ML20235J970

Forwards List of General Questions & Comments Re Updated Inservice Insp/Inservice Testing Programs Needed to Be Resolved Before Review Completed,Per Util 850625 Submittal

ML20235J970
Person / Time
Site:	Hatch
Issue date:	07/07/1987
From:	Crocker L Office of Nuclear Reactor Regulation
To:	James O'Reilly GEORGIA POWER CO.
References
NUDOCS 8707160084
Download: ML20235J970 (17)

Text

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Docket Nos.: 50-321 JUL 0 71987 50-366 Mr. James P. O'Reilly Senior Vice President - Nuclear Operations Georgia Power Company l P.O. Box 4545 l Atlanta, Georgia 30302 l I

Subject:

Updated IST Program for Hatch Units 1 and 2 l Georgia Power Company's letter of June 25, 1985 submitted updated inservice inspection / inservice testing (ISI/IST) programs for the Edwin I. Hatch Nuclear Plant, Units 1 and 2. By letter dated September 29, 1986, you were informed that the ISI portion of the program was acceptable for implementation, but that the IST portion of the program was still under review.

The initial review of the updated IST program has resulted in a number of questions and comments which need to be resolved before the review can be l completed. These are presented in the enclosure to this letter. We would l like to arrange a meeting at the plant site at an early date between the NRC l and contractor reviewers and knowledgeable plant personnel at which these l questions and comments can be discussed and necessary clarification obtained.

A formal response to these questions and comments is not required, but it would be helpful if draft responses were available at the time of the meeting. We  ;

would propose to use the enclosure as the agenda for the meeting. '

After GPC has had an opportunity to review the enclosed questions and comments, please contact me so that we may arrange a mutually agreeable meeting date.

Sincerely, Lawrence P. Crocker, Project Manager Project Directorate 11-3 Division of Reactor Projects I/II

Enclosure:

As stated l cc: See next page  ;

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Enclosure EDWIN I. HATCH NUCLEAR PLANT UNITS 1 & 2

_ PUMP AND VALVE INSERVICE TESTING PROGRAM REVIEW QUESTIONS AND COMMENTS

1. VALVE TESTING PROGRAM l

A. General Questions and Comments i

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1. Provide a list of all valves that are Appendix J, Type C. leak rate tested and that are not included in the Edwin I. Hatch Nuclear Plant Units 1 & 2. IST programs and categorized l "A" or "AC". I

2. ihe NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined l by 10CFR50, Appendix J. Relief from paragraphs IWV-3421 through 3425 for containment isolation valves oresents no safety problem since the intent of IWV-3421 through 3425 is met by Appendix J j requirements. nowever, the licensee shall comply with Paragraphs l IWV-3426 and 3427.

3. The Code permits valves to be exercised during cold shutdowns l where it is not practical to exercise them during plant operation and these valves are specifically identified by the licensee and are full-stroke exercised during cold shutdowns. The NRC staff reouires that the licensee provide a technical justification for each valve that cannot be exercised quarterly during power operations that clearly explains the difficulties or hazards that would be encountered during that testing. The NRC staff will then verify that it is not practical to exercise those valves and that the testing should be performed during cold shutdowns. Cold shutdown testing of valves identified by the licensee is I

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acceptable when the following conditions are met:

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a. The licensee is to commence testing as soon as the cold l

shutdown condition is achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 1 after shutdown, and continue until complete or-the plant is t ready to return to power.

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

c. Any testing not completed during one cold shutdown should be performed during any subseauent cold shutdowns starting from the last test performed at the previous coid shutdown.

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

Do the Edwin I. Hatch Nuclear Plant Units 1 & 2, IST programs conform to this staff position for valves tested on a cold shutdown frecuency?

4. Provide the limiting values of full-stroke times for the power #

operated valves in the Edwin I. Hatch Nuclear Plant Units 1 & 2, i IST programs for our review. What are the bases used to assign the limiting values of full-stroke time for these valves?

5. When flow through a check valve is used to indicate a full-stroke exercise of the valve disk the NRC staff position is that verification of the maximum flow rate identified in any of the plant's safety analyses through the valve would be an adeouate demonstration of the full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differential pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum 2 '

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l required flow through the valve. The Edwin I. Hatch Nuclear Plant Units 1 & 2. IST programs should conform to this staff positiCn.

6. The relief request and cold shutdown justification bases should-indicate the negative consequences that make testing at the Code required frecuency impractical such as endangering personnel, damaging equipment, or resulting in a plant shutdown.

7. Those valves, if any, that serve both a pressure boundary isolation function and a containment isolation function must be leak tested to both the Appendix J and the Section XI requirements. The Edwin I. Hatch Nuclear Plant Units 1 & 2. IST programs should conform to this staff position, therefore, provide clarification of the leak rate testing discussed under

" Pressure Isolation Valves" in Section 6 of the program.

8. The NRC staff position is that the emergency diesel generators  ;

perform a safety-related function and that the appropriate valves in the emergency diesel air start cooling water, and fuel oil transfer systems should be included in the IST program and be tested in accordance with the Code. Engine driven pumps are considered to be part of the diesel and need not be tested separately. Provide the P& ids that show these emergency diesel generator subsystems for our review.

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9. Solenoid operated valves are not exempted from the stroke time  :

measurement requirements of Section XI: their stroke times must l be measured and corrective action taken if these times exceed the limiting value of full-stroke time. The NRC staff will grant relief from the trending requirements of Section XI (Paragraph IWV-3417(a)) for these rapid-acting valves; however, in order to l obtain this relief, the licensee must assign a maximum limiting stroke time of two seconds to these valves.

10. The NRC staff position is that excess flow check valves perform a safety-related function and should be included in the IST program.

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11. Clarify the definition of " Passive Power Operatea Valves" contained in Section 6 of the IST Program. Why are these valves cyc l e d ?-

12. Relief Recuests and Notes that reference the FSAR, Technical Specifications, and other documents should be expanded to Drovide a brief discussion of the. applicable technical information containea in the referenced document.

l 13. The NRC staff has concluded that a valve sample disassembly and inspection utilizing a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke capability. This program involves grouping similar valves together and testing one valve in each group during each refueling outage. The sampling techniaue reauires that each valve in the group be of the same design (manufacturer, size, model number and materials of construction) and have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or Corroced parts).

A different valve of each group is reauired to be disassembled, inspected and manually full-stroke exercised at each refueling outage, until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in cuestion, the remainder of the valves in that group must also be disassembled, inspected and manually full-stroke exercised during the same outage.

B. Main Steam and Feedwater System

1. Provide a more detailed technical justification for not full-stroke exercising valves B21-F010A and -F010B ouarterly during power operation and cold shutdowns.

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2. Review the safety-related function of the main steam relief valves, B21-F013A. B, C, D. E, F, G, H. J, K L, and M to determvee if tney should be categorized B/C. If they are power operated, provide a detailed technical justification for not full-stroke exercising them and measuring stroke times cuarterly j

3. Provide Relief Reauest 6,J.23 for our review. Does this request apply to both IST programs or to the inboard MSIVs at Unit 1 and ]

l the outboard MSIVs at Unit 2?

1 4 Describe how the MSIVs are full-stroke exercised cuarterly.

5. Provide a more detailed tecnnical justification for not l

full-stroke exercising valves B21-F032A and -F032B auarterly during power operation and cold shutdowns. (Unit 1)

6. Is valve B21-F032A reauired to perform a safety-related function in both the open and closed positions? P&ID H-161B8 does not acoear to agree with P&ID H-16062. (Unit 1) 1

7. Provide a more detailed technical justification for not full-stroke exercising valves 2B21-F076A, -F076B, -F077A. and 1

-F077B auarterly during power operation.

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

F525 RV-F110G RV-F110A RV-F110H RV-F110C

. C. Reactor Recirculation System

1. Provide a more detailed technical justification for not full-stroke exercising valves B31-F013A, -F013B, -F017A, and

-F017B auarterly during power operation and cold shutdowns.

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2. What are tne consequences of full-stroke exercising valves B31-F031A and -F031B auarterly during power operation?

0. Standby Liouid Control System

1. Provide a more detailed technical justification for not  !

full-stroke exercising va,1ves C41-F006 and -F007 Quarterly.

2. How are valves C41-F006 and -F007 individually verified to close? ;

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3. How are valves C41-F033A and -F033B full-stroke exercised i cuarterly.

l E. Residual Heat Removal System

1. Provide a more detailed tecnnical justification for not full-stroke exercising valves E11-F008 and -F009 auarterly,

2. Review the safety-relatea function of valves E11-F021A and -F021B to cetermine if they should be categorized A.

3. Provide a more detailed technical justification for not full-stroke exercising valves E11-F078A and -F078B ouarterly.

How are these valves presently being full-stroke exercised?

4. Review the safety-related function of valves E11-F024A. -F0248,

-F027A. and -F0278 to determine if they should be categorized A.

5. Wny are valves E11-F026A and -F026B categorized A?

t. How are valves E11-F046A, -F046B, -F046C and -F0460 verified to full-stroke exercise cuarterly? Provide Note 29 for our review (Unit 2).

7. How is long term reactor cool down accomplished if credit is not I taken for the operability of valves E11-F068A and -F068B?

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8. Review tne safety-related function of the following valves to determine if they should be included in the IST program and tested in accordance with Section XI:

E11-F040 E11-F049 E11-F089 E11-F090 E11-122A E11-F1228 E11-F005A E11-F005B l Ell-F005C Ell-F0050 .

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9. Provide a discussion that justifies not measuring the stroke time of valves E11-F200A-D, and 2E11-F207A-D ouarterly. How are these valves fail-safe tested auarterly?

10. How are valves 2E11-F126A and -F126B fail safe tested auarterly?

11. Have valves 2E11-F201A-D been removed from the system? If not, they should be tested in accordance with Section XI.

F. Core Soray System

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1. How are valves E21-F036A and -F036B individually verified to  ;

full-stroke exercise quarterly?

2. What is the P&ID location of valves 2E21-F044A and -F044B?

3. Review the safety-related function of the following valves to <

determine if they should be included in the IST program and tested in accordance with Section XI:

E21-F029A E21-F029B E21-F030A E21-F030B E21-F037A E21-F037B G. High Pressure Coolant Iniection System

1. If failure of valve E41-F002 during cuarterly testing would render an entire safety system inoperable, then testing this valve during cold shutdowns should be considered.

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2. Is valve E41-F007 accessible during power operation? If it failed during testing, could it be reopened manually? Why is there a concern with failure of this valve during power operation wnen valve E41-F002, which is inaccessible, is exercised quarterly?

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3. Describe the containment..jsolation function performed by valve '

E41-F008.Section XI, Table IWV-3700, reavires that passive .

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Category A containment isolation valves be leak-rate tested. j 4 Valves E41-F008 and -F011 must change position to prevent diversion of flow if an initiation signal is received while the system is in the test mode. The NRC staff position is that these l valves snould be included in the IST program and tested in accordance with Section XI.

l 5. Relief Reauest 6.1.12 may not be necessary for the HPCI System l because the NRC staff position concerning full-stroke exercising of check valves is that if the valve is exercised by passing full design basis flow through it, then the valve is considered to have been full-stroke exercised. This position is satisfied by full flow tests of the HPCI pump and turbine.

l 6. The NRC staff position concerning the disassembly of valve E41-F045 is that disassembly to verify valve operability be performed each refueling outage instead of every other refueling l outage.

7. How is valve E41-F046 verified to full-stroke exercise quarterly?

8. Review the safety-related function of valves E41-F103 and -Fill to determine if they should be included in the IST program and tested in accordance with Section XI. l j

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9. Review the safety-related function of valves E41-F048 and -F057 to determine if they should be included in the IST program and tested in accordance with Section XI.

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10. Review the safety-relatea function of valves 2E41-F025 and -F026 to determine if they snould be included in the IST orogram and l tested in accordance with Section XI.

H. Reactor Core Isolation Coolina System  !

1. Relief Recuest 6.1.12 may.not be necessary for the RCIC System because the NRC staff position concerning full-stroke exercising of check valves is that if the valve is exercised by passing full design basis flow through it, then the valve is considered to have been full-stroke exercised. This Dosition is satisfied by full flow tests of the RCIC pump and turbine.

2.

Provide a more detailed technical justification for not measuring the stroke time of valve E51-F019 avarterly.

3.

How is valve E51-F021 verified to full-stroke exercise cuarterly?

4. Valve E51-F105 does not appear to be a self-modulating pressure control valve. Is this a typographical error in the Unit 1 IST program? Why does Relief Request 6.1.2 apply to this valve in the Unit 2 program?

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Is credit taken in any plant safety analysis for the operability of the RCIC pump? If so. the following valves should be included in the IST program and tested in accordance with Section XI:

E51-F010 E51-F011 E51-F012 E51-F014 E51-F022 E51-F029 E51-F030

6. Review the safety-related function of valves E51-F102 and -F103 1

i to determine if they should be included in the IST program and tested in accordance with Section XI.

7. Provide P&ID H-16334, Sheet 2. for our review.

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1. Reactor Water Clean-uo System l

1. Wny is walve G31-F039 identified as a passive containment isolation valve? Provide a detailed technical justification for l not full-stroke exercising this valve cuarterly. Why has this valve been omitted from the Unit 2 program?

J. Torus Drainage and Purification System 1

1. Wny is valve G51-F002 categorized AE?

2. I Review tne safety-related function of valve G51-F001 to determine i if it should be included in the IST program. l I

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What is the normal position of valves G51-F011 and -F012? The l t

l normal position indicated on P&lD H-16135 does not agree with Note 1 of the program. (Unit 1) 4 Why are valves 2G51-F011 and -F012 categorized AE?

K. Demineralized Water System l 1.

Why are Unit I valves P21-F353 and -F406 and Unit 2 valves 2P21-F032 and -F034 categorized A/E?

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Review the safety-related function of valve P21-F420 to determine if it should be included in the IST program.

L. Hydrogen and Oxygen Analyzer System 1.

Review the safety-related function of valves P33-F005 and -F013 (Unit 1) to determine if they should be included in the IST program and tested in accordance with Section XI.

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M. plant Service Water System I

1. Relief Teauest 6.1.14 does not meet the NRC staff position '

exclained in Item A.13 of these auestions, therefore, provide the appropriate relief reauests that include an exercising frecuency and grouping of valves that meets this staff position.

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2. Review the safety-related function of valves P41-F064 and -F065 to determine if they must also close to perform their safety function. (Unit 1) l

3. Review the safety-related function of valves P41-F066 and -F067 to determine if they should be included in the IST program and tested in accordance with Section XI. 1 I

4 Provide a discussion tnat justifies not measuring the stroke time of valves P41-F208A -F208B. -F208C. and -F2080 Quarterly. How l are these valves fail safe tested quarterly? (Unit 1) l

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5. Wnat are the P&ID locations of valves P41-F310A, -F310B, -F310C.

1 and -F310D? What are the consequences of full-stroke exercising I these valves during power operation?

6. How would failure of valve P41-F311A, -F3118, -F311C. or -F3110 in the open position affect plant operation? Should these valves also be verified to shut?

7. Provide the coordinates for the valves listed on Sheet 24 of 33 in the Unit 1 Valve Testing Program.

8. Review the safety-related function of valves P41-F438A and -F4388 to determine if they should be included in the IST program and tested in accordance with Section XI. (Unit 1)

9. Review the safety-related function of valves 2P41-F023A and l -F023B to determine if they should be included in the IST program and tested in accordance with Section XI.

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e 10 Valves 2P41-F315A and -F315B have not been idsntified as passive valves, therefore, they must be tested in accordance with the Section-XI requirements for Category B valves.

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11. What are the consequences of full-stroke exercising valves l 2P41-F316A, -F3168, -F316C and -F316D auarterly during oower operation? .

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12. Have valves 2P41-F319A-D been removed from the system? If not, ,

1 they should be tested in accordance with Section XI. I

13. Provide a aiscussion that justifies not measuring the stroke time of valves 2P41-F320A, -F3208 -F320C, and -F320D Quarterly. How are these valves fail-safe tested quarterly?

14 Review the safety-related function of valves 2P41-F306A and 1 -F306B to determine if they should be included in the IST program anc tested in accordance with Section XI.

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15. Provide a more detailed technical justification for not measuring l l

the stroke time of valves 2P41-F339A and -F339B auarterly. I

16. Wnat is the '4ID location of valve 2P41-F340?

l l 17. Review the safety-related function of valves 2P41-F321, l 2P41-F312A, and -F312B to determine if they should be included in the IST program and tested in accordance with Section XI.

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l N. Reactor Buildino Closed Coolino Water System i

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1. Provide a more aetailed technical justification for not full-stroke exercising valves P42-F051 and -F052 quarterly.

O. Service Air System

1. Why are valves P51-F513, -F514, and 2P51-F651 categorized A/E?

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1 P. Drywell Pneumatic System i

1. Review the safety-related function of the following valves to determine if they should be included in the IST program ana tested in accordance with Section XI:

821-F024A B21-F0248.. 821-F024C B21-F024D B21-F036A B21-F036B B21-F036C B21-F036D B21-F036E B21-F036K B21-F036F B21-F036G B21-F036H B21-F036J B21-F036L Q. Containment Purce and Inertino System

1. What is the normal cosition of valves T48-F118A and -F118B? The body of the IST program does not agree with the P&ID. (Unit 1)

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2. What is the normal position of valves T48-F319 and -F320? The body of the IST program does not agree with the P&ID. (Unit 1)

3. Why are Unit I valves T48-F318 and T48-F326 and Unit 2 valve 2T48-F318 normally open? Should these valves be normally shut?

4 Provide a detailed technical justification for not measuring the stroke time of valves T48-F323A-L Quarterly.

5. Provide a detailed technical justification for not measuring the stroke time of valves T48-F328A and -F328B Quarterly.

6. The NRC staff position concerning valves that do not perform a safety-related function is that if they are to remain in the IST program they must be tested in full compliance with the requirements of Section XI. This staff position will affect the test program for valves T48-F342A-L.

7. What is the normal position of valves 2T48-F209. -F210. -F211.

and -F212? The body of the IST program does not agree with the P&ID.

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R. T"aversino In-core Probe System l

1. Review tte safety-related function of the TIP shear valves to determine if they should be included in the IST program and tested in accordance with Section XI.

2. Is the TIP nitrogen purge. supply line eauippea with an isolation check valve? If so. it should be included in the IST program and its closed position verified.

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l S. Fission Products Monitorina System

1. What is the normal cosition of valve 2011-F053?

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2. Why are valves 2011-F058 and -F061 categorized A_: i

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MSIV Lea < ace Control System I

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1. Provide a more detailed technical justification for not full-stroke exercising valves 2E32-F006, -F007, -F008, and -F009 cuarterly.

U. Radwaste System

1. Why are valves 2G11-F852 and -F853 categorized AE?

V. ILRT System

1. Review the safety-related function of valves 2T48-F363A and

-F364B to determine if they should be included in the IST program and tested in accordance with Section XI.

W. Fire Protection System

1. Provide the P&lD that shows the location of valves 2T43-F159 and

-F160. Why is valve -F160 categorized AE?

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X. Reactor and Radwaste Buildino Service Air System

1. Review tne safety-related function of valves 2P51-F513 and -F651 ,

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

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Pumo Testino Procram

1. What is the basis for establishing a minimum vibration reading of 1.5 mils for all service water pumps in the IST program? How are vibration measurements of less than 1.5 mils trended from test to test?

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2. Provide the documentation that demonstrates that pump operational readiness is assured through the use of expanded ranges for reference values of flow and differential pressure.

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3. Describe the test flow path utilized when measuring the flow rate l of the standby liauid control pumps.

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4. Why were the spent fuel pool cooling oumps excluded from the IST progran? Do these pumps perform a safety-related function?

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. Mr. James P. O'Reilly Edwin I. Hatch Nuclear Plant, Georgia Power Company Units Nes. I and 2 cc:

G. F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Mr. L. T. Gucwa Engineering Department Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Nuclear Safety and Compliance Manager Edwin I. Hatch Nuclear Plant Georgia Power Company P. O. Box 442 Baxley, Georgia 31E13 Mr. Louis B. Long Southern Company Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 Resident Inspector U.S. Nuclear Regulatory Conmission Route 1, P. O. Box 279 '

Bax1ey, Georgia 31513 Regional Administrator, Region II l U.S. Nuclear Regulatory Commission la ta, eor a b3 Mr. Charles H. Badger Office of Planning and Budget 1

Room 610 270 Washington Street, S.W.

Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Consnissioner Department of Natural Resources 270 Washington Street, N.W.

Atlanta, Georgia 30334 Chairman Appling County Connissioners

! County Courthouse Baxley, Georgia 31513 l

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