ML20215L341

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Forwards Response to NRC Re Inservice Testing of Pumps & Valves & Draft Rev 0 to ISI-P-008, Inservice Test Program for Vogtle Electric Generating Plant,Unit 1, Per SER Confirmatory Item 13
ML20215L341
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/20/1986
From: Bailey J
GEORGIA POWER CO.
To: Youngblood B
Office of Nuclear Reactor Regulation
Shared Package
ML20215L344 List:
References
GN-1129, NUDOCS 8610280586
Download: ML20215L341 (25)
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Text

, , Georgi 2 Power Company Post Offics Box 282 Waynesbora Georgia 30830 Telephona 404 554-9961 404 724-8114 Southern Company Services, Inc.

Post Office Box 2625 Birmingham, Nabama 35202 Telephone 205 8704011 VOgtie Project October 20, 1986 Director of Nuclear Reactor Regulation File: X7BC35 Attention: Mr. B. J. Youngblood Log: GN-1129 PWR Project Directorate #4 Division of PWR Licensing A U. S. Nuclear Regulatory Commission Washington, D.C. 20555 NRC DOCKET NUMBERS 50-424 AND 50-425 CONSTRUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 V0GTLE ELECTRIC GENERATING PIANT - UNITS 1 AND 2 SER CONFIRMATORY ITEM 13: INSERVICE TESTING OF PUMPS AND VALVES

Dear Mr. Denton:

On October 8 and 9,1986 GPC met with your staff to discuss the subject confirmatory item. As a result of our meeting the following information is provided:

Enclosure A - Response to NRC letter dated August 11, 1986.

Enclosure B - Draft revision to the Inservice Test Program, VEGP Unit 1, ISI-P-008.

The formal program revision will be transmitted within two weeks.

If your staff requires any additional information, please do not hesitate to contact me.

Sincerely,

(* k J. A. Bailey Project Licensing Manager JAB /sm Enclosure xc: R. E. Conway NRC Regional Administrator R. A. Thomas NRC Resident Inspector J. E. Joiner, Esquire D. Feig B. W. Churchill, Esquire R. A. McManus M. A. Miller (2) L. T. Gucwa B. Jones, Esquire Vogtle Project File G. Bockhold, Jr. (2)g) 8610280586 861020 I  !?

{DR ADOCK 05000424 PDR l

V0 GILE ELECIRIC GENERATING PIANT, UNIT 1 ISI PROGRAM (REVISION 0) REhtM QUrsn0NS AND RcMJNSES I. Valve Testing Program A. General Questions and Coments

1. Are valves that perfom both a contaiment isolation function and a pressure boundary isolation function leak rate tested to both the Appendix J and Section XI requirements?

Response: Currently no leak rate tested valves are identified which perfom both a contaiment isolation function and a pressure boundary isolation function.

2. Are all valves that are Appendix J type C leak rate tested, included in the IST program and categorized A or A/C?

Response: All valves that are identified in the FSAR Table 6.2.4-1 as being subject to Appendix J type C leak rate test are included in the IST Program and categorized A or A/C.

3. How are valves inside contaiment fail-safe tested quarterly?

Response: He fail-safe test for these valves is perfomed by placing the control switch to the position required to deenergize the solenoid. He proper position of the valves is accomplished by observing the remote position indicators.

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

Response: 'Ihe current limiting value of full-stroke time for all mer operated valves in the IST Program are shown miow. The full-stroke time for these valves may change after an evaluation of the baseline testing is perfomed. 'Ihe limiting value of full-stroke time for wwer operated valves will not be included in the IST

?rogram.

ISr VALVE SIROKE TIMES MAXIMLH SOURCE OF i

VALVE NO. SIROKE TIME INFORMATION/ REMARKS 1201-HV0442A 10 Sec Vendor Manual l

1201-HV0442B 10 Sec Vendor Manual 1204-HV8000A 10 Sec Vendor Drawing 1201-HV8000B 10 Sec Vendor Drawing PAGE 1 0F 24

MAXIMM SOURCE OF VALVE NO. SIROKE TIME INFORMATION/REPARKS 1201-W8028 15 Sec FSAR Table 6.2.4-1 1201-HV8033 15 Sec , FSAR Table 6.2.4-1 1201-HV8047 15 Sec FSAR Tabl'e 6.2.4-1 1201-HV8095A 10 Sec Vendor Drawing 1201-HV8095B 10 Sec Vendor Drawing 1201-HV8096A 10 Sec Vendor Drawing 1201-HV8096.3 10 Sec Vendor Drawing 1201-HV8701A 120 Sec Vendor Drawing 1201-HV8701B 120 Sec Vendor Drawing 1201-HV8702A 120 Sec Vendor Drawing 1201-HV8702B 120 Sec Vendor Drawing 1201-LV0459 30 Sec W 1etter 1201-LV0460 30 Sec U letter 1201-PV0455A 2 Sec Vendor Drawing 1201-PV0456A 2 Sec Vendor Drawing 1202-CV-9446 3 Sec See Note 1/Close Only 1202-CV-9447 3 Sec See Note 1/Close Only 1202-HV1668A 20 Sec Valve Data Sheet 1202-HV1668B 20 Sec Valve Data Sheet 1202-HV1669A 20 Sec Valve Data Sheet 1202-HV1669B 20 Sec Valve Data Sheet 1202-HV2134 40 Sec FSAR Table 6.2.4-1 1202-HV2135 40 Sec FSAR Table 6.2.4-1 1202-HV2138 40 Sec FSAR Table 6.2.4-1 1202-HV2139 40 Sec FSAR Table 6.2.4-1 1204-HV0943A 10 Sec Vendor Drawing 1204-HV0943B 10 Sec Vendor Drawing 1204-HV8801A 10 Sec Vendor Drawing 1204-HV8801B 10 Sec Vendor Drawing 1204-HV8802A 10 Sec Vendor Drawing 1204-HV8802B 10 Sec Vendor Drawing 1204-HV8806 15 Sec Vendor Drawing 1204-HV8807A 15 Sec Vendor Drawing 1204-HV8807B 15 Sec Vendor Drawing 1204-HV8809A 15 Sec Vendor Drawing 1204-HV8809B 15 Sec Vendor Drawing 1204-HV8813 10 Sec Vendor Drawing 1204-HV8814 10 Sec Vendor Drawing 1204-HV8821A 15 Sec Vendor Drawing 1204-HV8821B 15 Sec Vendor Drawing 1204-HV8823 15 Sec FSAR Table 6.2.4-1 1204-W8824 15 Sec . FSAR Table 6.2.4-1 1204-HV8825 15 See FSAR Table 6.2.4-1 1204-HV8835 10 Sec Vendor Drawing 1204-HV8840 20 Sec Vendor Drawing 1204-HV8843 15 Sec FSAR Table 6.2.4-1 1204-HV8871 10 Sec FSAR Table 6.2.4-1 1204-W8875A 10 Sec Vendor Drawing 1204-HV8875B 10 Sec Vendor Drawing 1204-HV8875C 10 Sec Vendor Drawing PAGE 2 0F 24

MAXIMLN SOURCE OF VALVE NO. STROKE TIME INFORMATION/ REMARKS 1204-HV8875D 10 Sec Vendor Drawing 1204-HV8875E 10 Sec Vendor Drawing 1204-HV8875F 10 Sec Vendor Drawing 1204-HV8875G 10 Sec Vendor Drawing 1204-HV8875H 10 Sec Vendor Drawing 1204-HV8881 15 Sec FSAR Table 6.2.4-1 1204-HV8888 10 Sec FEAR Table 6.2.4-1 1204-HV8890A 15 Sec FSAR Table 6.2.4-1 1204-HV8890B 15 Sec FSAR Table 6.2.4-1 1204-HV8920 10 Sec Vendor Drawing 1204-HV8923A 15 Sec Vendor Drawing 1204-HV8923B 15 Sec Vendor Drawing 1204-HV8924 15 Sec Vendor Drawing 1204-HV8964 10 Sec FSAR Table 6.2.4-1 1204-HV9017A 15 Sec Vendor Drawing 1204-HV9017B 15 Sec Vendor Drawing 1204-HV10950 15 Sec FSAR Table 6.2.4-1 1204-HV10951 15 Sec FSAR Table 6.2.4-1 1204-HV10952 15 Sec FSAR Table 6.2.4-1 1204-HV10953 15 Sec FSAR Table 6.2.4-1 1204-HV10957 10 Sec Data Sheet 1204-HV10958 10 Sec Data Sheet 1205-HV8716A 15 Sec Vendor Drawing 1205-HV8716B 15 Sec Vendor Drawing 1205-HV8804A 15 Sec Vendor Drawing 1205-HV8804B 15 Sec Vendor Drawing 1205-HV8811A 20 Sec Vendor Drawing 1205-HV8811B 20 Sec Vendor Drawing 1205-HV8812A 20 Sec Vendor Drawing 1205-HV8812B 20 Sec Vendor Drawing 1206-HV8994A 15 Sec Vendor Drawing 1206-HV8994B 15 Sec Vendor Drawing 1206-HV9001A 15 Sec Vendor Drawing 1206-HV9001B 15 Sec Vendor Drawing

, 1206-HV9002A 15 Sec Vendor Drawing 1206-HV9002B 15 Sec Vendor Drawing 1206-HV9003A 15 Sec Vendor Drawing 1206-HV9003B 15 Sec Vendor Drawing 1208-HV8100 15 Sec FSAR Table 6.2.4-1 1208-HV8105 15 Sec FSAR Table 6.2.4-1 1208-HV8106 10 Sec Vendor Drawing 1208-HV8110 10 Sec Vendor Drawing 1208-HV8111A 10 Sec Vendor Drawing 1208-HV8111B 10 Sec Vendor Drawing 1208-HV8112 15 Sec FSAR Table 6.2.4-1 1205-HV8116 10 Sec Vendor Drawing 1208-HV8152 15 Sec FSAR Table 6.2.4-1 1208-HV8160 15 Sec FSAR Table 6.2.4-1 1208-HV8485A 10 Sec Vendor Drawing PAGE 3 0F 24

-,, --.-,,-r-. -,r---- , y cw , m - - - i-,,w - ----,

MAXIMLM SOURCE OF VALVE NO. SIROKE TIME INFORMATICN/RDfARKS 1208-HV8485B 10 Sec Vendor Drawing 1208-HV8508A 10 Sec Vendor Drawing 1208-HV8508B 10 Sec Vendor Drawing 1208-HV15214 24 Sec See Note 2/Close Only 1208-LV0112B 10 Sec Vendor Drawing 1208-LV0112C 10 Sec Vendor Drawing 1208-LV0112D 15 Sec Vendor Drawing 1208-LV0112E 15 Sec Vendor Drawing 1212-HV3502 15 Sec FSAR Table 6.2.4-1 1212-HV3507 15 Sec FSAR Table 6.2.4-1 1212-HV3508 15 Sec FSAR Table 6.2.4-1 1212-HV3513 15 Sec FSAR Table 6.2.4-1 1212-HV3514 15 Sec FSAR Table 6.2.4-1 1212-HV3548 15 Sec FSAR Table 6.2.4-1 1212-HV8220 15 Sec FSAR Table 6.2.4-1 1214-HV0780 15 Sec FSAR Table 6.2.4-1 1214-HV0781 15 Sec FSAR Table 6.2.4-1 1217-HV1974 10 Sec Valve Data Sheet 1217-HV1975 10 Sec Valve Data Sheet 1217-HV1978 10 Sec Valve Data Sheet 1217-HV1979 10 Sec Valve Data Sheet 1301-W3000 20 Sec Vendor Drawing 1301-W3010 20 Sec Vendor Drawing 1301-W3020 20 Sec Vendor Drawing 1301-W3030 20 Sec Vendor Drawing 1301-HV3006A 5 Sec FSAR Table 6.2.4-1 1301-HV3006B 5 Sec FSAR Table 6.2.4-1 1301-HV3016A 5 Sec FSAR Table 6.2.4-1 1301-HV3016B 5 Sec FSAR Table 6.2.4-1 1301-HV3026A 5 Sec FSAR Table 6.2.4-1 1301-HV3026B 5 Sec FSAR Table 6.2.4-1 l 1301-HV3036A 5 Sec FSAR Table 6.2.4-1 1301-HV3036B 5 Sec FSAR Table 6.2.4-1 1301-HV3009 10 Sec Valve Data Sheet l 1301-HV3019 10 Sec Valve Data Sheet 1301-HV7603A 15 Sec FSAR Table 6.2.4-1 1301-HV7603B 15 Sec ESAR Table 6.2.4-1 l 1301-HV7603C 15 Sac FSAR Table 6.2.4-1 l 1301-HV7603D 15 Sec ESAR Table 6.2.4-1 l

1301-HV9451 15 Sec FSAR Table 6.2.4-1 1301-HV9452 15 Sec ESAR Table 6.2.4-1 1301-HV9453 15 Sec FSAR Table 6.2.4-1 1301-HV9454 15 Sec FSAR Table 6.2.4-1 1301-HV13005A 5 Sec Valve Data Sheet 1301-HV13005B 5 Sec Valve Data Sheet 1301-HV13006A 5 Sec Valve Data Sheet 1301-HV13006B 5 Sec Valve Data Sheet 1301-HV13007A 5 Sec Valve Data Sheet PAGE 4 0F 24

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

l

MAXD Of SOURCE OF VALVE NO. S11t0KE TIME INFORMATION/RDfARKS 1301-W13007B 5 Sec Valve Data Sheet 1301-HV13008A 5 Sec Valve Data Sheet 1301-HV13008B 5 Sec Valve Data Sheet 1301-HV15212A 15 Sec See Note 3/ Estimated 1301-HV15212B 15 Sec See Note 3/ Estimated 1301-HV15212C 15 Sec See Note 3/ Estimated 7 1301-WIP.12D 15 Sec See Note 3/ Estimated 1301-HV15216A 15 Sec See Note 3/ Estimated 1301-HV15216B 15 Sec See Note 3/ Estimated 1301-HV15216C 15 Sec See Note 3/ Estimated 1301-HV15216D 15 Sec See Note 3/ Estimated 1302-HV5106 10 Sec Valve Data Sheet 1302-HV5113 10 Sec Valve Data Sheet 1302-HV5118 10 Sec Valve Data Sheet 1302-HV5119 10 Sec Valve Data Sheet

, 1302-HV5120 10 Sec Valve Data Sheet 1302-HV5122 10 Sec Valve Data Sheet 1302-HV5125 10 Sec Valve Data Sheet 1302-HV5127 10 Sec Valve Data Sheet 1302-HV5132 10 Sec Valve Data Sheet 1302-HV5134 10 Sec Valve Data Sheet '

1302-HV5137 10 Sec Valve Date Sheet 1302-HV5139 10 Sec Valve Data Sheet 1302-HV15196 5 Sec Valve Data Sheet 1302-HV15197 5 Sec Valve Data Sheet

, 1302-HV15198 5 Sec Valve Data Sheet i 1302-HV15199 5 Sec Valve Data Sheet i 1305-HV5227 5 Sec FSAR Table 6.2.4-1 1 1305-HV5228 5 Sec FSAR Table 6.2.4-1 i

1305-HV5229 5 Sec FSAR Table 6.2.4-1 1305-HV5230 5 Sec FSAR Table 6.2.4-1

, 1505-HV2626A 10 Sec FSAR Table 6.2.4-1 t

1505-HV2626B 5 Sec FSAR Table 6.2.4-1

1505-HV2627A 10 Sec FSAR Table 6.2.4-1 1

1505-HV2627B 5 Sec FSAR Table 6.2.4-1 1506-HV2628A 10 Sec FSAR Table 6.2.4-1

. 1506-HV2628B 5 Sec FSAR Table 6.2.4-1 1

1506-HV2629A 10 Sec FSAR Table 6.2.4-1 1506-HV2629B 5 Sec FSAR Table 6.2.4-1 1508-HV2624A 20 Sec FSAR Table 6.2.4-1 1508-HV2624B 20 Sec FSAR Table 6.2.4-1 l

1609-HV12975 15 Sec FSAR Table 6.2.4-1 1609-HV12976 15 Sec FSAR Table 6.2.4-1 1609-HV12977 15 Sec FSAR Table 6.2.4-1 1609-HV12978 15 Sec FSAR Table 6.2.4-1 PAGE 5 0F 24 .

MAXINLM SOURCE OF VALVE NO. STROKE TIME INFORMATION/RDfARKS 1901-W7126 15 Sec FSAR Table 6.2.4-1 1901-W7136 15 Sec FSAR Table 6.2.4-1 1901-W7150 15 Sec FSAR Table 6.2.4-1 1901-W7699 15 Sec FSAR Table 6.2.4-1 2301-W27901 20 Sec FSAR Table 6.2.4-1 2401-W9385 20 Sec FSAR Table 6.2.4-1 2402-W8880 15 Sec FSAR Table 6.2.4-1 2420-W9378 15 Sec FSAR Table 6.2.4-1 2702-W8208 15 Sec FSAR Table 6.2.4-1 2702-W8209 15 Sec FSAR Table 6.2.4-1 2702-W8211 15 Sec FSAR Table 6.2.4-1 2702-W8212 15 Sec FSAR Table 6.2.4-1 Note 1: ne stroke times for these valves are 2.55 seconds + 25% for closing and 8.1 seconds + 25% for opening. 'Ihe maxhun stroke -

time assigned to these viilves is 3.00 seconds for closing and 10 seconds for opening.

Note 2: h stroke time for this valve is 24 seconds + 25% for opening and 19.5 seconds + 25% for assigned to closing. 'Ihe maxima stroke time for tEis valve is 30 seconds for opening and 24 seconds for closing.

Note 3: hse valves are similar to other valves with a maximm stroke time of 15 seconds.

5. h NRC has concluded that the applicable leak test procedures and requirenents for contaiment isolation valves are determined by 10 CFR 50 Appendix J, however, the licensee nust conply with the Analysis of Iatakage Rates and Corrective Action Requirements Paragraphs of Section XI, IW-3426 and 3427.

Response h Appendix J, type C requirements are inplemented in lieu of paragraphs lW-3421 through IW-3425. Iaiakage rate analysis and corrective actions as required by IW-3426 and 3427 will be performed.

B. Reactor Coolant System

1. Provide a more specific technical justification for not full-stroke exercising reactor head vent valves during each cold shutdown.

PAGE 6 0F 24

i Response: h IST Progr e will be changed to indicate full-stroke exercisin6 of head vent valves HV-0442A&B, HV-8095A&B,

) and HV-8096A&B on a cold shutdown frequency.

i

2. What is the safety function of valves LV-0459 and 04607 Response: Further review of these valves indicates that they are not required to perfom a safety function. Rese

. valves will be r eoved fr a the IST Program.

3. He NRC staff's position is that the PORV's function is to protect 4

the reactor vessel and coolant syst e fr a low-teuperature 4 overpressurization conditions and should be exercised prior to 4

2 initiation of syste conditions for which vessel protection is needed. Routine quarterly exercising of the PORVs during power l operation is not required.

Response: h IST Program will be changed to indicate that the PORV's (PV-455A and PV-456A) will be tested before the

! cold overpressurization protection system is required to be operable. Note: Technical Specification (NRC j

Proof & Review Copy) 3.4.9.3 establishes when these .

valves are required to be operable for low-tmperature overpressurization.

j 4. What is the safety function of valve U4-0207 i

Response: Valve U4-020 is a manual test connection valve which

! is utilized during Appendix J type C leak rate

! testing. Bis valve is tx>t required to be included in the IST Program as discussed with the NRC staff on

! October 8 & 9, 1986. E is valve and other similar l valves will be r eoved fr a the ISr Program.

l l 5. Should valve U6-112 be categorized A/C7 Is this valve ever open

during plant operation?

l Response: h is valve is a check valve and as such should be

, categorized AC. H e IST Progr e will be changed to 1

indicate that this valve is active. Relief will be c requested to allow the App-the J type C leak rate test

! to be the method of assuring closure capability of this l valve during refueling.

6. Review the safety function of valves HV-8145 and 033 (P&ID No.

i 1X4DB112 D-5) to detemine if they should be included in the IST Program.

l Respcnse: 2 ese valves are not required to perform a safety related function. H e safety grade means of depressurization of the RCS involves venting steam fra the pressurizer to the pressurizer relief tank via the power operated relief valves.

PAGE 7 0F 24

,---.---_,w-,~~,__, ,,,_...-.w. .w, c w ww.-,m

C. Nuclear Service Cooling Water Syste

1. Are valves W-2134, 2135, 2138, and 2139 leak rate tested to the Appendix J requirements for contairunent isolation valves?

Response: h contaiment penetrations associated with these valves are not required to be Appendix J type C leak rate tested by ESAR Table 6.2.4-1.

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

P&ID No. 1X4DB135-2 location W-1807 E-7 W-1809 G-7 W-1823 D-3 W-1831 D-1 P&ID No. 1X4DB135-1 Iocation W-1806 F-5 W-1808 H-5 W-1822 E-2 W-1830 G-2 Response: h valves listed above are the outboard valves for the Nuclear Service Cooling Water Syst e to the containment coolers. 'Ihese valves are open during normal operation, shutdown, and post-accident conditions. Since these valves are not recuired to change position to perform a safety relatec; function, they are considered " passive".

D. Safety Injection Syst e

1. ht is the' safety function of valves W-0943A&B and valves W-8875A-H7 Response: 'Ihese valves are normally used to fill and vent the acctmulator tanks as required to maintain the within Technical Specification limi.ts, h se valves can also be used to depressurize the acctmulator tanks for cold shutdown if necessary.
2. How are check valves U6-079, 080, 081, and 082 full-stroke exercised during refueling?

Response: h IST Program will be revised to require disassably and full-stroke exercising of these valves on a staggered test basis during refueling outages. An alternate method of testing has been proposed to the NRC staff and is presently being evaluated in lieu of disassembly.

PAGE 8 0F 24

3. What is the safety function of valve W-8843?

Response: Valve W-8843 is required to be closed during accident conditions. Technical Specification (NRC Proof & i i

Review Copy) 4.6.3.3 requires this contairment isolation valve to be tested.

4. Provide a more specific technical justification for not full - or
partial-stroke exercising check valves U6-013, U4-026, 027, 028, and 029 quarterly during power operation.

Response: Injecting water into the RCS through the boron

injection tank during power omration exmses the safety injection nozzles to twrmal shocc. The IST Program will be revised to discuss themal shock in RR-5.

I 5. Are valves 8802A&B recuired by Technical Specifications to be j disabled in the closec. position during plant operation?

Response: Technical Specification (NRC Proof & Review Copy) 4.5.2a requires verification once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that i the power is removed from the valve operators and that these valves are in the closed position. The IST ,

Program will be changed to reflect a test frequency of 4

cold shutdown for these valves with appropriate justification.

6. Provide a more specific technical justification for not full-stroke exercising valve W-8806 quarterly during plant operations. i Response: Valve W-8806 isolates the Refueling Water Storage Tank frcan the suction of the Safety Injection Ptmps.

Failure of this valve in the closed position could render both safety injection ptmps inoperable. To close this valve during plant operations is contrary to the intent of Technical Specification (NRC Proof &

Review Co:or) 4.5.2a which requires verification once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the power is removed from the valve operator and that the valve is in the "Open" position.

l

7. Provide a more specific technical justification for not full-stroke exercising valves W-8809A&B quarterly during power i operation.

Response: Valves W-8809A&B isolate the RHR discharge from the RCS cold legs when they are closed. Failure of these valves in the closed position would render that portion of low head safety injection inoperable. To close l these valves durirn plant operations is contrary to the intent of Technica.. Specification (MtC Proof & Review

! Copy) 4.5.2a which requires verification once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the zwer is removed from the valve operators and that the valve is in the "Open" position.

i.

PAGE 9 0F 24 -

8. Would failure of valve W-8813 in the closed position during l quarterly testing render an entire safety syst e inoperable?

l Response: Failure of valve W-8813 would render both miniflow lines for the Safety Injection Ptmps inoperable. h IST Program will be changed to reflect a test frequency of cold shutdown for this valve with oyyrvyciate justification. It should be noted that this valve is included in Technical Specification (NRC Proof & Review Copy) 4.5.2a which requires verification once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the power is removed from the valve operator

, and that the valve is in the "Open" position.

l 9. Do valves W-8814 and 8820 (sic) perform a safety function in the open positica?

Response: Valves W-8814 and W-8920 perform a safety function in the open position by allowing ptmp miniflow operation. Stroke time testing these valves from the closed position to the open position is unnecessary because these valves are normally open. h open safety position will be added to the IST Program.

10. Provide a more specific technical justification for not

' full-stroke exercising valves W-8821A, 8821B, and 8835 quarterly during power operation.

Response: These valves when closed isolate the discharge of the safety injection punps to the RCS cold lega. During normal operation these valves are open which is their alig ment for safety injection into the RCS cold legs.

If either of valves W-8821A or W-8821B would not re-open following testing it would result in that train of l

safety injection being inoperable. If valve W-8835 would not re-open following testing it would result in both trains of cold leg safety injection being inoperable. It should be noted that valve W-8835 is included in Technical Specification (NRC Proof & Review j Copy) 4.5.2a which requires verification once every 12

! hours that the power is removed from the valve operator and that the valve is in the "Open" position. The IST Program will be changed to reflect quarterly full-stroke exercising for valves W=8821A and W-8821B.

11. Would failure of valve W-8840 in the open position during quarterly testing divert low pressure safety injection from the analyzed flow path?

Response: Valve W-8840 opens during the post-accident recircula tion phase for low pressure safety injection into the RCS hot legs. During normal operation this valve is closed which ensures that low pressure safety injection is to the RCS cold legs. The IST Program will be changed to reflect a test frequency of cold shutdown for this valve with appropriate justification.

4 PAGE 10 0F 24

It should be noted that this valve is included in Technical Specification (NRC Proof & Review Copy) 4.5.2a which requires verification once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that the pcwer is raroved frm the valve operator and that the valve is in the " Closed" position.

12. Provide a more specific technical justification for not full-stroke exercising valves W-8923A&B quarterly during power operations.

Response: Further review of these valves indicates that they are not required to perfom a safety function. These valves will be removed fr m the IST Program.

13. We is the safety function of valves U4-016, X165, and X444?

Response: These valves will be removed fr a the IST Program.

Refer to Question B.4 for general explanation.

14. How is each of the following valves full-stroke exercised during the refueling outage testing identified in relief request RR-6?

Valves U4-143, 144, 145, and 146.

Response: These valves are tested during refueling with flow when the reactor vessel head is renoved. The total flow frm one safety injection ptmp will be connared to the system flow balance requirments of the Tecmical Specifications to verify that these valves open to perfom their function.

15. How is each of valves U6-128 and 129 full-stroke exercised during cold shutdown?

Response: These valves are tested during cold shutdown with flow frm the RHR xmps. The maxinun required flowrate will be verified trough each valve.

16. How is each of valves U6-147, 148, 149, and 150 verified to full-stroke during the cold shutdown exercise test?

Response: hse valves are tested during cold shutdown with flow fra one RHR punp. The total flow from one RHR pump will be conpared to the system flow balance requirements of the Technical Specifications to verify that these valves open to perfom their function

17. ht is the safety function of valve W-8924?

Response: This valve is required to close if valves W-8807A&B will not close during post-accident conditions to minimize the affects of a passive failure on the safety injection ptmp side of valves W-8807A&B.

PAGE 11 0F 24

. . 1

18. How is each of valves HV-083, 084, 085, and 086 (sic) full-stroke exercised during cold shutdown?

Response: Valves U6-083, 084, 085, and 086 will be partial-stroke exercised during shutdown with flow from the l RHR pugs. The IST Program will be revised to indicate (1) partial-stroke exercising during cold shutdown and (2) disassably and full-stroke exercising of these valves on a staggered test basis during refueling

. outages. Refer to Question D.2.

19. How does the ECCS test line subsystem individually verify leak tight integrity of series pressure boundary isolation check valves (i.e., U6-123 and 124)?

Response: h valves closest to the RCS are pressurized from the RCS. The second valves from the RCS are utilizing test connections and "jtmpers" pressurized to obtain theby appropriate test pressures. The leakages are measured by opening the appropriate valves and measuring the leakage rate.

20. Review the safety function of the following valves to determine if they should be included in the ISr program.

HV-8877A-D (P&ID No. IX4DB120)

HV-8879A-D (P&ID No. IX4DB120)

HV-8889A-D (P&E No. 1X4DB121) hV-8803A&B (P&ID No. IX4DB119)

HV-8870A&B (P&ID No. IX4DB119)

HV-8883 (P&E No.1X4DB119) 041&O42 (P&E No. 1X4DB119)

HV-8882 (P&E No. IX4DB119)

Response: Valves HV-8877A-D, HV-8879A-D, HV-8889A-D, and W-8882 are part of the leak rate test subsystem used during testing of the RCS pressure isolation valves. These valves do not perform an active safety function.

Valves HV-8803A&B, HV-8870A&B, and HV-8883 are referenced to notes 8 and 9 on P& E 1X4DB119 which state that the power is disconnected to these valves.

Therefore these valves are not capable of performing an active safety function. Valves 041 & 042 are also not capable of performing an active safety function because they are located in series with manual valves which are normally closed.

E. Residual Heat Removal System

1. What alternate methods have been considered for verification that valve position is accurately indicated for valves HV-881L%B?

Response: The requirements of IW-3300 will be met for these valves.

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2. Do testable check valves U4-122 and 123 utilize a manual operation lever or a zwer operated actuator for demonstration of full-stroke capaaility?

Response: Valves 11205U4122 and 11205U4123 utilize a manual operation lever for their full-stroke testing.

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

P&ID No. 1X4DB122 location W-0610 H-5 W-0611 E-5 W-8986A (sic) B-4 HV-8986B B-4 Response: Valves W-0610 and W-0611 will be added to the IST Program and tested to Code requirements. Refer to Question 0.1 for valves HV-8986A&B.

F. Containment Spray System

1. Does the procedure for quarterly. full-stroke exercising valves HV-8994A&B render the entire contaiment spray systen unavailable during plant operation?

Response: The IST Program will be changed to reflect cold shutdown testing of these valves with appropriate justifica-tion. The spray additive tank should not be rendered inoperable for velve testing.

2. What alternate methods have been considered for verification that valve position is accurately indicated for valves HV-9002A&B?

Response: The requirements of IW-3300 will be met for these valves.

3. What alternate methods have been considered for' verification of closure capability of valves U6-001 and 008?

Response: The only other method which has been considered for verification of closure capability of valves U6-001 and 008 is to measure differential pressure. However, the systen design does not contain valves which could be utilized to isolate the necessary boundaries to set up conditions to observe a pressure differential across these valves.

4. How are check valves U6-037 and 038 verified to close during quarterly exercise testing?

Response: During the pmp test on one train, the valve in the other train will be verified closed by observing the suction and discharge local pressure gauges on the PAGE 13 0F 24

tntested pmp piping. 'Ihe pressure will be read before and during the puup test. A decrease in pressure while the pmp is operating would indicate that the pmp is pulling water through the eductors and that the check valve is stuck open.

5. Review the safety function of the vacutzn breakers on the s ray additive tank to determine if they should be included in t w IST progre.

Response: h vacutan breakers will be added to the IST Progra and tested to the Code requir ments for Category C check valves.

G. Chanical and Voltane Control Syste

1. How are valves HV-0190A&B utilized for safety grade cold shutdown as described in relief request RR-15? Provide additional discussion why stroke time measurenents will not provide meaningful data for determining valve degradation for these valves.

Response: h stroke time will be measured for these valves.

2. Provide a more detailed technical justification for not full-stroke exercising valve HV-8110 quarterly during power operation.

(CS-11 appears to be incorrect.)

Response: h IST Progran will be changed to indicate quarterly testing for this valve.

3. W at is the safety function of valves HV-8485A&B in the closed position?

Response: After further w aew, it was determined that these valves do not ' ave a safety function in the closed position. 'Ib IST Program will be changed to delete j ' the valve.

4. Do valves LV-0112D&E perform any safety function in the closed position?

Response: '1hese valves are required to close during the post accident recirculation phase. IST Prvar-u will be l changed to reflect a closed safety position for these j , valves.

5. Do valves U4-140 and 147 perform any safety function in the closed position?

Response: normal operation these valves prevent reverse flow train-to-train in the Chemical and Voltane Control System. accident conditions valves HV8111A&B receive a ety injection signal to close and this precludes reverse flow through check valves U4-l 140 and 147.

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6. How are valves U6-142 an 149 full-stroke exercised quarterly during power operation?

Response: After further review, it was determined that only a partial-stroke exercise test is possible during power operation. h IST Program will be changed to reflect quarterly partial-stroke testing and full-stroke testing during refueling. A full-stroke exercise test during cold shutdown could overpressuri::e the RCS.

7. Provide a more specific technical justification for not partial-stroke exercising valves U6-189 and 436 during cold shutdown. How and when are these check valves verified to close to perfom that safety function?

Response: Partial-stroke exercising of these valves during cold shutdown is possible. Tae IST Program will be changed to reflect forward partial-stroke exercising during cold shutdown and full-stroke exercising during refueling. h motor operated valves located upstream of these check valves are capable of closing.

h refore, these check valves are not required to close to prevent reverse flow. h IST Program will be -

changed to reflect only an open safety position for these check valves.

8. Are reactor coolant pmps stopped during each cold shutdown to facilitate exercising seal water isolation valves HV-8100 and 8112?

Response: h plant test procedure requires that the reactor coolant pmps be stopped to facilitate testing valves HV-8100 and HV-8112.

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9. Wat is the safety function of valve HV-15214?

Response: Valve HV-15214 closes when a downstream line break is detected. Tenperature indicatcrs are located in j various rooms outside contaiment which can signal this valve to close.

10. Do valves HV-8105 and U6-032 perform any safety function in the open position? '

i Response: These valves have an open safety function to support i cold shutdown. The IST Program will be changed to i

reflect an open safety position.

11. Review the safety function of the following valves to determine -

if they should be included in the IST program.

P&ID No. 1X4DB114 location HV-8113A-D (sic) A-6 355 A-7 354 A-7 353 A-7 i 004 A-7 i

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P&ID No. IX4DBil6-1 Iocation HV-182 C-7 W-121 B-6 129 C-5 124 E-3 499 D-3 HV-8439 D-3 HV-8104 D-1 185' D-1 P&ID No. 1X4DB116-2 Location HV-8438 D-7 HV-8509A D-5 HV-8509B F-5 P&ID No. 1X4DB118 location 284 D-5 299 B-5 Response: Valves HV-8103A-D, 355, 354, 353, and 004 do not close to perfom a safety function. The RC punp seal injection remains in operation during accident conditions.

Valves HV-182 and W-121 are control valves and are exmpt per IW-1200. If these valves are not operating properly, it will be detected during nomal operation and corrected.

Valves 129 and 124 are not required to change position to perfom a safety related function.

Valves 499, & 185, will be added to the IST Program and tested to the open position during cold shutdown.

Testing during nomal operation could cause changes in RCS boron concentration and could result in a plant shutdown. Valves HV-8439, HV8104, 284 & 299 will be added to the IST Program and exercised quarterly.

Valves HV-8438, HV-8509A, and HV-8509B are not required to change position to perfom a safety related function.

H. Nuclear Sacpling-Liquid System

1. Does valve HV-8220 perfom any safety function in the open position?

Response: Refer to Question 0.1.

I. Auxiliary Cmponent Cooling Water System

1. Are the reactor coolant pmps stopped during each cold shutdown to facilitate full-stroke exercising valves HV-1974,1975,1978, and 19797 l

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Response: h reactor coolant ptmps are stopped while full-stroke exercising these valves.

2. What alternate tests have been considered for verification of closure capability of valves,U4-084, 085, 086, and 087?

Response: An alternate method for testing these valves would be to pressurize the downstream side of the check valves and nionitor pressure. h IST Program will be changed to reflect this alternate method in lieu of disasserbly.

3. Provide sheet 2 of 2 of the valve list of this system.

Response: Sheet 2 of 2 for this system does not exist. The reference on page 4-34 to " Sheet 1 of 2" will be changed to indicate " Sheet 1 of 1".

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

P&ID No. IX4DB138-2 Iocation W-19051 E-7 W-19053 C-7 -

W-19055 B-2 W-19057 F-1 W-2041 F-7 Response: hse valves will be added to the IST Program and tested to the closed position during cold shutdown.

Testing during normal operation would stop cooling water to the thermal barriers. (This voids the response in I.3.)

J. Main Steam Systen i

1. Do valves W-3009 and 3019 perform a safety function in both the open and closed positions?

Response: Valves W-3009 and W-3019 are required to close to perform a safety funccion. The normal position of

, these valves is open which allows steam flow to the auxiliary feedwater turbine. Since the normal position of these valves is considered open, testing to the open position is unnecessary.

2. Do valves U4-0% and 008 perform a safety function in both the open and closed positions? How are these valves verified to full-stroke exercise to their safety related positions?

Response: Valves U4-006, U4-008, and U4-404 are recuired to open to allow steam flow to the auxiliary feecwater turbine. h se valves will be partial-stroke exercised during quarterly ptmp testing and full-stroke exercised during cold shutdown. h ISE Program will be changed I

PAGE 17 0F 24

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to reflect a closed safety position on valves U4-008 and U4-404. Valve U4-006 is not required to close. l Valve U4-404 will be verified capable of closing by l closing valve HV-3009 and listening for stem to stop i flowing through the AFW drain to the condenser. This l will be performed quarterly while the AFW punp turbine is being supplied stem through valve U4-008. Valve U4-008 cannot be verified closed when the system is hot without jeopardizing personnel safety. Valve U4-008 will be disassembled and manually full-stroke exercised during refueling outage.

3. Provide the P&ID that shows valve U4-404.

Response: This valve is shown on P&ID 1X4DB159-2. A copy of this P&ID was provided to the NRC during the meeting on October 8 & 9, 1986. The response to Question J.2 above describes the testing of this valve.

K. Auxiliary Feedwater System

1. Do valves U4-001, 002, and 014 perfoun a safety function in the closed position?

Response: Adequate assurance to preclude steam binding is provided by testing valves U4-113, U4-114, U4-115, and U4-116 for closure. Tenperature is emputer monitored on the discharge of the AFW pmps and alarms on high tenperature. This is adequate to ensure system function and testing of valve U4-001, U4-002, U4-014, U4-017, U4-020, U4-023, U4-026, U4-037, U4-040, U4-043, and U4-046 to the closed position is unnecessary.

2. Do any of the following valves perform a safety function in the closed position?

P&ID No. IX4DB161-2 U4-017 U4-037 U4-020 U4-040 U4-023 U4-043 U4-026 U4-046 i

P&ID No. 1X4DB168-3 U4-113 U4-114 U4-115 U4-116 Response: Valves U4-017, U4-020, U4-023, U4-026, U4-037, U4-040, U4-043, and U4-046 are discussed in question 1 above. Valves U4-113, U4-114, U4-115, and U4-116 will be changed in the IST Program to reflect a closed safety position. The pressure gauges upstream of the valves will be monitored quarterly to ensure that these j valves are closed.

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3. How are valves U4-014, 017, 020, 023, and 026 full-stroke exercised during cold shutdowns?

Response: During the cold shutdown cycle the turbine-driven auxiliary feedwater pmp will be aligned for full flow. h flow rate through each valve will be measured and conpared to each other to verify that these valves are operating properly. Acceptable flow from the p mp verifies that valve U4-014 is operating properly.

4. m y are the following valves included in the IST program if their internals have been renoved as indicated by note 3 on P&ID No.

1XDB161-27 U4-013 U4-052 U4-033 U4-058 U4-051 U4-061 Response: Revision 17 of P&ID No.1X4DB161-2 does not reflect a note 3 which indicates that internals have been recoved from these valves. These valves will be partial-stroke exercised quarterly and full-stroke exercised during cold shutdown.

5. Provide a more specific technical justification for not full-stroke exercising valves HV-15196, 15197, 15198, and 15199 quarterly during power operation.

Response: During normal operation, feedwater flows through both the main feedwater and the bypass feedwater lines. The bypass feedwater lines are operated continuously during operation to minimize transients to the feedwater nozzles which have caused nozzle cracking in other plants. To test these valves and isolate the bypass feedwater line flow is contrary to their designed function.

6. W at safety function do valves U4-ll7, 118, 119, and 120 perform '

in the open position?

Response: These valves are not required to perform a safety function in the open position. The IST Program will be changed to delete the open safety position.

7. Is the flowrate through check valves U4-125, 126, 127, a d 128 during power operation greater than or ecual to the safety flowrate required frcxn the auxiliary feecwater systen?

Response: The test frequency for these valves will be changed from cold shutdown to quarterly. Normal plant operation assures that these valves are open.

PAGE 19 OF 24

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

P&ID No. 1X4DB168-3 location U4-121 H-2 U4-122 H-4 U4-123 H-6 U4-124 H-8 P&ID No. 1X4DB161-2 location W-5154 C-6 W-5155 B-6 Response: Note 3 on P&ID 1X4DB168-3, Revision 17 indicates that the discs are r eoved from valves U4-121, U4-122, U4-123, and U4-124. Therefore these valves are incapable of performing a safety function.

Valves W-5154 and W-5155 will be added to the IST Program and tested to Code requirements.

K. Condensate Feedwater System

1. h t alternate methods have been considered for verification of check valve closure capability of valves U4-071, 073, 075, and 0777 Response: h only other method which has been considered for verification of closure capability of valves U4-071, U4-073, U4-075, and U4-077 is to measure differential pressure. The syst e design does not contain valves which could be utilized to isolate the necessary boundaries to set up conditions to observe a pressure differential across these valves.

L. Contaiment Air Purification and Cleanup Systen l 1. Do valves HV-2624A&B perform any safety function in the closed position?

Response: hse valves perform a conrMr=mt isolation function l in the closed position. h se valves are normally l closed during normal operation and as such, would not l be required to change position to perform their l containment isolation function. However the Technical i S mcifications require that these valves be tested to t m closed position. h refore, the IST Program will be changed to reflect a closed safety function which will result in testing these valves to the closed position.

i 2. Does valve U4-012 perform any safety function in the open position?

Response: Valve U4012 is a manual valve and as such, is incapable of performing an " active" safety function.

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3. Do valves W-2790A, 2790B, and 2791A perform any safety function in the open position?

Response: h IST Propam will be changed to reflect an "Open" and Closed" safety position for valves W-2790A, 2790B, & 2791A. In addition valves W-2791B, 2792A&B, 2793A&B, U4-001, and U4-002 will be added to the IST Program. Relief will be requested to verify closure of U4-001 and U4-002 by Appendix J leak testing.

4. Review the safety function of valve W-8221 P&ID No.1X4DB213-2 location D-6 to determine if it should be included in the IST Program.

Response: Refer to Question 0.1.

M. Service Air System

1. Provide a more specific technical justification for not full-stroke exercising valve W-9385 quarterly during power operation.

Response: Valve W-9385 will be exercised quarterly in accordance with Code requirments.

N. Nitrogen to Acetmulators System

1. Is valve U4-017 ever open during plant operation?

Response: 'Ihis valve will be identified as " active" and closure verification will be performed during refueling outages by Appendix J leak rate testing. Relief will be requested.

O. Post Accident Sampling System

1. 'Ihe NRC staff position is that the operability of this system is required by NUREG-0737 (It s II.B.3), therefore, all valves in this syst e required for operation uust be included in the IST program and tested to the Code requirements.

l Response: h post accident sampling system is not identified as

being ASME Code Class 1, 2, or 3 and such is not within the scope of Section XI valve testing as stated in IW-1100.

P. Diesel Generator Systens

1. Review the safety functions of the following valves to determine i

if they should be included in the ISr program.

PAGE 21 0F 24 1

P&ID No. IX4DB170-1&2 Location 044&050 C-3 047&053 C-4 730&770 H-3 736&764 , F-3 W-9068A&B G-5 W-9069A&B G-5 W-9070A&B G-5 W-9071A&B G-5 Nesponse: %ese valves are not identified as being ASME Code Class 1, 2, or 3 and as such, are not within the scope of Section XI valve testing as stated in IW-1100. Le testing required by the Technical Specifications is sufficient to assure operational readiness of the diesel generator systems.

2. Do tenperature control valves 'ILV-19096 and 19097 (location F-7) have a required fail-safe position?

Response: Same response as provided to question P.1 above.

II. Pump Testing Progra

1. How is inlet pressurb and pump differential pressure measured for the nuclear service cooling water peps?

Response: h e inlet pressure is determined fr m the basin level indicators. Le pmp discharge pressure is determined fr m pressure indicators downstream of the applicable pmps . He pmp differential pressure is determined fr m pressure differential indicators which receive input fract the level indicators and tre discharge pressure indicators.

2. How is vibration displacement measured on the submerged nuclear service cooling water pmps?

Response: Acceleroneters are mounted on the second stage bowl and on the driver stand. Vibration anplitude data is derived fr m a double integration signal and read from a hand held indicator.

3. Why are the nuclear service cooling water pmp bearing temperature measurement requirements considered non-applicable?

Response: 2 e bearings of the nuclear service cooling water pmps are in the main process flow path and therefore tenperature measurements are not required by IWP-4310.

4. Provide a more specific technical justification for not measuring pmp bearing temperatures for all pmps as required by Section XI.

PAGE 22 OF 24

Response: h once-a-year tenperature measurement will not provide significant information about ptmp conditions.

h long running time required to achieve tecperature stability could result in increased maintenance and repair. Delation of this measurement will not have significant affect on evaluating ptmp test results since other required test parameters are being measured.

5. Is the flow measurement instrtunent accuracy for the conpanent cooling water and nuclear service cooling water ptmps within the acceptable limits identified in Table IWP-4110-1?

Response: h flow measurement instruments used for testing the conponent cooling water and nuclear service cooling pumps have an accuracy within the limits identified in Table IWP-4110-1.

6. Does che ptmp vibration monitoring program utilize displacement or velocity measurements?

Response: At the present time, VEGP plans to measure ptmp vibration in units of displacement to the requirements of Table IWP-3100-2. If a decision is made in the future to use velocity measurement in lieu of displacement, acceptance, alert and required ranges will be established and forwarded for review.

7. Review the safety functions of the following punps to determine if they should be included in the IST program and tested to the Code requirments.

Diesel Circulating Cooling Water Punps Diesel Fuel Oil Transfer Pucps Spent Fuel Pit Cooling Ptmps Boric Acid Transfer Ptmps Response: h diesel circulating cooling water ptmps are identified on P&ID's 1X4DB170-1&2 as the engine driven l

jacket water ptmps. These ptmps are not identified as being ASME Code Class I, 2, or 3 and as such, are not l within the scope of Section XI ptmp testing as stated in IWP-1100. h testing required by the Technical l S mcifications on the diesel generators verifies that I

tuse ptmps provide sufficient cooling water to the diesels to prevent them from overheating.

l The diesel fuel oil transfer ptmps are identified on P&ID's IX4DB170-1&2 as the diesel fuel oil storage tank ptmps. h diesel fuel oil storage tank ptmps are not l identified as being ASME Code Class 1, 2, or 3 and as l such, are not within the scope of Section XI ptmp i testing as stated in IWP-1100. h Technical PAGE 23 0F 24

Specifications require that the day tanks be filled to a mininun level and as such, this assures these ptmps are operable.

Adequate make-up water can be provided to the spent fuel pit, therefore testing the spent fuel pit cooling ptmps is unnecessary.

'Ihe boric acid transfer ptmps will be added to the IST Program. Specific relief will be requested where Code requirements cannot be met.

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