ML20236A965

Forwards Questions & Comments Re Proposed Pump & Valve Inservice Testing Program.Questions & Comments Will Serve as Agenda for Requested Meeting to Resolve Concerns

ML20236A965
Person / Time
Site:	River Bend
Issue date:	10/09/1987
From:	Paulson W Office of Nuclear Reactor Regulation
To:	Deddens J GULF STATES UTILITIES CO.
References
NUDOCS 8710230262
Download: ML20236A965 (13)

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' N October 9,1987-o

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Docket No. 50-458'.

Mr.: James C. Deddens .

. Senior,Vice President, (RBNG)

-Gulf _ States Utilities .

1 P. 0; Box 220.

St. Francisville,,LA !70775' '

ATTN: ' Nuclear Licensing.

SUBJECT:

INSERVICE TESTING PROGRAM -: RIVER BEND. STATION, UNIT N0.-~1' i

The NRC staff and consultant, Idah'o': National Engineering Laboratory, have completed a preliminary review of your proposed pump and val _ve inservice- . . .;

testing ~ program,' Revision;3,-submitted by'your. letter dated January 30, 1987. l We have. identified a set of questions and comments. that need clarification. ~

We request that a: meeting. be' held at the River Bend Station .at; an early' date' i

to resolve the. concerns identified in the enclosure. The enclosed questions l and. comments.will! serve as'an agenda for this meeting. ' Formal. responses to  !

the questions prior to the meeting are not required; however, we-request that- l

~ draft: responses be' prepared prior to the meeting and that they be available j for the meeting.c )

I will contact your staff .in the near future to establish a mutually acceptable meeting date..

l Sincerely,.

< IS}

Walter A. Paulson, Project Manager l

Project Directorate :IV L ' Division of Reactor Projects - III, IV,'V and Special. Projects l

Enclosure:

l As' stated.

cc w/ enclosure: ,

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.See next page L

DISTRIBUTION '

3DocketJ11e c1. NRC PDR .Ltrni POR PD4 Reading J. Calvo P. Noonan' W. vaulson 0GC-Bethesda-

. E. Jordan J. Partlow ACRS=(10) PD4 Plant. File l

LTR NAME:' RIVER BEND INSER CE TESTING ,. j PD4/L PD Pl+ 'PD4/D[IN PNoona WPaulson:sr JCalvo 10/q/87 10/g/87. 10/1/87 8710230262 B71009 PDR ADOCK 05000458' P PDR ,

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.Mr. James C. Dedden.

Gulf States Utilities. Company River Bend Nuclear Plant ]

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CC:

Troy B. Conner, Jr., Esq. Mr. J. E. Booker Conner and Wetterhahn. Manager-River Bend Oversight P. O. Box 2951 l 1747 Pennsylvania Avenue,.NW

-Washington, D.C. 20006- Beaumont, TX 77704 l Mr. Eddie Grant' Mr. William H. Spell, Administrator  !

Director .- Nuclear Licensing Nuclear Energy Division R Gulf States Utilities Company Office of Environmental Affairs i P..O. Box 220 P.-0. Box 14690 St. Francisville, LA 70775 Baton-Rouge, Louisiana 70898 i i

Richard M. Troy, Jr., Esq' .

J.- David McNefil, III Assistant Attorney General in Charge Mr.

State of Louisiana Department of Justice William G. Davis, Esq. j 234 Loyola Avenue Department' of. Justice New Orleans, Louisiana 70112- . Attorney General's Office 7434 Perkins Road Resident Inspector Baton Rouge, Louisiana 70808 1 P. O. Box 1051 St. Francisville, Louisiana 70775 H. Anne Plettinger 3456 Villa Rose Drive i i

Gretchen R. Rothschild Baton Rouge, Louisiana 70806 Louisianians for Safe Energy, Inc.

1659 Glenmore Avenue Baton Rouge, Louisiana 70775 President of West Feliciana Police Jury Regional Administrator, Region IV P. O. Box 1921 U.S. Nuclear Regulatory Commission St. Francisville, Louisiana 70775 Office of Executive Director for Operations Mr. Frank J. Uddo 611 Ryan Plaza Drive, Suite 1000 Uddo & Porter Arlington, Texas 76011 6305 Elysian Fields Avenue ,

Suite 400 Philip G. Harris New Orleans, Louisiana 70122 Cajun Electric Power Coop. Inc. i 10719 Airline Highway i P. O. Box 15540 Baton Rouge, LA 70895 l

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RIVER BEND STATION q PUMP AND VALVE INSERVICE TESTING PROGRAM-

-QUESTIONS AND. COMMENTS l l

1. VALVE T'ESTING PROGRAM-A. General Questions and Comments j

1. Provide a list of all valves that are Appendix J, Type C, leak rate tested but.not included in the.IST program and categorized A or A/C.

2. '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-staff; i requires that the licensee provide a technical justification for (

each valve that cannot be exercised quarterly during power-operation that clearly explains the difficulties or hazards I encountered during that testing. The 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 acceptable when the

'following conditions are met: ,

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

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 /> after shutdown, and continue until complete or the plant is ready to return to' power.

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

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.Any testing not completed during one cold shutdown should be j c.

performed during any subsequent cold shutdowns starting from- f I

the last test performed at the previous cold shutdown.

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A'different valve of_each group-is' required to be disassembled, .

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inspectod and manually full-stroked at each refueling, until the entire group has been' tested. .If it is found that the.

disassembled valve's full-stroke capability is in question, the' .

remainder of the valves in that group'must also be disassembled, ]

inspected, and manually full-stroked at the same outage.

= Valve Relief _ Request No 24'will-be_affected by this position.

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6. Valve Relief Request No. 50 is not necessary because Section.XI-does-_not identify any leak rate testing for category B. valves.

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'7. Valves that have been identified as: Passive in the -IST program do'

.not require a request for' relief from exercising'according'to-IWV-3700,1therefore, passive valves should be identified in the IST program and testing conducted in.accordance with Table .

IWV-3700-1. Various relief requests will;be affected.by this requirement.

8. Valves and pumps needed to support the operation of the HPCS diesel generator should be included in the IST program and tested

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in accordance with Section XI.

9. Air operated dampers in the' ventilation systems do not come under t

the definition of valves as addressed by Section XI and need not be included in the IST program.  ;

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B. Control Rod Drive Hydraulic System l E

1. Provide the current' revision of P&IO:36-10 for our review. q

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2.  : Provide the CR0 scram test schedule that is required by Technical

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j Specifications (refer-to Valve Relief Request No'. 33). \

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How are valves'V115 and V138 individually. verified to close- j

3. J cduring.CRD scram testing?.  ;

'i C. Reactor Recircu'l'ation System"

1. Provide a more specific technical justification for.not q

full-stroke. exercising valves-VF013A, 138,,17A, and 178 quar te r'l y.

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D. Condensate Makeup. Storage and Transfer System 1, What is the safety:related function o'f valves VF044A and 44B7 q

d E. -Feedwater System q l

1. Provide a more specific technical justification for not l full-stroke exercising valves VF010A, VF010B, A0VF032A,- and A0VF032B during cold shutdown.

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2. Concerning Valve Relief Requests No.3 and No 28, what are the .

.3 consequences of interruption of feedwater flow to the. reactor. ]

during power operation?

1 F. Main Steam System

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Provide a more specific technica1' justification for-not 'i 1.

full-stroke exercising, fail-safe testing, and stroke timing )

valves A0V022A, 228, 220, 220, 28A, 288, 280,- and 280 quarterly. l L -1 l

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2. Provide a more specific technical; justification for not l full-stroke exercising valves VF036A, 36F, 36G, 36J, 36L, 36M, ]

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36N, 36P, 36R, 398, 39C, 390, 39E, 39H, 39K, 395, V31, and V9 during cold shutdown.

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3. Provide a more specific technical. justification for not full-stroke exercising and stroke timing valves RVF041A, 418, 41C, 410, 41F, 41G, 41L, 47A, 478, 47C, 470, 47F, 47G, 47L, 518, 510, 510, and 51G quarterly.

4. Review the safety-related function of valves VF024A, 24B, 24C, 240 (p&ID 3-1A, locations F-14, L-7, K-14, and G-7), VF029A, 298, 29C, and 290 (P&lD 3-1C, locations K-18, N-18, H-18, and L-18) to determine if they should be included in the IST program. ,

G. Reactor Plant Closed Cooling Water System i

1. Provide a more specific technical justification for not full-stroke exercising valve V119 quarterly.

2. How are valves V133 and V160 verified to full-stroke open?

3. Provide a more specific technical justification for not full-stroke exercising valves V72 and V73 quarterly. Also, the functional description for these valves in Valve Relief Request No. 15 appears to be in error. What is the safety-related position (s) for these valves.

4. Provide a more specific technical justification for not full-stroke exercising valves MOV16A, 168, 129, 130, 335, and 336 quarterly.

5. If valves MOV163 and MOV169 have a safety-related function in the open position, then valves V75 and V80 (PalD 9-18, locations N-2 and M-2) should be included in the IST program and tested to the Code requirements.

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j H. Service Water System

1. Describe how the proposed refueling outage exercise testing of valves V135, 136, 143, 144,-326, and 327 meets the requirements of IE Bulletin No. 83-03.

2. Provide a more specific technical justification-for not full-stroke exercising valves MOV57A and 57B auarterly.

3.- What is the P&I'0 locations of valves 1SWP*V1102, 1SWP*S0V523A, and 1SWP*S0V523C? Also, the P&IO coordinates for valves RV49A, l

A0V51A, MOV73A, and MOV74A are incorrect.  !

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4. Provide a more specific technical justification for not 1 l

full-stroke exercising valves-V172 and V173 during cold shutdown, Provide a more specific technical justification for not verifying l 5.

the open position of valves V174 and V175 quarterly.

6. Provide a more specific technical justification for not full-stroke exercising valves V650 and V651 quarterly. J

7. What are the consequences of valve failure during quarterly full-stroke exercising of valves MOV507A and MOV507B (downstream valves MOV4A and MOV4B are exercised during cold shutdown as per Valve Relief Request No. 52)?

8. What are the consequences of valve failure during quarterly full-stroke exercising of valves MOV81A and MOV81B (downstream valves MOVSA and MOV5B are exercised during cold shutdown as per Valve Relief Request No. 52)?

9. Provide the P&ID(s) that show valves 1SWP*V1086, V1087, V1091, V1092, V1095, V1098, V1103, SOV522A, 50V522B, 50V522C, S0V5220, SOV523B, S0V5230, SOV552A, and SOV5528.

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.. .. .. 1 I. Service and Breathing Air System

1. Provide'a.more specific technical' justification for not full-stroke exercising and leak rate testing valve V487 in accordance with the. requirements'of Section XI.

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. Provide a more. specific technical justification ~for.not j

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j full-stroke exercising valves V514, V515,l V562, V563. V608, . and. 1 V609 quarterly. What are the consequences of testing these-valves quarterly?'

'3. Is valve V79 correctly identified as'to type on page 38 of Appendix C?

J. Standby Liquid Control-System i

1 Provide a more specific technical justification for not )

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full-stroke exercising valves VF006 and.VF007 quarterly.

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2. Provide a more specific technical justification for not - 1 full-stroke exercising valves MOVF001A, MOVF001B, VF033A, and ]

VF0338 quarterly.

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3. Why are valves VEXF004A and VEXF004B categorized as A?

i K .- Residual Heat Removal System

1. How are valves VF046A, 468, and 46C verified to full-stroke open quarterly?

2. Provide a more specific technical justification for not' full-stroke' exercising closed valves VF050A and VF0508'during cold shutdown.

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3. Is credit.taken for the steam condensing mode of the RHR system l 1

at River Bend? If not, should valves VF054A and VF0548 be included in the-IST program?

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4. Can valves VF085A,'858,;and 85C be verified.to full-stroke exercise closed using the valve handwheel?- .

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5. Why is valve VF]99C listed ~in valve. Relief. Request No. 31 and not j i

listed in Appencix C?'

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6. Valve VF041CLis not listed on Relief Request No. 31, but is .]

listed in Appendix C as being listed'on Relief Request No. 31. I i

L. Low pressure Core Spray l

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1. How is valve V10 verified'to full-stroke exercise open quarterly?. ]

2. How is valve VF033 verified closed quarterly?

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' i M. MSIV Positive Leakage Control System l

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1. What is the difference between valves E33-RV-F002 and E33-PV-F0227 Should these two' valves be included in the IST ]

program? )

N. Reactor Core Isolation Cooling System 1, What alternate methods have been investigated to verify closure of valves VF011 and VF061. quarterly?

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2. Describe the flow path. utilized to full-stroke exercise valve VF030 open quarterly. Does this valve. perform a' safety function

.in the closed position?

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3. Does valve VF040 perform a safety function in the closed position? If so, should it beLconsidered as a containment isolation valve and tested accordingly?

4. Provide a more detailed technical justification for not full-stroke exercising valve VF013 quarterly?

5. Would f ailure of valve VF063 in the closed position during quarterly exercising render an entire safety system inoperable?

Should this valve be exercised during cold shutdowns?

6. How is valve 11CS-V21 verified to full-stroke exercise quarterly?

0. MSIV & Penetration Valve Leakage Control System

1. In reference to Relief Request No. 4, identify the systems that would be affected while exercising the check valves listed in this relief request. Also explain the consequences of removing those systems from service for the purpose of check valve exercising.

2. Why are manual valves LSV-V64 and V65 listed as Category C valves?

P. HVAC Chilled Water System

1. How is the closed position of valve V421 verified quarterly?

Does this valve perform a safety function in both the open and closed positions?

2. Review the safety-related function of valve V420 to determine if l it should be included in the IST program.

Q. Containment Atmosphere and Leakage Monitoring System

1. What is the correct direction of flow through valve V41? Should both the open and closed positions be verified during testing?

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2. How are solenoid valves SOV31A, S0V31B, SOV31C, S0V310, SOV32A, SOV32G, 50V35A, 50V358, S0V35C, and S0V350 fail safe tested "as-is"? The P&ID indicates that these valves fail closed.

R. Fuel pool Cooling System

1. How are valves V350 and V351 full-stroke exercised quarterly?

S. Orains-Floor and Equipment system

. 1 '. What is the P&IO location of valve DER-V4?

2. Provide the P&ID that shows'the location of the vaives listed on page 104 of 105, Appendix C.

T. Sampling- Reactor plant System

1. Provide a more detailed technical justification for not full-stroke exercising valves SSR-V705 and V706 quarterly. In reference to Relief Request No. 43, inconvenience is not adequate justification for not performing the required testing.

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.j t'. 9, L ~2. PUMP' TESTING PROGRAM l

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1. Provide _ pump Relief Request No. 10 for'our review,

2. 'Why-is lubricant level listed asc"N/A" for.;the HPCS, RHR, LPCS, standby service water, and diesel'. generator fuel oil pumps?

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- 3. In reference to pump Relief Request No. 6, the NRC staff position is that instrumentation that meets the accuracy requirements of the ASME Code,Section XI, is readily.available on the commercial a I market and.should:be procured,' installed, and' utilized in order to' permit pump testing in accordance with Section XI.

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- 4, Provide a more detailed technical justification for not measuring, the inlet pressure of the standby liquid control pumps.during.

pump tests.

5. In reference to pump Relief Request No. 2, provide a detailed I technical justification for not establishing Required Action ranges for pump flow and differential pressure in accordance with -:i Section XI.

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6. How is flow measured during tests of the standby liquid control pumps?

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