ML20212N726
| ML20212N726 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/06/1987 |
| From: | Allen C COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2823K, NUDOCS 8703130133 | |
| Download: ML20212N726 (14) | |
Text
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\\,'COIRInonweeNh Edson D.
One Fest Nabonel Plaza, Chcago, IEncis
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U Chee00, IEnois 60000 0767 March 6, 1987 L U.S. Nuclear ' Regulatory Comunission
- ATTN: Document Control Desk Washington, D.C.
20555
Subject:
LaSalle County Station Unit 2 Pump and Valve Inservice Testing Plan.
NRC Docket No. 50-374 References (a): Draft Unit 2 Inservice Testing Program Review Questions.
(b): Telecon between NRC Staff and Commonwealth Edison March 2, 1987.
Dear Sir:
This letter addresses the draft questions regarding LaSalle County Station Unit 2 Inservice Testing Program (reference (a)). These questions were discussed in a telephone conversation held March 2, 1987 (reference (b)). Responses to questions are provided in the enclosure, if the answer is available. Some questions are still under further consideration. These will be answered in a later transmittal as soon as possible.
Also attached are a letter dated September 17, 1986 from C. M. Allen to H.R. Denton responding to staff review of LSCS Unit 1 IST Program and Relief Request RP-04 for Unit 1.
In addition, requested P&ID's are attached to the copies being sent to Dr. A. Bournia and H. Rockholz for their review.
We would appreciate the opportunity to discuss any of these proposals at length with your staff.
Please direct any additional questions you may have regarding this
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matter to this office.
ver truly you l
C. M. Allen Nuclear Licensing Administrator i
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Enclosure i
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Dr. A. Bournia - NRR (w/Att.)
j Resident Inspector - LSCS H. Rockholz - EG&G (w/Att.)
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LaSalle Unit 2 - Inservice Testing Program:
1 Response to the NRC's Draft SER Ouestions
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6 A.
Genera 1 Ouestions and Cosaments Question / Response:
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A.l.
The following P&ID's are provided per the NRC's request:
0 134-2 (CSCS EQP CLN WTR) 2139-1 141 (HP) 2139-2 147-1 (RCIC) 2139-4 142-3 (RH) 2139-3 2139-8 Question:
A.2.
The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves arb determined by 10 CFR 50 Appendix J, however, the licensee must comply with the Analysis of Leakage Rates and Corrective Action Requi,rements Paragraphs of Section XI, IW-3426 and 3427. Does the current LaSalle, Unit 2, IST program meet this NRC statf position?
Response
A.2.
Yes, the current IST program racets the requirements of IW-3426 and IW-3427 for those valves which are identified as Appendix J.
Question:
A.3.
Relief from exercising valves that have been identified as
" Passive" is unnecessary because Section XI, Tabls IW-3700-1, does not require " Passive" valves to be exercised.
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Response
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A.3.
The above statement applies to relief requests RV-09 and RV-37; for those valves which are category h, and identified as
" Passive," the relief requests will be revised to reflect this
. 4 fact.
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Question:
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A.4.
What is the basis for selection of power operated valve maximum W,
limiting stroke times, i.e., are the maximum stroke times listed
+c in the IST program based on actual stroke times?
Response
A.4.
Per telecon with NRC, BG&G, and LaSalle on 3/3/87, we will respond to specific questions generated upon further review of IST program by BGGG.
Question:
A.5.
Are the discharge check valves of the BCCS water leg pumps verified to open and close quarterly?
Response
A.5.
Yes, the ability of each of these check valves to pass flow and to check flow is demonstrated quarterly during regular scheduled
/1 surveillance testing.
)
Question:
A.6.
In accordance with Section XI, Paragraph IWV-3000, all valves equipped with remote position indication shall be observed to verify that the position indication is in agreement with actual valve position at least once each two years.
Response
A.6.
Since the initial IST program submittal numerous valves have had remote position verification testing added to their list of required tests.
It is LaSa11e's intent to identify this test requirement in the IST program, and to implement, through scheduled surveillance testing, the Section XI requirement.
Question:
A.7.
In reference to RV-25, the NRC staff will grant relief from the requirements of Section XI, Paragraph 3417(b), provided that the requirements of 3417(a) are met while exercising valves identified for cold shutdown testing.
Response
A.7.
In the event that a valve must be declared inoperable as a result of cold shutdown testing the applicable unit's start-up limitations will be as stated in the technical specification,
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limiting conditions for operations. When valve repairs are completed a retest to demonstrate acceptable operation is performed prior to declaring the valve operable. Refer to notes three (3) and 14 of the IST plan for further information pertaining to this subject.
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C Question:
A.8.
Are all valves that are Appendix J, Type C, leak rate tested included in the LaSalle, Unit 2, IST progren as Category A or A/C valves?,,
Response
d A.8.
No.
Several valv'es have been identified as Appendix J
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applicable and,.ere not included ir. the IST program. They are:
CM-02*l, CM-028, CM-029, CM-030, IN,018, and C51-J004 A,B,C D, and E.
The CM and IN identified system valves will be added to the IST' program.. The tip' guide tube valves are not Section XI applicable, and LaSa11e's position is to exclude them from the IST-program, however, it should be noted that an acceptable level of testing per Tech Spec 4.6.3.3 is currently being accomplished.
Question:
1
^
A.9.
The NRC staff position is that the emergency diesel generator air start' solenoid valves perform a safety function and should be included in the IST program and tested in accordance with Section XI to the extent practicable.
p Response:"[
A.9.
We agree with the NRC's staff position that the diesel generator air start. solenoids perform a safety function, however, we do not believe that their inclusion into the IST program will provide any further increase in determining the operational readiness of these valves. The technical specification surveillance requirements are far more stringent and e
f comprehensive than the Section XI requirements.
Question:
e A.10.
Does the LaSalle, Unit 2, control room ventilaticn system include pumps and valves that perform a safety function?
Response
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A.10.
The control room ventilation system doer not consist of a closed I
loop chill water system with pumps and valves.
The mechanical cooling capability of this system is provided by two individual refrigeration units connected to separate air cooling coils.
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. B.
Containment Monitoring System Question:
B.I.
Are the valves in this system that have a fail safe position being tested in accordance with Section XI?
Response
B.1.
Although not specifically delineated as such in the IST program as receiving a fail safe test, all valves identified on the p&ID's as having a fail position are fail safe tested. This is r
i; accomplished by turning the handswitch for the valve to the fail safe position, which in effect de-energizes the control circuit, f
simulating a loss of power and/or loss of air supply pressure.
This test (PST) will be identified under the list of required tests in the IST program for all applicable valves.
Question:
B.2.
Are the following valves leak tested in accordance with Appendix J?
2CM021B 2CM024A 2CM022A 2CM025A 2CM023B 2CM026B
Response
[
B.2.
No, these valves are not tested in accordance with Appendix J because they open during a LOCA, and have a fril position of i
open on loss of actuator power. They are included in the IST
]p program as Category B for the above reasons.
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<a Question:
il B.3.
Review the safety function of valve (s) 2CM047 (typical of 24 valves) to determine if (they) should be included in the IST y
program.
Response
k B.3.
The safety function of valves CM047 have been reviewed to i F) determine inclusion into the IST program, and because the entire panel (2PL15J) is isolated during accident conditions by containment isolation valves it is LaSa11e's position not to add them to the IST program. These valves do not perform a safety function.
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. Question:
B.4.
Review the safety function of valves 2cM027, 2cM028, 2CM029, and 2CM030 to determine if they should be included in the IST program.
Response
B.4.
The above valves have a containment isolation function and are Appendix J applicable. Although not identified in the IST program the required Section XI tests are performed during scheduled Tech Spec and the Section XI surveillances. These valves will be added to the IST program as category A.
C.
Diesel Generator Systems Question:
C.I.
What is the safety function of valve 2DG-011?
Response
C.I.
The backwashing function of the strainer provides for an automatic means to backflush the strainer every eight hours of operation, or if differential pressure exceeds four psi to prevent plugging of cooled component heat transfer passages without significantly affecting system function.
D.
Feedwater System Question:
D.1.
Provide a more detailed technical justification for not full-stroke exercising valves 2B21-F010A and B during cold shutdowns.
Response
D.1.
Under further review.
Question:
D.2.
Provide a more detailed technical justification for not full-stroke exercising valves 2B21-F032A and B during cold shutdowns.
Response
D.2.
Under further review.
. E.
Containment Combustible Gas Control System Question:
E.1.
What is the safety-related function of valves 2HG003 and 2HG009?
Response:-
E.1._
These valves are required to operate to provide HG system redundancy -(cross-ties between units).
F.
High Pressure Core Spray System Question:
F.1.
Does the test operator on valve 2E22-F005 full-stroke the valve disk?
Response
F.1.
Under further review.
Question:
F.2.
Provide a more detailed technical justification for not full-stroke exercising valve 2E22-P016 during cold shutdowns.
Does this valve perform a safety function in the closed position?
Response
F.2.
Under further investigation and consideration.
Question:
l F.3.
What is the safety function of valve 2E22-F3197
Response
i F.3.
The backwashing function of the strainer provides for an automatic means to backflush the strainer every eight hours of operation, or if differential pressure exceeds four psi to i
prevent plugging of cooled component heat transfer passages i
without significantly affecting system function.
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Question:
'F.4.
Review the safety function of valves 2822-F010. -F0ll, and -F023 to determine if they should be included in the IST program.
Response
F.4.
These valves have been included into the IST program as'follows:
2822-F010 and -F0ll Category B 2B22-F023 Category A Note 15 is also being added to the_IST program to provide justification for performing cold shutdown testing in lieu of quarterly testing for certain valves. The note states, "These valves when cycled result in draining of the associated piping system which renders the system inoperable for several hours until it is refilled and vented.
Therefore, these valves will only be cycled in cold shutdown, or refuel conditions when the consequences of the required safety system unavailability has less impact on plant operation." This note is appli d to valve e
G.
Drywell Instrument Nitrogen System Question:
G.I.
In reference to RV-12, is the drywell nitrogen concentration maintained during each cold shutdown? Can the valves listed on this relief request be exercised during those cold shutdowns when the drywell is de-enerted?
Response
I G.I.
Under further review.
Question:
G.2.
Review the safety function of valves 2IH100 and 2IN101 to determine if they should be included in the IST program.
Response
G.2.
These valves have been added to the IST program, and included with RV-12 (Category B).
Question:
G.3.
In reference to RV-16, can the valves listed on this relief j
request be exercised during those cold shutdowns when the drywell is de-enerted?
Response
G.3.
Under further review.
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H.
Low Pressure Core Spray System Question:
H.l.
Does the test operator on valve 2821-F006 full stroke the valve
' disk?
Response
H.l.
Under further review.
Question:
H.2.
Review the safety function of valve 2E21-F012 to determine if it should be included in the IST program.
Response
H.2.
This valve has been added to the IST program and Note 15 will apply (Category A).
I.
Main Steam System Question:
I.2.
Provide a more detailed technical justification for not full-stroke exercising the main steam relief valve tailpipe vacuum breakers during cold shutdowns.
Response
I.2.
Under further review.
J.
Nuclear Boiler and Reactor Recirculation System Question:
J.l.
Provide a more detailed technical justification for not full-stroke exercising the instrument line excess flow check valves during cold shutdowns.
Response
J.l.
Under further review.
K.
Nuclear Boiler and Reactor Recirculation System Question:
K.l.
How are valves 2PC001A-D full-stroke exercised quarterly?
Response
K.l.
These valves are manually stroked without flow per scheduled surveillance testing.
. L.
Control Rod Drive System Question:
L.l.
What is the frequency of the control rod scram testing performed in accordance with Technical Specifications?
Response
L.l.
18 months and rotating 10% every 120 days. Also after 120 day shutdown.
Question:
L.2.
Review the safety function of valves 2Cll-D001-115 and -138 to determine if they should be included in the IST program.
Response
L.2.
See response to Finding 5 of the U-l IST program SER, Attachment A.
Question:
L.3.
Provide the P&ID that shows the location of valves 2Cll-F0380,
-F381, -F388, and -F389.
Response
L.3.
Attached are P&ID's 146-2 and 146-4 which shows their locations.
M.
Residual Heat Removal System Question:
M.I.
Does the test operator on valves 2E12-F041A, -F041B, -F041C full-stroke the valve disk?
Response
M.1.
Under further review.
Question:
M.2.
How are valves 2E12-F046A, -F046B, F046C individually verified to full-stroke exercise quarterly?
Response
M.2.
These valves are considered to be full-stroked exercised when the RHR pump flow increases to greater than 500-1000 gpm and the minimum flow valve closes.
o Question:
M.3.
Does LaSalle, Unit 2, take credit for the operability of the steam condensing mode of the RHR system?
' Response:
M.3.
No, this' mode of operation of the RHR system is not taken credit for in any safety analysis ~in the PSAR.
Question:
M.4.
What is the safety function of valves 2E12-F336A and -F336B?
Response
M.4.-
The backwashing function of the strainer provides for an automatic means to backflush the strainer every eight hours of operation, or if differential pressure exceeds four psi to prevent plugging of cooled component heat transfer passages without significantly affecting system function.
Question:
M.5.
Review the safety function of valvas 2E12-F040A and -F040B to determine if they should be included in the IST program.
Response
M.S.
The function of these valves is to provide a means of periodic blowdown of the RHR heat exchangers to remove any sediment deposits, and specifically, provides a redundant isolation to valves 2E12-F049A and -F049B.
N.
Reactor Core Isolation Cooling System Question:
N.l.
Does the 2851-F013 provide a pressure boundary isolation function?
Response
N.l.
No, the 2E51-F065 and 2E51-F066 provides the pressure boundary isolation function for the RCIC injection line.
Question:
N.2.
Provide a more detailed technical justification for not full-stroke exercising valve 2E51-F030 quarterly.
Response
N.2.
Under further review.
CE' ~
.. Question:
N.3.
Does the-test operator.on ralves 2851-F065 and -F066 full-stroke the disk?
Response
N.3.
Under'further review.
Question:
N.4.
Review the safety function of valves 2E51-F022 and -F059 to determine if they should be included in the IST program.
Response
N.4.
These valves have been added to the IST program as Category B.
Question:
N.5.
Are. valves 2E51-F028 and -F040 leak tested as indicated in the
" Remarks" column? If so, they should be categorized A/C. Do these valves perform a safety function in the closed position?
i
Response
N.5.
These valves are leak tested in accordance with Appendix J and the IST program will be changed to reflect category A/C. Also, these valves are closure tested by the performance of the above leak test to verify their closure capability.
Question:
N.6.
Provide a more detailed. technical justification for not full-stroke exercising valves 2E51-F064 and -F091 quarterly.
Response
N.6.
Under further review.
O.
Standby Liquid Control System Question:
0.1.
Provide a more detailed technical justification for not full-stroke exercising valves 2C41-F001A and -F001B quarterly.
Response
0.1.
Under further review.
.,- Question:
0.2.
Provide a more detailed technical justification for not full-stroke exercising valves 2C41-F006 and -F007 quarterly.
Response
0.2.
Under further review.
P.
Primary Containment Ventilation System Question:
P.1.
Provide a more detailed technical justification for not exercising all valves listed in this system during each cold shutdown.
Response
P.l.
Under further review.
Q.
Miscellaneous Systems Question:
Q.l.
Provide the analysis upon which RV-18 is based on excluding valves 2B33-F013A, -F013B, -F017A, and -F017B from the IST program.
Response
Q.1.
Under further review.
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, Pump Ouestions-Question:
i 1.
Provide a more detailed technical justification for not establishing fixed limiting values for vibration Alert and Required Action ranges.
Question:
2.
Which method of vibration measurement is being utilized during pump' testing? Both vibration amplitude and displacement are discussed in the IST program.
Response
'1/2.
Attachment B is provided and should adequately address the above questions, Question:
o 3.
In reference to RP-05, the NRC staff position is that the lack of installed instrumentation is not an acceptable long term technical justification for not measuring the Code required parameters on pumps that perform a safety-related function.
Response
3.
RP-05 concerns have been addressed in LaSalle's response to Finding 2 for the Unit 1, IST program's SER.
Attachment A is provided for reference to this issue.
Question:
4.
Is RP-08 still applicable to the residual heat removal pump tests? Should this relief request be referenced under " Test Parameters"?
Response
I i
4.
Yes, and the IST program will be revised to add RP-08 under the applicable " Test Parameters" column.
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