision: None WCAP.13559 Revision:

Rev the Comment for Bulletin 88 08 as follows:

I SSAR Subsection 5.4.10. ! , 3.9.3.1.2 Revise the Comment for Bulletin 88-08 supplements 1,2, and 3 as follows:

I SSAR Subsection 4-44043.9.3.1.2 T Westinghouse

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.s NRC REQUEST FOR ADDITIONAL INFORMATION Question 650.7 GL-89-G4: Guidance on developing acceptable inservice testing programs.

Westinghouse states that this generic letter is addressed in Sections 5.2.4 and 6.6 of the SSAR. The staffi evaluation and acceptance of the AP600 inservice testing program tvas based on the information in SSAR 3.9.6, Therefore, GL-89-004 is resolved for the AP600. SSAR Section 3.9.6 should be added in the " Comment" under GL 89-004 in WCAP 13559.

Response

The AP600 inservice testing program requirements are outlined in subsection 3.9.6 SSAR Revision: None WCAP 13559 Revision:

Revise the Comment for Generic Letter 89-004 as follows:

I SSAR Subsections 3.9.6.25.2.4,6.6

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.l NRC REQUEST FOR ADDITIONAL INFORMATION

. . . . . ..._m.

Question 650.8 GL 8910: Safety related motor operated valve testing and surveillance Westinghouse states that this generic letter is not applicable to the AP600 design because it involves procurement and surveillance issues: however, the generic letter is addressed in Section 3.9.6.2 of the SSAR. The staff's position is that this generic letter is applicable to the AP600. Therefore, the state-ment in the Comment" under GL-8910 should be revised. The staff's evaluation of the information

-in SSAR 3.9.6 relative to motor-operated valve testing and surveillance provides the basis for the staff to conclude that GL-8910 is resolved for the AP600.

Response: ,

! The AP600 inservice testing program requirements are outlined in subsection 3.9.6 I SSAR Revision: None l

WCAP 13559 Revision:

Revise the Comment for Generic Letter 89-010 as follows:

1 Nc: Applienb!c P:ceure:nc.: Testing and Surveillance Issue SSAR Subsection 3.9.6.2 T Westinghouse i

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