ML20214P939

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Forwards Request for Addl Info on Inservice Testing Program, SER Open Issue 1(b) & Associated Relief Requests,Submitted on 860409.Meeting Should Be Arranged W/Nrc Prior to Preparing Written Response
ML20214P939
Person / Time
Site: Beaver Valley
Issue date: 11/26/1986
From: Tam P
Office of Nuclear Reactor Regulation
To: Carey J
DUQUESNE LIGHT CO.
References
TAC-62870, NUDOCS 8612040434
Download: ML20214P939 (13)


Text

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Ncvember 26, 1986 Docket No. 50-412 DISTRIRUTION

[55EEEFTTF P. Tam Local PDR D. Miller PAD #2 Rdg ACRS (10)

' Mr. J. J. Carey, Senior Vice President LRubenstein A. Masciantonio Duquesne Light Company OELD Gray File Nuclear Group E. Jordan

. Post Office Box 4 J. Partlow--

Shippingport, PA 15077 N. Thompson

Dear Mr. Carey:

Subject:

Beaver Valley Unit 2 - Request for Additional Infomation on Inservice Testing Program, SER Open Issue 1(b) (TAC 62870)-

We have reviewed your Inservice Testing Program (IST) and associated relief-requests that you submitted by letter dated April 9,1986. We found that information is needed in order for us to complete our review. (See enclosure)

Please review the enclosure and prior to preparing a written response, have your staff arrange a meeting with us to discuss your proposed response.

This information request affects fewer than 10 respondents, therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Original signed by Peter S. Tam, Project Manager PWR Project Directorate #2 Division of PWR Licensing-A Office of the Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page LA: PAD #2 PM: PAD #Dj{

DMiller PTam;abl LRuben ein 12/ /86 ff/2{,/86 lf/Q8 2

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8612040434 861126 PDR ADOCK 05000412 et PDR

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Mr. J. J. Carey r Duquesne Light Company Beaver Valley 2 Power Station -)

[ t.

E cc:

Gerald Charnoff, Esq. Mr. R. E. Martin, Manager Jay E. Silberg, Esq.  !

Regulatory Affairs Shaw, Pittman, Potts A Trowbridge Duquesne Light Company

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2300 N Street, N.W. Beaver Valley Two Pro.iect Washington, DC 20037 P. O. Box'328 Shippingport, Pennsylvania 15077 Mr. C. W. Ewing, Quality Assurance Zori Ferkin Manager Assistant Counsel Quality Assurance Department Governor Energy Council Duquesne Light Company 1625 N. Front Street P. O. Box 186- Harrisburg, PA 15105 Shippingport, Pennsylvania 15077 John D. Burrows, P.E.

Director, Pennsylvania Emergency Director of litilities Management Agency State of Ohio Room B-151 Public Utilities Commission Transportation & Safety Building 180 East Broad Street Harrisburg, Pennsylvania 17120 Columbus, Ohio 43766-0573 Mr. T. J. Lex Bureau of Radiation Protection Westinghouse Electric Corporation PA Department of Environmental Power Systems Resources P. O. Box 355 ATTN: R. Janati Pittsburgh, Pennsylvania 15230 P.O. Box 2063 Harrisburg, Pennsylvania 17120 Mr. P. RaySircar Stone & Webster Engineering Corporation BVPS-2 Records Management Supervisor

.P. O. Box 2325 Duquesne Light Company Boston, Massachusetts 0?107 Post Office Box 4 Shippingport, Pennsylvania 15077 Mr. J. Beall U. S. NRC John A. Lee, Esq.

I P. O. 181 Duquesne Light Company Shippingport, Pennsylvania 15077 1 0xford Centre 301 Grant Street Mr. Thomas E. Murley, Regional Admin. Pittsburgh, Pennsylvania 15270 U. S. NRC, Region I 631 Park Avenue King of Prussia, Pennsylvania 15729

BEAVER VALLEY POWER STATION - UNIT NO. 2 if-IST PROGRAM (REVISION 0) REVIEW 00ESTIONS REQUEST FOR ADDITIONAL INFORMATION .

I. Valve Testing Program A. General Comments and Questions

1. Are all valves that are Appendix-J-type-C-leak-rate-tested, included in the IST program and categorized A or A/C7
2. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR Appendix J, however, the applicant must comply with the-Analysis of Leakage Rates and Corrective Action requirements of Section XI, paragraphs IWV-3426 and 3427.

S. Provide the limiting value of full-stroke time for all power operated valves in the IST program for the staff's review.

4. 'Are all valves with a required fail safe position tested to the requirements of IWV-34157
5. Should the following category A or A/C valves be addressed in valve relief request 17 2CHS*31 2CHS*472 2CHS*474 2CHS*475 2CHS*176 ,

2 SIS *83 2 SIS *84 2 SIS *94 2 SIS *95 1

2 SIS *M0V836

=I .

2 SIS *M0V840 2 SIS *MOV867C 2 SIS *M0V8670~ ,

2 SIS *M0V869A 2 SIS *MOV869B 2RSS*29 2RSS*30 2RSS*31 2RSS*32 B.- . Reactor Coolant System

1. Provide a.more specific technical justification-for not full-stroke exercising valves 2RCS*68 and 2RCS*72 during cold shutdowns.
2. Is pressurizer alternate spray from the chemical and volume control system. utilized to satisfy the requirements of Branch Technical Position RSB 5-l?

C. Chemical and Volume Control System 1.- Provide a more specific technical justification for not full-stroke exercising valves 2CHS*22, 23, and 24.

2. How are valves 2CHS*LCVll5B and ll5D full-stroke exercised ,

quarterly without introducing highly borated water from the RWST into the reactor coolant system?

3. _W hat are the consequences of valve failure during auarterly full-stroke exercising of valve 2CHS*M0V2897 2
4. Provide a more specific technical justification for not.

full-stroke exercising valves 2CHS*MOV8130A, 8130B, 8131A, 8131B, 8132A, 81328, 8133A, and 81338 quarterly.  ;

5 .- Provide a more specific technical justification for not full-stroke exercising valve 2CHS*31 at cold shutdown.

6. What are the conseouences of valve failure during quarterly full-stroke exercising of valves 2CHS*MOV310, A0V204, LCV460A, and B?
7. Review the safety functions of valve 2CHS*472 to determine if.it should be categorized A/C passive.
8. How is valve 2CHS*84 full-stroke exercised quarterly without introducing highly borated water from the boric acid tanks into the reactor coolant system?
9. Are alternate suction sources available for the charging pumps to allow quarterly full-stroke exercising of valves 2CHS*LCV115C and ll5E?
10. What are the consequences of failure in the shut position of valve 2CHS*MOV373 during quarterly full-stroke exercising?
11. Review the safety functions of valve 2CHS*18 (Figure 7-l; G-6) to determine if it should be included in the IST program.
12. Provide a more specific technical justification for not full-stroke exercising valves 2CHS*473, 474, 475, and 476 during cold shutdown.

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D. Residual Heat Removal System

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1. How are valves 2RHS*3 and 4 full-stroke exercised closed during cold shutdown?
2. Will valves 2RHS*MOV701A,'701B, 702A, 7028, 720A, and 7208 be -

leak-rate-tested per technical specifications to confirm their pressure isolation capability?

3. Review the safety functicns of valves 2RHS*M0V750A and B (Figure 10-1; D-5) to determine if they should be included in the IST program.

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E ." -Safety Injection System

1. Provide a more specific technical justification for not full-stroke exercising valves 2 SIS *6 and 7 during cold shutdowns.
2. Provide a more specific technical justification for not full-stroke exercising valve 2 SIS *27 during cold shutdown.
3. Provide a more specific technical justification for not full-stroke exercising valve 2 SIS *M0V841 quarterly.
4. Provide a more specific technical justification for not full-stroke exercising valve 2 SIS *MOV8889 quarterly.
5. Provide a more specific technical justification for not
full-stroke exercising valve 2 SIS *42 during cold shutdowns.
6. Could valves 2 SIS *83, 84, 94, and 95 he full-stroke exercised on a cold shutdown frequency utilizing the external exercise arm?

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7. Provide a more specific technical justification for not I..

full-stroke' exercising valves 2 SIS *107,108, and 109 during cold shutdown. How is full-stroke exercising verified for each valve?

8. Provide a more specific technical justification for not full-stroke exercising valves 2 SIS *122, 123, 124, 125, 126, and 127 during cold shutdown. How is full-stroke exercising verified for each valve?
9. Provide a more specific technical justification for not full-stroke exercising valves 2 SIS *128 and 129 during cold shutdown. How is full-stroke exercising verified for each valve?
10. - Could valves 2 SIS *130,132, and 133 be full-stroke exercised on a cold shutdown frequency util' zing the external exercise arm?
11. Provide a more specific technical justification for not full-stroke exercising valves 2 SIS *134,135,136,137,138, and 139 during cold shutdown. How is full-stroke exercising verified for each valve? ,
12. What alternate methods of full-stroke exercising of valves 2 SIS *l41, 142, 145, 147, 148, and_151 have been considered?
13. Provide a more specific technical justification for not full-stroke exercising valves 2 SIS *545, 546, and 547 during cold shutdown. How is full-stroke exercising verified for 545 and 5467
14. Provide a more specific technical justification for not full-stroke exercising valves 2 SIS *548, 550, and 552 during cold shutdown. How is full-stroke exercising verified for each valve?

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. 1 F. Containment Vacuum System t

1. Review the safety function of valve 2CVS*14 (Figure 12-1;10-9)to determine if it should be included in the IST program.

G. Quench Spray System

1. Provide a more specific technical justification for not full-stroke exercising valves 2QSS*3 and 4 during cold shutdown.
2. What are the consequences of _ valves 2QSS*S0V100A and B failing open during quarterly full-stroke exercising?
3. What are the consequences of valves 20SS*MOV102A and B failing open during quarterly full-stroke exercising?
4. Provide a more specific technical justification for not full-stroke exercising valve 20SS*267 during cold shutdown.
5. How are valves 2QSS*303 and 304 verified closed during cold shutdown?

H. Recirculation Spray System

1. Could valves 2RSS*29, 30, 31, and 32 be full-stroke exercised during cold shutdown by utilizing the external exercise arm?
2. How are valves 2RSS*154C and D full-stroke exercised?
3. Are the remote valve indications for valves 2RSS*155A, B, C, and D verified in accordance with IWV-33007
4. Are valves 2RSS*M0V156A, B, C, and D leak rate tested as per Appendix J type C requirements?

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I. Component Cooling System i

1. ~ Provide a more specific technical justification for not i full-stroke exercising valve 2CCP*352 during cold shutdown.
2. What is the' function of valves 2CCP*DCV100-1 and 100-2 (Figure 15-1; D-3 and G-3)?
3. Do the following valves have a required fail safe position?

Location Valve _ (Figure 15-1)

DCV101A F-4 DCV101B D-4 ,

DCV101C E-4 TCV100A G-5 .

TCV100B D-5 TCV100C E-5

4. Review the safety functions of valves 2CCP*289 (Figure 15-2; E-5), 290 (Figure 15-3; E-7), and 291 (Figure 15-3; E-2) to

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determine if they should be included in the IST program.

J. Main Steam System

1. Provide a more specific technical justification for not full-stroke exercising open valves 2 MSS *18, 19, 20, 196, 199, and 200 on a cold shutdown frequency. How is full-stroke exercising open verified for each valve?
2. Review the safety functions of valves 2 MSS *S0V120, 2 MSS *344, 345, and 346 (Figure 21-1A; C-5) to determine if they should be included in the IST program.

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K.. Steam Vent System i

1. How are valves 2SVS*80, 81, and 82 each verified to full-stroke open during plant cooldown?
2. Provide a more specific technical justification for not full-stroke exercising valves 2SVS*PCV101A, B, C, and HCV104 quarterly.

L. Main Feedwater System

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1. Provide a detailed discussion on the method used to verify closure of 2FWS*28, 29, and 30.
2. What is the safety functions of valves 2FWS*FCV478, 479, 488, 489, 498, and 4997 M. Auxiliary Feedwater System

'l . Provide a raore specific technical justification for not exercising valves 2FWE*42A, B, 43A, 8, 44A, and 8 closed quarterly.

2. How are valves 2FWE*42A, 43A, and 44A verified to full-stroke open during cold shutdown?
3. Clarify the alternate testing frequency for valves 2FWE*99,100, and 101.
4. How is valve 2FWE*FCV122 verified to full-stroke open during cold shutdown?
5. Provide a detailed discussion on the internal operation of valve 2FWE*FCV122.

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N. Steam Generator Blowdown System t

1. - What is the safety function of valves 2BDG*A0V103A and B?;
0. Service Water System
1. - Provide a more specific technical justification for not full-stroke exercising valves 25WS*57, 58, and 59 quarterly.
2. Provide a more specific technical justification for not full-stroke exercising valves 25WS*M0V102A, B, C1, and C2 cuarterly.
3. Provide the P&ID that shows valve 2SWS*A0Vll8C.
4. Provide a more specific technical justification for not full-stroke exercising valves 25WS*486, 487, and 488 quarterly.
5. Review the safety functions of valves 25WS*S0V130A, B, and M0V1708 (Figure 30-2; C-9, C-5, and A-2) to determine if they should be included in the IST program.
6. Provide a more specific technical justification for not full-stroke exercising valves 25WS*M0V107A, B, C, and D quarterly.
7. Do valves 2SWS*FCV120A and B (Figure 30-4; A-1) have a required fail safe position?
8. Review the safety functions of valves 25WS*1103 and 1104 (Figure 30-4; A-3) to detcrmine if they should be included in the IST program.
9. Provide a more specific technical justification for not full-stroke exercising valves 2SWS*M0V103A and B quarterly.

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10. Provide a more ' specific technical justification for not I

full-stroke exercising valves 2SWS*106 and 107 quarterly.

11. Do valves 25WS*TCV101A and B (Figure 30-1: D-3) have a required fail safe position?
12. Is the operability of the Containment Air Recirc Cooling Coils (Figure 29-4) required during any accident scenario?

P. Standby Service Water System

1. How are valves 25WE*221 and 222 verified to full-stroke open during quarterly testing?

Q. Fire Protection System

1. . What is the proposed alternate testing frequency for the valves addressed in relief request no. 65?

R. Containment Instrument Air System

1. Provide a more specific technical justification for not full-stroke exercising valve 2IAC*22 during cold shutdown.

S. Hydrogen Control System

1. Provide a more specific technical justification for not full-stroke exercising valves 2HCS*l19 and 120 during cold shutdown.

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II. Pump Testing Program L

l'.

Provide a more specific technical justification for not testing the residual heat removal pumps quarterly.

2. Provide a' detailed discussion of the recirculation spray pump testing performed during refueling outages. Why can this testing not be performed quarterly or during cold shutdown?

-3. Explain the flowpath utilized when testing the standby service water pumps.

4. How is pump bearing vibration measured when testing the standby service water pumps?
5. If the inlet pressure of the service water pumps, standby service water pumps, and fuel oil transfer pumps is not measured in accordance with Section XI requirements, then specific relief must be requested and an alternate method of measurement proposed.
6. Where is service water pump flowrate measured during the service water pump tests?
7. How is pump bearing vibration measured when testing the fuel oil transfer pumps?

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8. Lack of installed instrumentation does not negate the requirement for measuring fuel oil transfer pump flowrate. How will this flowrate be measured?

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