ML20236H536
| ML20236H536 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/12/1987 |
| From: | Hartley S, Ransom C EG&G IDAHO, INC. |
| To: | Hou S NRC |
| Shared Package | |
| ML20236H522 | List: |
| References | |
| NUDOCS 8708050238 | |
| Download: ML20236H536 (31) | |
Text
.-
gg g ggah3 NOTEGRAM We value innt,vation.
1 FORM EGKG460A 1Rav 0584 t.
June 12, 1987
'l CW To:
Dr. Shou Hou From:
S. Hartley/C. B. Ransom Org:
NRC/ EMEB Org:
NRR and I&E Support Address: Bethesda, MD Address:
INEL-Idaho Falls, ID TRIP REPORT FOR THE-PUMP AND VALVE INSERVICE TESTING PROGRAM WORKING l
MEETING FOR MILLSTONE NUCLEAR POWER STATION, UNIT 3 j
On June 2 and 3, 1987, a working meeting was held at the Millstone Nuclear l
facility simulator building in Niantic, Connecticut with Northeast Nuclear Energy Company, NRC, and EG&G Idaho, Inc. representatives to discuss the questions resulting from the review of the Millstone Nuclear Power Station, Unit 3, pump and valve inservice testing (IST) program, j
Attached is a list of meeting attendees, the questions that served as an agenda for the meeting, and the responses to those questions as taken from
),
the meeting minutes and the written responses provided by the licensee.
The utility representatives were given a brief introduction outlining the l
agenda and the methods used for the documentation of questions and This was followed by detailed discussions concerning specific l
responses.
pumps and valves in the Millstone Nuclear Power Station, Unit 3, IST program.
i These discussions resulted in one open item for the licensee.
This open item is identified in this trip report.
i,.ve are several additional l
items where the licensee has agreed to make corrections or changes to their IST program as indicated in the responses to the questions.
Attachment:
As Stated t
cc: D. Caphton NRC/RI R. L. Ferguson NRC/PD I-4 i
H. L. Magelby f
C. F. Obenchain H. C. Rockhold E. J. Sullivan NRC/EMEB
~
B70B050238 B70724 DR ADOCK 05 g3
.l
~
. Attachment ATTENDANCE LIST INSERVICE TESTING PROGRAM WORKING MEETING Millstone Nuclear Power June 2 and 3, 1987 Station, Unit 3 Name Representing R. Scott Hartley EG&G Idaho /INEL Clair B. Ransom EG&G Idaho /INEL Shou N. Hou NRC/EMEB Robert L. Ferguson NRC/PD I-4 Donald Caphton NRC - Region I Keith Covin NU Unit 3 Operations
{
Augie Cardillo NU Unit 3 Engineering Mike Hess i
NU Unit 3 Engineering Janis B. Ossman NUSCO Engineering Ravi Joshi NU Licensing Tom Shedioski NRC MP3 Senior Resident l
e J
MILLSTONE NUCLEAR POWER STATION, UNIT 3 i
PUMP AND VALVE INSERVICE TESTING PROGRAM 00ESTIONS AND COMMENTS I.
VALVE TESTING PROGRAM l
l A.
General Questions and Comments 1.
Section 4.3.7 of the Millstone Unit 3 IST program does not agree with Section XI, Paragraph IWV-3416.
The Code requires valves to be exercised within 30 days prior to return of the system to operable status; why can't this Code requirement be met?
Response
The Millstone Unit No. 3 (MP3) IST Manual, Section 4.3.7 will be updated to add " prior to".
I g
2.
Are all valves that are Appendix J, Type C, leak-rate tested included in the Millstone Unit 3 IST prograin and categorized "A" or "AC"?
Response
l Yes, all Appendix J, Type C, valves are categorized "A" or "AC".
Any changes in the Appendix J program will be reflected by changes in the IST program.
3.
The NRC has concluded that e e applicable leak test procedures and requirements for containment isolation valves are determined by 10CFR50, Appendix J.
Relief from paragraphs IWV-3421 through 3425 for containment isolation valves presents no safety problem since the j
i
)
intent of IWV-3421 through 3425 ic met by Appendix J requirements, l
however, the licensee shall comply with Paragraphs IWV-3426 and 3427.
1 l
l
e*
1 l
Response
l The licensee will request relief from the requirements of IWV-3421 through -3425.
The licensee will comply with the requirements of IWV-3426 and -3427.
l 4.
The Code permits valves to be exercised during cold shutdowns 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 requires that the i
licensee provide a technical justification for each valve that cannot 4
.be exercised quarterly during power operations that clearly. explains the difficulties or hazards 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.
Response
i Valves that cannot be full-stroked during operations, but are tc be full-stroke exercised during cold. shutdowns are provided with their relief requests in.Section 7.0'(deferred tests) of the MP3-IST program.
The need for technical justification for components identified for cold shutdown testing was discussed.
j 5.
What are the bases used to assign the limiting values of full-stroke time for the power operated valves in the Millstone Unit 3 IST program? Provide the limiting values of full-stroke times for those valves that have NSR(1) in the maximum stroke time column of Table 5.4.
l 2
i j
i I
l a
e
Response
Stroke times were provided for all NSR (non safety related) designated valves.
For all NSR designated valves the baseline valve operating time measurement is doubled to provide the maximum limiting stroke time.
Upon exceeding this value corrective. action will be taken in accordance with IWV-3417(b).
The licensee will review the limiting values of valve full-stroke times for all other IST program valves.
Section 5.4-of the Millstone Unit 3 IST manual will be revised to address the actions to be taken upon exceeding the full-stroke. time limits established during this review.
6.
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
.k.
safety analyses through the valve would be an adequate 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 required flow through the valve.
Does the Millstone Unit 3 IST program conform to this staff position?
Response
The demonstration of full-stroke capability of check valves utilizing flow was discussed.
The utility will conform with the NRC staff position and will verify that these check valves pass the minimum acceptable flow for that accident scenario requiring the largest flow rate.
3
e 7.
The relief request and cold shutdown justification b'ases should' indicate the negative consequences that make testing at the Code required frequency impractical such as endangering personnel, damaging equipment, or resulting in a plant shutdown.
Response
This is understood. This item is addressed for each individual relief request where specific questions are asked addressing.this lack of information.
l B.
1 1.
How are. valves 3RCS*V31, 32, 71, 107, and 146 verified to full-stroke during cold shutdown testing 7
Response
f'.
Valves 3RCS*V31 and V32 do not perform a safety-related function and will be deleted from the IST program.
Check valve sample disassembly / inspection and valve grouping concerns were discussed.
The licensee will provide a relief request for valves 3RCS*V30, 71, 107, and 146 for sample disassembly / inspection te', ting at a refueling outage frequency.
Valve relief request R-3 will be revised and include only valves 3SIL*V15, 17, 19, and 21.
j 4
2.
What is the safety related function of valves 3RCS*V31, 32, 147, and 148? If these valves perform a safety-related function in the closed position, how are they individually verified to close? Do'these valves perform a pressure isolation function?
Response
Valves 3RCS*V31, 32, 147, and 148 do not perform a safety-related function and will be deleted from the IST program.
C.
Reactor Coolant Pump Seals 1.
Provide a more detailed technical justification for not full-stroke exercising valves 3CHS*V393, 433, 466, and 500 during cold shutdowns (Relief Request R-17 does not address the consequences of exercising these valves).
Response
.I.
Valves 3CHS*V393, 433, 466, and 500 will be included in the IST program and full-stroke exercised during refueling outages.
Relief will be requested from quarterly testing and more information will be provided to demonstrate the impracticality of exercising these valves during cold shutdown.
2.
Provide a more detailed technical justification for not full-stroke exercising valves 3CHS*V394, 434, 467, and 501 during cold shutdowns (Relief Request R-2 does not address the consequences of exercising these valves during cold shutdowns).
l 5
i
?
4 l
Response
i Relief request R-2 will be revised to include valves 3CHS*V394, 434,.467, and 501 and more technical justification will be provided.
D.
Chemical and Volume Control System 1.
Provide -a more detailed technical justification for not full-stroke exercising valves 3CHS*V5 and 802 quarterly during power operations.
l
Response
1 CSR-5 will be revised to include more' technical justification for not exercising these valves quarterly.
2.
Protide a more detailed technical justification for not full-stroke exercising valves 3CHS*V40 and 41 quarterly during power operations.
.?
Response
CSR-6 will be revised to include more technical justification for not exercising these valves quarterly.
3.
Provide a more detailed technical justification for not full-stroke exercising valves 3CHS*V46, 47, and 48 quarterly during power I
operations and during cold shutdowns.
1 i
Response
R-18 will be revised to include more technical justification and will address partial-stroke exercising these valves quarterly 3
during operations.
6
'4.
Provide a more detailed technical justification for not full-stroke exercising valves 3CHS*V56 and 57 quarterly during power operations.
Response
CSR-7 will be deleted and valves 3CHS*V56 and 57 will be added to CSR-5.
5.
Provide a more detailed technical justification for not full-stroke exercising valve 3CHS*V58 quarterly during power operations and during cold shutdowns.
Response
R-2 will be revised to include more technical justification for not testing valve 3CHS*V58 during cold shutdowns.
6.
Provide a more detailed technical justification for not full-stroke
),
exercising valves 3CHS*V333, 710, 711, and 712 quarterly during power operations.
Response
These valves will remain in the IST program.
CSR-8 will be revised to include more technical justification for not exercising these valves quarterly.
l 7.
Provide the P&ID that shows valves 3CHS*V487, 488, and 489.
Response
1 P&ID was provided.
No further questions.
8.
Provide a more detailed technical justification for not full-stroke exercising valves 3CHS*V532 and 533 quarterly during power operations and during cold shutdowns.
i 7
=
Response
R-17 will be revised to reflect that these valves wil1 be full-stroke execised during cold shutdowns when the RCS is depressurized.
9.
Review the safety function of valve 3CHS*V42 (P&ID 25212-26904 Sh. I location J-9) to determine if it should be included in the IST program and tested to the Code requirements.
Response
This valve is not safety-related and need not be included.in the IST program.
- 10. Do valves 3CCE*V9 and 21 (P&ID 25212-26905 locations E-2 and C-2) have a required fail-safe position?
If so, they are active valves and should be included in the IST program and tested to the Code requirements.
Response
Valves 3CCE*V9 and 21 will be included in the IST program and full-stroke exercised quarterly.
- 11. Would failure of valve 3CHS*V269 closed during quarterly stroke testing render an entire safety system inoperable?
Response
No.
These pumps are protected by miniflow relief valves which line up on the high pressure safety injection signal.
8
7 e
- 12. Review the safety related function of valves 3CHS*V294, 296, and 320.
(P&ID 25212-26904 Sh. 3 locations J-5, J-6, and F-4) to determine if they should be included in the IST program, i
Response
]
Valves.3CHS*V294, 296, and 319 will be included in the IST l
program and full-stroke exercised quarterly.
Valve 3CHS*V320 will be included in the IST program and full-stroke exercised at cold shutdown and the technical justification provided in CSR-23.
E.
Fuel Pool Cooling System 1.
Review the safety function of valves 3SFC*V3 and 6 (P&ID 25212-26911 locations G-9 and G-10) to determine if they should be included.in the IST program and tested to the Code requirements.
Response
i j
Valves 3SFC*V3 and 6 will be included in the IST program and full-stroke exercised quarterly.
F.
Low pressure Safety Injection System 1.
Would failure of valve 3SIL*VS or 11 closed during quarterly stroke testing render the low pressure safety injection system unavailable to perform its safety function?
Response
Failure of one of these valves would render the low pressure safety injection' system unavailable.
CSR-24 will provide the technical justification for not exercising these valves quarterly
-during operation.
9
2.
How are valves 3SIL*V6, 7, 12, and 13 partial-stroke exercised quarterly during power operations?
Response
These valves will not be partial-stroke exercised quarterly i
during operation oue to the possibility of hydraulic shock which could possibly result in equipment damage. These valves will be full-stroke exercised at cold shutdown.
3.
The proposed alternate test frequency for valves 3SIL*V15, 17, 19, and 21 does not adequately demonstrate the operability of these valves.
The NRC staff has concluded that a valve sample disassembly / inspection-l utilizing a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke capabilityi This program involves grouping similar valves together and testing one valve in each group during each refueling outage.
The sampling technique requires that each valve in the group be of the same design 4
(manufacturer, size, model number and materials of construction) and have the same service conditions.
Provide a justification for not meeting this NRC staff position.
Response
l l
l These valves will be included in a separate relief request and one valve will be disassembled and inspected on a sample basis each refueling outage.
If the operation of any disassembled valve is questionable then all valves in the group will be disassembled and inspected during the same refueling outage.
4.
Would failure of valve 3SIL*V25 open during quarterly stroke testing 1
render the low pressure safety injection system unavailable to perform l
its safety function?
10
Response
Yes.
This will be addressed and this valve will be t'ested at cold shutdown. A cold shutdown relief request (CSR-25) will be provided to address this.
Also, valves 3SIH*V93 and 100 addressed in question I-5 will be added to this relief request.
I 5.
How are valves 3SIL*V26, 27, 28, and 29 partial-stroke exercised quarterly during power operations?
Response
l l
Valves 3SIL*V26 and V28 will not be part.ial stroke exercised due to the possibility of hydraulic shock and resulting equipment damage.
R-22 will be revised to include additional technical justification for not full-stroke exercising valves 3SIL*V26 and l
28 during cold shutdown.
l f.
Valves 3RCS*V69 and V142 are in line with valves 3 SIC *V26 and V28 l
and will be added to R-22.
l Valves 3SIL*V27 and 29 (see discussion for valves 3SIL*V26 and 28 above) are addressed in R-1 and no changes are necessary).
l l
6.
Valve disassembly and inspection is an acceptable test method, however, the test frequency proposed in Relief Request R-5 for valves 3SIL*V982 and 983 is not adequate (see question F.3 above).
l 11
Response
R-5 will be revised to include additional technical justification l
and a clarification of the valve disassembly and inspection program.
7.
Review the safety function of valves 3SIL*V32 and 33 to determine if they should be included in the IST program and tested to the Code requirements.
a
Response
Valves 3SIL*V32 and 33 are categorized B passive and no testing is required, therefore, these valves need not be included in the IST program.
Valves 3SIL*V31 and 34 will be categorized l
l A passive and leak-rate tested per Appendix J.
l l.
8 Review the safety function of the following valves (located on P&ID 25212-26912 Sh. 2) to determine if they should be included in the IST program and tested to the code requirements:
3SIL*V41 3SIL*V44 3SIL*V82 3SIL*V885 J
3SIL*V42 3SIL*V53 3SIL*V83 3SIL*V886 1
3SIL*V43 3SIL*V64 3SIL*V884 3SIL*V887 1
1
Response
l I
i Valves 3SIL*V41-44 and V884-887 will be included in the IST l
1 program and full-stroke exercised quarterly.
Valves 3SIL*V53, 64, 82, and 83 are thermal reliefs and need not be included in the IST program.
12
I I
i G.
Residual Heat Removal System 1.
Do valves 3RHS*t/3, 7, 25, and 42 (P&ID 25212-26912 Sh. 1 l' cations o
G-7, G-10, E-7, and E-9) have a required fail-safe position? If so,.
{
they should be included in the IST program and tested to the Code q
requirements.
Response
1 Valves 3RHS*V3, 7, 25, and 42 are normally closed, fail closed, and need not be included in the IST program.
2.
Would failure of valve 3RHS*V4 or 8 in the closed position-during quarterly stroke testing render the low pressure safety injection system unavailable to perform its safety function?
]
Response
1 h.
Yes.
Quarterly full-stroke exercising would render the low pressurp injection system inoperable.
CSR-26 will be revised to include more technical justification for not full-stroke exercising these velves quarterly.
1 1
l 3.
Provide a more detailed technical justification for not full-stroke l
l exercising. valves 3RHS*V998 and 999 quarterly during power operations.
1 i
s
Response
l The licensee will provide a cold shutdown relief request providing technical justification for not full-stroke exercising-3 bene valves. quarterly duriag operations.
l 4.
Review the safety function of valves 3RHS*V24 and 41 (P&ID 25212-26912 Sh. I locations E-6-and E-11) to determine if they.should be included.
I in the IST program and tested to the Code requirements.
t 13
- \\
i J
j 1
Response
Valves 3RHS*V24 and 41 will be included in the IST program and full-stroke exercised quarterly.
l H.
Recirculation Spray System 1.
The Code identifies valve disassembly as an acceptable method of verifying valve operability, however, the testing interval identified I
in relief request R-6 for valves 3RSS*V3, 6, 9, and 12 is not acceptable by the NRC staff.
~
Response' l
Valves 3RSS*V3, 6, 9, and 12 will be disassembled and inspected on a sample basis at a refueling outage frequency (see F-3).
I.
High pressure Safety Injection System 1.
Relief request R-4 is inconsistent since it provides a justification
]
for not full-or partial-stroke exercising valve 3SIH*V5 in the basis for relief and then in the alternate testing section proposes to i
partif.-stroke exercise this valve quarterly.
Response
Valve 3SIH*V5 will not be partial-stroke exercised quarterly.
R-4 will be revised to include more technical justification.
14
I 2.
How are valves 3SIH*V13 and 17 partial-stroke exercised quarterly during power operations?
Response
Valves 3SIH*V13 and 17 will not be partial-stroke exercised quarterly during power operations due to the possibility of hydraulic shock and resulting equipment damage.
R-9 will be revised te provide more technical justification.
3.
Would failure of valve 3SIH*V20 closed during quarterly stroke testing render both trains of the high pressure safety injection system unavailable to perform their safety function?
l
Response
CSR-27 will be added to provide technical justification for not full-stroke exercising value 3SIH*V20 quarterly during power
.I i
operation.
4.
Can valves 3SIH*V22, 24, 26, and 28 be partial-stroke exercised during cold shutdowns utilizing residual heat removal recirculation flow?
Response
There is no practical method to partial stroke exercise these valves utilizing the residual heat removal syste.n.
1 l
5.
Would failure of valve 3SIH*V93 or 100 open during quarterly stroke testing render a train of the high pressure safety injection system unavailable to perform its safety function?
15 i
I i
Response
1 Yes.
This will be addressed and these valves will be full-stroke exercised at cold shutdown.
CSR-25 will address these valves and provide technical justification.
6.
Could exercising valves 3CHS*V259 and 260 during power operations result in the injection of refueling water storage tank water into the reactor coolant system?
I
Response
l l
No.
The VCT has adequate pressure to overcome the refueling water storage tank to charging pump suction head.
Currently this testing is performed per Millstone Nuclear Power Station, Unit 3 procedures on a quarterly basis.
7.
Would failure of valve 3SIH*V962 closed during quarterly stroke L
testing tender both trains of the high pressure safety injection system unavailable to perform their safety function?
Response
Failure of valve 3SIH*V962 in the closed position during quarterly testing could render both trains of high head safety injection inoperable.
The licensee will provide a cold shutdown request to full-stroke exercise this valve at cold shutdown.
8.
Provide a more detailed technical justification for not exercising valve 3CHS*V261 during cold shutdowns.
Response
R-11 will be revised to include more technical justification.
16
J.
Quench Spray System 1.
The Code identifies valve disassembly as an acceptable method of verifying valve operability, however, the testing interval identified in relief requests R-7 and a-8 for valves 3QSS*V4, 8, 976, 977, 978,.
and 979 is not acceptable by the NRC staff.
Respense:
More technical justification will be provided and valves 3QSS*V4, 8, 978, and 979 will be disassembled and inspected in accordance with F-3.
R-7 will be revised to delete valves 3QSS*V976 and 977 and a separate relief request will be provided to address-valves 3QSS*V976 and 977 disassembly and inspection and the l
l technical concerns for not performing this testing quarterly during operations and cold shutdown.
I 2.
Orovide a more detailed technical justification for not verifying closure of valves 3HCS*V7 and 14 quarterly during power operations or during cold shutdowns.
j
Response
R-16 will be revised to include more technical justification.
3.
Could failure in the open position of valve 3QSS*V30 or 31 during quarterly valve testing result in the flow of caustic chemicals inco the refueling water storage tank?
Response
No. Procedures are adequate to prevent chemical contamination of the RWST.
17
4 1
l l
4.
Review the safety related function of valve 3QSS*V984 (P&ID 25212-26902 Sh. I coordinates E-4) to determine if it shou,ld be included in the IST program.
\\
Response
I This valve is only used for testing and is, therefore, need not be included in the IST program.
I l
K.
Reactor Plant Component Cooling System 1.
Provide a more detailed technical justification for not full-stroke exercising valves 3CCP*V18 and 60 quarterly during power operations.
Response
l CSR-14 will be revised to include more technical justification.
j 2.
Do valves 3CCP*V989, 990, and 991 (P&ID 25212-26921 Sh. I coordinates I-7, I-8, and I-6) have required fail-safe positions?
Response
Valves 3CCP*V989, 990, and 991 do not have required fail safe I
positions and need not be included in the IST program.
1 L.
Main Steam and Blowdown System 1.
Provide a more detailed technical justification for not full-stroke exercising valves 3 MSS *V1, 4, 7, and 10 quarterly during power operations.
l 18 l
l
Response
CSR-15 will be revised to include more technical justification.
2.
What is the safety-related function of valves 3 MSS *V2, 5, 8, and 11?
I l
Is this an active function?
Response
These valves perform a safety-related functi m during plant startup.
CSR-16 will be revised to include more technical justification.
I 3.
Do valves 3 MSS *V12, 37, and 38 perform a safety function in the closed position?
If so, how are these valves verified to close during quarterly testing?
l
Response
]
Valves 3 MSS *12, 37, and 38 do perform a safety function and will j
be exercised to the closed position quarterly using the motor operator.
I M.
Feedwater System j
1.
Can valves 3FWS*V15, 22, 29, and 36 be partial-stroke exercised quarterly during power operations? What is the safety related function of these valves?
Response
These valves are demonstrated operable by proper operation of the steam generator level control system.
These valves will be full-stroke exercised during cold shutdowns.
CSR-17 will remain as is, i
19
2.
Provide a more detailed technical-justification for not fbil-or partial-stroke exercising valves'3FWS*V18, 25, 32, and 39' quarterly during power operations. What is the safety related function of these valves?
i
Response
CSR-19 will be revised to include more technical justification.
3.
Provide a more detailed technical justification for not full-or partial-stroke exercising valves 3FWS*V20, 27, 34, and 41 quarterly during power operations.
Response
CSR-18 will be revised to include more technical justification.
4.
Provide a more detailed technical justification.for not exercising l.k-valves 3FWS*V898, 899, 920, and 921 quarterly during power operations'
(
Response
CSR-20 will be revised to include more technical justification.
5.
Is credit taken for the reverse flow closure of the following auxiliary feedwater check valves?
If so, how are these' valves
)
individually verified to close?
3FWA*V9 3FWA*V23 3FWA*V882 3FWA*V884 7
3FWA*V14 3FWA'V28 3FWA*V883.
3FWA*V885' i
1 i
20
^
1
Response
l 1
No.
These valves are normally closed, required to go open and
]
these valves normally see feedwater pressure.
I I
6.
Which auxiliary feedwater check valves prevent diversion of flow
)
through an idle auxiliary feedwater pump when another pump is f
operating? How are these valves individually verified to close?
]
I Response-Valves 3FWA*V3, 6, ~, 12, 17, 21, 31, 35, 39, 43, and 47 will be
]
verified in the closed position during cold shutdown testing.
1 The licensee proposes the following:
1 We will include these valves in the (IST) program in the closed position.
We will write a relief request for cold shutdown.
The relief request will state:
The Code does not require these valves to be tested closed because they are passive valves in the closed position. We have included them in the program due to the importance of the safety function that they perform in the closed position.
The valves cannot be tested individually.
The valves in a train will be tested closed during full flow testing which l
can be performed during cold shutdown.
l l
OPEN ITEM.
The EG&G reviewers feel that these are active valves that perform a safety-related function in both the open and closed positions and, further, that the licensees proposal does not satisfy'the Code requirements.
21 l
7.
Review the safety function of the following valves (located on P&ID 25212-26930 Sh. 2) to determine if they should be included,in the IST program and tested to the Code requirements.
Valve Valve Valve 3FWA*V6 3FWA*V27 3FWA*46 3FWA*V8 3FWA*V34 3FWA*48 3FWA*V11 3FWA*V36 3FWA*60 3FWA*V13 3FWA*V38 3FWA*62 3FWA*V20 3FWA*V40 3FWA*854 3FWA*V22 3FWA*V42 3FWA*855 3FWA*V25 3FWA*V44 i
Response
These valves perform no active safety function and'they need not be included in the IST program.
4 N.
Service Water System
? 1.
1.
Provide a more detailed technical justification for not full-stroke exercising valves 3SWP*V25, 27, 58, and 60 quarterly during power operations and during cold shutdowns.
Response
R-14 will be revised to include more technical justification.
2.
Could failure of either valve 35WP*V33 or 65 closed during quarterly testing cause equipment damage as a result c' loss of cooling flow to 1
the component cooling water heat exchangers?
Response
CSR-28 will provide technical justification for not full-stroke exercis.ng these valves quarterly during plant operation.
l l
22 i-l
{
l 1
E- -
3.
How are valves 3SWP*V705 and 706 verified to close during quarterly testing?
Response
R-23 will provide technical justification and request to perform disassembly and inspection of valves 3SWP*V705, 706, 707, and 708 on a sampling basis during refueling outages (see F-3).
(Valves 3SWP*707 and 708 are not included in the current IST program revision).
4.
Do valves 3SWP*V14 and 47 (P&ID 25212-26933 Sh. 2 locations F-9 and F-2) have required fail-safe positions?
Resp:Qse:
l No, therefore, valves 35WP*V14 and 47 need not be included in the IST program.
.0.
O.
Instrument Air System 1.
Provide a more detailed technical justif_ication for not full-stroke exercising vsives 3IAS*V131 and 809 quarterly during power operations.
Response
I I
CSR-22 will be revised to include more technical justification.
2.
Are there any valves in the air / nitrogen supply to the MSIVs and main feedwater isolation valves whose failure could prevent these isolation valves from performing their safety related functions?
23 l
i]
Responso:
\\
No.
The nitrogen supply to these valves is a Class IV system and is isolated at power.
The only' supply to these valves at' power is steam.
P.
Fire protection System 1.
Are' valves 3FPW*663 and 668 (P&ID No. 25212-26946 Sh. 2 coordinates C-4'and B-4) Appendix J, Type C, leak rate tested?
Response
Yes.
These valves will be-included.in the IST program and categorized A.
Q.
Control Building HVAC System
.f.
1.
Is credit taken for operability of the control room chilled water l
system to meet post accident control room habitability requirements?-
If so, all applicable active system valves should be included in the IST program and be tested to the. Code requirements.
Response
l l
i Yes, credit-is taken. The IST program will be revised to include the applicable system valves and relief will be requested where necessary.
l l
l
{
24 1
.j
R.
Containment Structure Ventilation System 1.
Is valve 3CVS*V19 ever required to change position in order to mitigate the consequences of an accident, shutdown the reactor to the cold shutdown condition, or to perform any other safety related function? If so, it is an active valve and must be exercised and have its stroke time measured quarterly in accordance with the Code.
If not, it should be identified as being a passive valve in the IST program.
Response
i Valve 3CVS*V19 is passive and will be identified as passive in 1
the IST program.
S.
Containment Monitoring System 1.
Are valves 3LMS*12, 12, 13, and 14 (P&ID No. 25212-26954 coordinates L
i G-6, G-7, and G-8) Appendix J, Type C, leak rate tested?
I
Response
l No. These valves are not Appendix J, Type C tested.
T.
Emergency Diesel Generator Systems 1.
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 trans#er systems should be included in the IST program and be tasted in accordance with the Code.
Review all active valves in these diesel generator sub-systems to determine if they should be included in the IST program.
25
l 4..
o
Response
. Valves 3EGF*VI, 3, 7, and 9 will be included in~ the IST program-and full-stroke exercised quarterly.. Components'in the. service water supply to the emergency generators will be evaluated and addressed in the utility resubmittal. A relief request will be generated-to address alternate testing'of the~ emergency generator-air start valves.
The licensee will provide an evaluation of the emergency' generator components which-are considered to be demonstrated operable by Technical Specification testing.
}.
i i
I l
l 2
26 j
u j
1
II.
PljMP TESTING PROGRAM 1
i l
i 1.
How are the pump inlet pressures and flowrates measured for the service water pumps during quarterly testing?
.i
Response
J The licensee will provide a pump relief request to identify the methods utilized to measure pump inlet pressure and flowrate for these pumns during quarterly pump testing.
2.
How are the pump inlet pressures measured fer the MCC and rod control area service water booster pumps during quarterly testing?
Response
Temporary quality assurance pressure gauges are installed at the suction of these pumps for the performance of pump testing.
t 3.
How are the pump flowrates measured for the. boric acid transfer pumps during quarterly testing?
l
Response
i l
2 The flow path is through 3CHS*FT110 in the recirculation path back to each respective boric acid tank.
1 4.
How are the pump inlet pressures measured for the emergency generator fuel oil transfer pumps during quarterly testing?
Respense:
The licensee will provide a relief request giving the technical justification for not measuring the pump inlet pressure quarterly as required by the Code.
27 i
1 l
)
)
o 5.
How are the pump flowrates measured for the steam generator auxiliary feedwater pumps during quarterly testing?
Response
Controlotrons (flow measurement devices) are installed on the recirculation path to the demineralized water storage tank.
6.
Provide the basis for the proposed pump vibration velocity acceptance criteria (refer to Relief Request No. R-19).
I
Response
R-19 will be revised to include more technical justification.
Additional discussion will be provided concerning the pump vibration velocity testing program acceptance criteria (OM-6).
7.
j Does the "controlotron" provide readout repeatability within the accuracy limits of Section XI, Table IWP-4110-1?
Response
{
The licensee will provide a relief request if their flow i
instrumentation does not meet the accuracy requirements specified in the code.
(The instrumentation currently installed does not meet the accuracy r3qaired by the Code, however, instrumentation has been ordered which meets the requirements and should be received prior to the resubmittal.)
28 i
i
i 8.
Are the pump vibration. velocity measurements taken at the locations specified in Section XI,.IWP-4510? Do the vibration instruments used to make these measurements meet the accuracy and range requirements of IWP-4110 and -4120?
Response
The pump velocity measurements are taken at the locations specified in IWP: 4510. The vibration instrumentation used to.
take'ASME IWP data meets the accuracy requirements specified in Table IWP-4110-1 and is digital readout meeting the requirements; j
of IWP-4120.
l A
i t
+%
t 29 i
4