ML20236L451
| ML20236L451 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 10/30/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| LIC-87-710, TAC-54804, NUDOCS 8711100348 | |
| Download: ML20236L451 (23) | |
Text
{{#Wiki_filter:_ _ _ _ _ _ _ - _ _ _ _ .I c s Omaha Public Power District 1623 Harney Omaha Nebraska 68102 2247 402/536 4000 October 30, 1987 LIC-87-710 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 l
References:
1. Docket No. 50-285 2. Letter from NRC to OPPD (R. L. Andrews) - Request for Addi-tional Information on the Inservice Test Program (TAC No. 54804) dated June 24, 1987 Gentlemen:
SUBJECT:
NRC Questions on the Fort Calhoun IST Program Reference 2 requested additional information to allow the NRC to complete its review of the Inservice Test Program for Fort Calhoun Station. A draft response was prepared and discussed in a meeting with OPPD, the NRC and the NRC's Consul-tant, EG&G Idaho, Inc., at the Fort Calhoun Station on Cctober 14 and 15,1987. This letter is to formally transmit OPPD's responses to the referenced letter as agreed upon in the above meeting. These responses include items yet to be re-solved and commitments to change the existing IST Program Plan. OPPD plans to submit a revised IST Program Plan to the NRC within two months. l This revised program will incorporate the commitments made in these responses as well as proposals to close any open items that have been identified. If you have i additional questions, do not hesitate to contact us. l Sincerely, R. ;[,ke di 6' l R. L. A'ndrews Division Manager Nuclear Production QllSOO$ 0 [ RLA/rh Attachments P c: LeBoeuf, Lamb, Leiby & MacRae l 1333 New Hampshire Avenue, N.W. Washington, DC 20036 R. D. Martin, Regional Administrator ], 9 A. Bournia, NRC Project Manager iL P. H. Harrell, NRC Senior Resident Inspector _=_
L Response to NRC Questions as Generated in Fort Calhoun IST Review Meeting on October 14-15, 1987 1. VALVE TESTING PROGRAM A. General Ouestions and Comments Ouestion A-1 Provide a list of all valves that are Appendix J, Type C, leak rate tested and not included in the IST program and categorized A or A/C.
Response
The following valves will be included in the IST program as Category A or A/C as applicable and tested to the requirements of Section XI. None of these valves are presently in the IST program. HCV-821A & B (see B-2) A/HCV-742 (see B-1) HCV-820A & B (see B-2) B/HCV-742 (see B-1) C/HCV-742 (see B-1) D/HCV-742 (see B-1) HCV-883A & B (see B-2) HCV-804A & B'(see B-2) Valves HCV-344, HCV-335 and RC-147 are not reauired to be leak rate test-ed per Appsodix J, therefore, need not be Categorized A in the IST pro-gram. Comment A-2 The NRC differentiates, for valve testing purposes, betweEn the cold shutdown mode and the refueling mode. That is, for valves identified for testing during cold shutdown, it is expteted that the tests will be performed both during cold shutdowns and each refueling outage. How-ever, when relief is granted to perform tests on a refueling outage frequency, testing is expected only during each refueling outage. In addition, for extended refueling outages, tests being performed are expected to be maintained as closely as practical to the Code-specified frequencies. Resnonse OPPD concurred with this position. No further action is required.
m -'t V 'A. S.eeral Questions and comments-(Continued): Agntj on - A Relief, Requests that reference the FSAR, TechnicaliSpecifications,;and ~ other documents should be: expanded to provide a brief discussion'of the R 'technicti information contained.in the: applicable document.. . Response' A brief discussion >of the. reference document requirementiwill be pro-vided.in'any relief request or cold shutdown justification 5that refer-ences'these documents, i 'Ouestion A-4 l Does the spent fuel pool cooling system ' perform a safety-related' func-tion?.If'so,.the appropriate pumps and valves'should be included.in the. ..IST program.
Response
OPPD believes that the spent fue1~ pool cooling system does aqi perform a 1 o' specific active function in shutting down a reactor or mitigating.the'- consequences of an accident. A safety. grade make-up water supply is available from the transfer. canal drain pumps and the safety injection. refueling water tank; thus the spent fuel pool cooling pumps and valves -need not be included in the IST program. t Ouestion A-5 The NRC position is that.the emergency diesel generator air start system and the fuel oil transfer system perform a safety-related function and that the appropriate pumps and valves should be included in the IST pro-3 gram and tested.in accordance with Section XI. Resoonse During meetings held with the NRC staff, the above position was clari-fied to specifically require the diesel air start solenoid valves and the compressor discharge check valves.to be included in the IST program and tested to the requirements of Section XI. This position also applies to the diesel fuel oil transfer pumps and valves. These valves and pumps are not presently in the IST program. OPPD will evaluate this concern and provide a formal response by ' December 15, 1987. .______._.m-_..______m__.__._
i i A. Seneral Ouestions and Comments (Continued) Question A-6 Has a reactor vessel head vent system been installed at Fort Calhoun? If so, the appropriate valves should be included in the IST program. Resoonse Valves HCV-17G, 177 and 180 (1" solenoid valves in RV Head Vent System) will be included in the IST program as Category B valves. These valves 1 cannot be exercised quarterly during power operation since this would vent high temperature / pressure reactor coolant to the quench tank. These valves will be exercised and stroke timed. The licensee will further evaluate'the possibility of testing these valves during cold shutdowns. These valves are not presently in the IST program. Question A-7 Does the control room ventilation system perform a safety-related func-tion? If so, the appropriate support system valves should be included in the IST program. Resoonse Appendix M of the Fort Calhoun Station USAR indicates the control room would continue to function in the event of loss of A/C. Accordingly, it is OPPD's position that the CCW valves (HCV-2898A&B and 2899A&B) providing cooling to the air conditioning for the control room need not be included in the IST program. These valves are not in the present IST program (See E-5). Question A-8 Valves that are identified as passive in the IST program do not require a request for relief from exercising according to IWV-3700.
Response
i Relief requests for not exercising passive valves will be deleted. Question A-9 Provide the documentation that ensures that IWV-3300 is being met. (Re-mote position indication verification)
Response
The remote valve position indication is verified to be accurate in accordance with the Code. The IST program will be amended to include this statement.
'e i ] L 'A.. General'Ouestions and Comments (Continued) Question A-10 l Pro' vide the documentation that ensures'that IWV-3415 is being met. (Fail-safe. testing of valves.) a Resoonse'. l The fail-safe testing of valves that have a required fail-safe position will be performed in accordance with Section XI~IWV-3415. Tnis will.be i documentedlin the IST program. j u Question A-11 Provide a list of 'all-power operated valves in the IST program that are not strcke timed when they are exercised? ] Eesconse All. power operated active valves will have a maximum permissible stroke time' identified in the IST program. 1 B. Containment Heatina. Coolina and Ventilating System (11405-M-11 1 Ouestion B-1 Do valves A/HCV-742, B/HCV-742, C/HCV-742, and D/HCV-742 (E-3) perform a containment isolation function? Shoid they be included in the IST pro-gram and categorized A?
Response
These valves are 1" block valves to the containment pressure transducers. OPPD must further evaluate all safety functions of these valves..These valves do not receive any safety signal to close and remain open during all accident. scenarios. However, the B, C and D valves are closed during portions of the Appendix J leak rate testing. These valves are not. pre-sently in the IST program. OPPD'.s position related to these valves will be' addressed in our revised IST program plan. Ouestion B-2 If the following valves are leak rate tested as containment isolation valves they-should be included in the IST program and categorized A. HCV-821A (E-5) HCV-883A (E-5) HCV-8218 (E-5) HCV-8838 (E-5) HCV-820A (E-5) HCV-884A (E-5) HCVr8208 (E-5) HCV-8848 (E-5) j
Response
f i These valves (1" containment hydrogen purge system isolation valves) will be included in the IST program as Category A valves and will be stroke j tested quarterly. These valves are not presently in the IST program. l
+ C. Demineralized Water System (11405-M-5) l Ouestion C-1 ) Review the safety function of valve DW-163 (H-4) to determine if it I should be included in the IST program and categorized A/C. ~
Response
i Valve DW-163 (2" check valve on DW supply to quench tank) is not current-ly leak-rate tested as a containment isolation valve and need not be in, cluded in the IST program (i.e., IST program unchanged). D. Waste Disposal System (ll405-M-6 and 11405-M-7) Ouestion D-1 i What is the normal position of valve WD-816 (M-6, E-3)? Should this valve be included in the IST program and categorized A?
Response
WD-816 ()" manual-valve in waste disposal line from RCD 1) is not Appen-I dix J leak rate tested as a containment isolation valve. This is a normally open manual valve and need not be included in the IST program (i.e., IST program unchanged). E. Component Coolina System (ll405-M-10 and ll405eM-40) Duestion E-1 Provide a more detailed technical justification stating why valves HCV-I I 425A, HCV-4258, HCV-425C, and HCV-4250 cannot be exercised during co'd shutdown. Resoonse j These valves (3" valves in CCW lines to the SI leakage coolers) will be exercised during cold shutdowns. These valves are exercised during re-fueling outages in the present IST program, f 1 l Ouestion E-2 Provide a more detailed technical justification stating why the reactor coolant pumps cannot be stopped to allow exercising valves HCV-438A, HCV-4388, HCV-438C, and HCV-438D during cold shutdowns.
Response
The RCP seal cooling water is not normally stopped during cold shut-downs. The pump manufacturer recommends seal flow whenever RCS temper-ature is 2 130*F. These valves (6" block valves on CCW lines to RCP seal and lube oil coolers) will be exercised during cold shutdowns if l all four RCP's are stopped and the RCS temperature is <130'F. The i valves will also be tested during each refueling outage. These valves are exercised during refueling outages in the present IST program. 1
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E. Component Coolina System (11405-M-10 and 11405-M-40) (Continued) 1: 'R Ouestion E-3 ] In reference to the exercising frequency of valves HCV-467A, B, C, and D, 'q what are the' consequences of failure to meet Technical Specification 2.13? h Resoonse' - These valves are 11" isolation' valves on the CCW lines'.to'the detector well cooling coils. Failure in the closed position could. result in exceeding y temperature' limits identified in the Technical Specification for concrete 'd temperature and could also affect excore nuclear instrumentation. The cold i shutdown justification will be supplemented with this information. These 1J . valves will continue to be exercised during cold shutdowns (i.e., test fre- -j quency unchanged). 1; Qpestion E-4 N What!are tius consequences of a loss of cooling water to a containment air cooling unit? Refer to the Relief Request for HCV-400A-D, -401A-D, -{ -402A-D, and -403A-D. Should these valves be categorized A?
Response
i These valves are 8" CCW block valves to the containment air cooling units. OPPD will evaluate the exercising frequency for these valves (cold shutdown { or quarterly) and provide our results in the revised IST program plan. These valves are 201 currently leak rate tested per Appendix J since the 0 system pressure is greater than peak accident pressure and the system is in g operation post-accident. These are Category B-valves tested during CS in i the present IST program. Duestion E-5 Review the safety function of the following valves to determine if they should be included in the IST program. (11405-M-10) i 1 HCV-2898A (A-2) HCV-2814A (G-3) HCV-2809A (G-4) HCV-28988 (B.2) HCV-28148 (F-3) HCV-2809B (F-4) HCV-2899A (A-3) HCV-2815A (G-3) HCV-2810A (G-4) HCV-28998 (B-3) HCV-2815B (F-3) HCV-28108 (F-4) HCV-481 (A-4) HCV-2813A (G-3) HCV-2811A (G-5) HCV-484 (B-4) HCV-28138 (F-3) HCV-28118 (F-5) HCV-485 (B-4) HCV-2808A (G-3) HCV-2812A'(G-5) HCV-478 (D-4) HCV-28088 (F-3) HCV-28128 (F-5) .q
Response
Valves HCV-480, 481, 484, 485 (the 14" CCW block valves to the shutdown H/X's) and 478 (the 8" CCW block valve to the spent fuel pool H/X) will be included in the IST program as Category B valves and tested quarterly. These valves are not presently in the IST program. j The remainder of the listed valves need not be included in the IST program since they are either passive or non-safety related (i.e., IST program un-changed). F .j
s,' ~ E.. Comoonent Coolina System (11405-N '10 and 11405-M-401- (Continued) Question E-6 .Do valves AC-101,.104, and -107 perform a safety function in both the open I and closed positions? If so, they should be exercised to both positions.. ]
Response
These valves (12" check valves on CCW pump discharge) do perform a safety function in the closed position and will be identified as such in the IST-Lprogram and verified to close quarterly. These valves are presently veri-fied to open, the test to verify closure will be added to the IST program. L F. Instrument Air System (11405-M-264 Sheet 1~of 5) Question F-1 Provide a more detailed technical justification stating why valve PCV-1849 y cannot be exercised during power operation and cold shutdowns. Resoonse PCV-1849 failure in the closed position during testing would result in other valves supplied with air through this valve failing in their fail-safe position and could result in a plant shutdown. OPPD will determine if this valve can bo exercised during cold shutdown. If so, the IST program will be modified. This valve is presently tested at refueling outage frequency. G. Chemical ar.d Volume Control System (E 23866-210-120 and 121) .qgfftion G-1 I Provide a more detailed technical explanation stating why valves TCV-202 and HCV-204 cannot be exercised during cold shutdown.
Response
These valves (2" block valves on RCS letdown line) will be exercised during cold shutdowns in addition to the present refueling outage exercise fre-quency. ,I' Ouestion G-2 Provide a more detai. led technical justification stating why the reactor coolant pumps cannot' be stopped to allow exercising of valves HCV-206 and i L HCV-241 during. cold shutdowns.
Response
These valves are 3/4" isolation valves on the RCP seal bleed off lines. These valves will be exercised during cold shutdown when the pumps are stopped and the Reactor Coolant System is depressurized. These are Category A valves which are exercised at refueling outage in the present IST program. L - --_
.i I N, I g i - .GS sCh$mical and 'Vclume ' Control System E'23866-21'0-120 and 121) (Continued)_ l ~ 1 ,a Ouestion G-3 l 1 What alternate. system configurations have been investigated to allow full-stroke exercising of valve LCV-218-2 during cold. shutdowns? Response, Valve LCV-218-2 J(4" valve 'under the volume control tank).will be exer ~ cised during cold shutdowns. The present _ test frequencyffor this valve. 4 is during refueling outages. 1 . uestion G-4-(First Part) Q Provide a more detailed technical justification for not' full-stroke' exer : 1 cising valves ~ HCV-240 and.-249 quarterly. 'Resoonse Valves HCV-240 and 249 (2" parallel block valves'on the auxiliary pres-surizer spray line) cannot be exercised' quarterly since a thermal shock, i to the pressurizer spray nozzle would occur resulting in premature' fail-ure.of _the nozzle and a large scale RCS pressure transient-would occur that could cause plant shutdown. These valves will be exercised during-q . cold shutdowns. The valves are presently exercised during refueling H outages' l. [ Ouestion'G-4 (Second Part) L h Review.the safety function of valve CH-205 / . E-23866-210-120, Sheet
- 1) to determine if it should be included it a IST program.
Resoonse l p Valve CH-205-(2" check' valve to the auxiliary pressurizer spray line) will be included in the IST program as a Category C valve and exercised to-the open position during cold shutdown in. conjunction with the exercising of HCV-240 and HCV-249. This valve is not presently in the IST program. l Ouestion G-5 What alternate system configurations have been investigated to allow full-stroke exercising valves HCV-258, HCV-265, and HCV-268 during cold j shutdowns? 3 - ) Rftsotnig These valves (3" block valves in boric acid supply system) will be exer-cised during cold shutdowns. These valves are presently tested during i refueling outages. s l L l
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\\ I G.- . Chemical and Volume Control System (E 23866-210-120 and121) (Continued) Question'G-6 Review'.the -safety-function of valve CH-198 to determine if it should be categorized A/C. Provide a more detailed technical explanation stating why this valve cannot be full-stroke. exercised during cold shutdown. Response-CH-198 (2". check. valve on charging line immediately upstream of con-tainment penetration).is not currently leak. rate tested per-Appen' dix'J, therefore, need not be categorized A/C. This valve is. stroked open during' normal plant operation. Test frequency for this valve is-presently during refueling outages and,will-be increased.to quarterly. Question G-7 Review the safety functions of the following valves to determine'if they_ . should be included in the IST program (E-23866-210-120, Sheet 1). CH-166 (I-4) CH-156 (G-2) CH-189 . (E-7) LCV-218-3 (G-2) CH-187 (E-2) 'LCV-101-2-(B-2)_ LCV-218-1 (I'1) CH-188 (E-4) LCV-101-1 (B-2) FCV-269Y E-23866-210-121 (C-7) CH-149 E-23866-210-121 (C-7) Responiq No credit is taken for the operability of the charging pumps in any accident scenario. 1 I CH-187,188.and 189 are 2" discharge check valves on the charging pump discharge and, therefore, do not need to be included in the IST program. These valves are presently not included in the IST program. Valves LCV-101-1 & 2 perform no safety function and need not'be included in the IST program. These valves are presently not in the IST program. OPPD will determine if credit is taken for emergency boration flowpath.
. 4, s. [< r .,^ ,Q M l W "- L H. - . Safety In.iection System'(E 23866-210-130)- i Ouestion-H-1 J i Are valves-HCV-347.and HCV-348 passive valves? Why is stroke time not. -mcasured?: E -Resoonse W HCV-347'and 348l(10": and 12" block' valves' on the RCS return :line to LPSI' suction): are nqt passive' valves. and should be stroke tested. These valves. cannot be' exercised quarterly since they are interlocked closed'when RCS- . pressure is _>250 psia. ' 0 PPD will evaluate' the practicality of stroke test-- -ing these valves:during cold shutdown. These are Category A valves in.the .IST_ program.that are not presently strokeLtested. g E Ouestion H-2 i ~Are valves. LCV-383-1 and LCV-383-2 " interlocked with valves HCV-383-3 and . HCV-383-4.such that. failure of one valve. to operate would prevent operation - -i of:the' others?' Could that failure result in failure of-any; safety injec'- tion systems?. Resoonse ~ 1 .The. response to.this question is no. LCV-383-1 and 383-2.are 20" block. . valves on the SI suction piping from the SIRWT. HCV-383-3 and 383-4'are 24" blo'ck valves on the SI suction piping from the containment sump.- These valves will be exercised and stroke timed quarterly, as is presently _re-quired by the IST program. Questlon~H-3 f Provide a more detailed technical explanation stating why valves HCV-2916, HCV-2936, HCV-2956, and HCV-2976 cannot be full-stroke exercised at the Code specified. frequency.
Response
L These are 1" block valves on the SI tank fill and drain lines. If failure in the open position occurred, the Technical Specification 2.3(1)c. states the-plant must be shutdown in 12 hours and in cold shutdown within 24 hours. It is not OPPD's policy to perform testing which could result in entry into an LC0. These valves will be exercised and stroke timed during cold shutdowns. They are presently exercised at refueling outage frequen-cy.
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L H. Safety In.iection System (E 23866-210-1301(Continued) Question H-4 Review the safety function of the following valves to determine if they should be categorized A/C. How are these valves full-stroke exercised i and what is the frequency of that exercising? i SI-194 SI-200 SI-208 i SI-195 SI-201 SI-212 Sl-197 SI-203 SI-216 SI-198 SI-204 SI-220 Resoonse OPPD will further evaluate the full stroke exercise test method and ) frequency for the following valves: i SI-208 SI-207 SI-212 SI-211 SI-216 SI-215 SI-220 SI-219 The following valves will continue to be categorized A check valves: SI-194 SI-200 SI-208 SI-105 SI-201 SI-212 SI-197 SI-203 SI-216 SI-198 SI-204 SI-220 The following valves are full stroke exercised open during refueling out-ages: SI-195 SI-198 SI-201 SI-204 Exercising these valves during cold shutdowns could result in a low tem-perature over-pressurization of the RCS; thus we will not test these valves during cold shutdowns. OPPD will determine if the following valves can be full stroke exercised during cold shutdowns utilizing residual heat removal capability: SI-194 SI-197 SI-200 SI-203 s l t l 1 k I' J
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- SafetyIn.iection' System (E23866-210-1305'(Continued);
u Ouestion H-5 1 ~ ,j What ' alternate system configurations'have been investigated ~to allow full-stroke' exercising valves HCV-344 and HCV-345 during power ~ operation and cold shutdown?, 'Are these two valves leak rate tested in accordance H
- with Appendix J7 Response-q j
HCV-344 Land 345 (8" block valves on the containment spray lines just J t outsidelof containment) will be exercised during~ cold shutdowns when the' inside containment manual isolation valves;are closed.to prevent the: q -possibility'of spraying containment; These valves are presently exer-Lcised during. refueling outages. l c .These valves are not required to be leak-rate tested per Appendix J, therefore,. these1 valves will not be categorized A.. These. valves ~are presently categorized _B. Ouestion H-6 4 Provide a more det' ailed technical justification explaining why ' valves SI-100 'and -113 cannot. be full-stroke exercised quarterly.
Response
i ' These valves are 6" and 8" check valves on the HPSI pump. suction lines. a- .i The only'. full flowpath for these check valves is into'.the'RCS and the HPSI. pumps cannot overcome normal' operating RCS pressure.. Testing these , valves.during cold shutdowns could result in a low temperature overpres- - surization of the RCS.- These check valves will be full stroke exercised - during each. refueling outage during.the safeguards testing. This.isithe frequency' presently.specified in the IST program. i Question H-7 Provide a more detailed technical justification explaining why valves SI-139 and -140 cannot be full-stroke exercised during cold shutdowns. Resoonse SI-139 'and 140 (20" check valves on the SI suction lines f' rom the SIRWT) can.only be full flow exercised open during refueling when the full flow flowpath is available for the quantity of: water required to full stroke .i ' these check valves. This is 'the frequency presently specified in the . IST program.
V (Continued) H. Safety In.iection System (E 23866-210-130) Question H-8 j i Provide a more detailed technical explanation why valves SI-121 and -129 cannot be full-stroke exercised during cooling operations. Resoonse SI-121 and 129 (8" check valves on LPSI pump discharge) may be full stroke exercised during cold shutdowns. These valves are presently tested during refueling outages. OPPD will determine if full accident flow through these valves can be achieved during cold shutdowns. If appropriate, these valves will be stroke exercised during cold shutdown. Question H-9 I Explain why the containment spray test line (6 in. SI-601R) cannot be { utilized to exercise the containment spray pump discharge check valves -l during cold shutdowns? Resoonse 6" SI 601R cannot be utilized during cold shutdown since both shutdown l cooling heat exchangers are required to be operable /available. Chack valves SI-135,143 and 149 on the containment spray pumps discharge will be full stroke exercised during each refueling outage (i.e., IST program unchanged). I Ouestion H-10 j In reference to valves SI-159 and -160, the NRC staff position is that i disassembly of. check valves is an acceptable alternate method to utilize to full-stroke exercise check valves and that the disassembly be per- ) formed each refueling outage on a sampling basis instead of at the fre-quency proposed.
Response
SI-159 and 160 are 24" check valves on the SI suction lines from the con- ) tainment sump. The NRC staff position on sample disassembly (i.e., one j valve disassembled and inspected each refueling outage) was explained to the licensee. The licensee has explained the problems with disassembly j (i.e., rad waste, ALARA, etc.) for these valves. OPPD will further evaluate an increased test frequency for these valves. Present IST program call for disassembly and inspection of alternate valves every five years. I 1
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<-(" y "2 r. .:1 c LSafety In.ie' tion ~ Systsmi(E ?aa51210-130E (Continued):
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5 N H.y 4 +1 y w g t., Ouestion'H-liL .U
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~ M7 Revikw the-' safety function;of:velves SI-175'and SI~176:to determine:ifj' N'*
- they should be"categorizedLA/C.' j How.are these' valves full-stroke exer-
,l m,. cised.during' refueling. outages?; R a .t1 m ResponseL 1 "y" .0 n N SI-175 andL176 arell2" check valves on the containment spray;11nes'~1n- '1, t . side thel containment. These valves:are not required to be. leak rate- _ ~ ,m.. tested per4 Appendix J,<ando.therefore,'dolnot need to be categorized A. y1 .l n L Ouestion H 12-y 3L 5 j .c ~How are' valves lSI-207, SI-211,3 SI-215,;and 'SI-219 full-stroke exercised: during; refueling outages?l n H .o. Response; 3 Check"valvesSI-207,211,.215and219onThe12"safetyinjectiontank! d drains are: partial-stroke tested'durthggrefueling outages.: OPPD will. 5 Levaluate a' fullistroke exercise : test. e 4 ;e b b \\ t Y I i - n) ,r} -. .s l i 4 ,'l .;d I i
( 1 H. Safety Iniection System (E 23866-210-130) (Continued) _Qgestion H-13 j Review the' safety. function of the following valves to determine if they perform a safety-related function. If so, they should be included in the IST program. (Sheet 1) i l HCV-304 (E-7) HCV-2937 (H-5) FCV-326 (D-5) HCV-305 (E-6)- HCV-2938 (F-5) HCV-335 (E-4) 1 HCV-306 (D-7) HCV-2947 (H-4) HCV-344 (E-4) 4 HCV-307 (D-6) HCV-2948 (F-4) HCV-2987 (B-6) HCV-2907 (G-7) HCV-2957 (H-3) SI-323 (C-6) HCV-2908 (F-7) HCV-2958 (F-3) HCV-308 (D-6) { HCV-2917 (G-7) HCV-2967 (H-3) HCV-2988 (D-6) 1 HCV-2918 (F-7) HCV-2968 (F-3) i HCV-2927 (G-6) HCV-2977 (H-2) HCV-2928 (F-6) HCV-2978 (F-2) ' Response Valves HCV-308 and 2988 (2" parallel valves on lines that tie the charg-ing pump discharge to the HPSI header) perform a long term core cooling j function and will be included in the IST program as Category B valves 1 'and tested during cold shutdowns. These valves are not presently in-cluded in the IST program. HCV-335 (12" block valve between LPSI pump discharge and shutdown heat exchangers) performs no safety function in the open position. This valve is normally closed and considered passive, therefore, need not be included in the IST program. This does not change the IST program. SI-323 (4" check valve in HPSI discharge) will be included in the IST program as a Category C check valve. This valve can only be verified to full stroke open during safeguards testing during each refueling outage since this is the only time a full flowpath is available for this sys-tem. This valve -is not presently included in the IST program. OPPD will determine if SI-323 performs a safety function in the closed position and, if so, how closure capability is verified. All other valves in this list are locked open in their fail-safe posi-tion and need not be included in the IST program (i.e., IST program unchanged). l i
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i s p. J' ,6 H. Safety 'ihiection' System (E 23866-210-130) (Continued)
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} Ouestion HyL4 / 'r Review the safety function of the 'following check valves to d6terd[n[if they must change position to provide pump m'qirum flow protection. ' If ~ <j ~ so, then they should be included in the IST prognm. (Sheet 1) i SI-104 (F-7) SI-304l (F-4) /.- SI-301 (F-2) SI-110 (F-6) )7> SI-303 (F-4) SI-300~(F-1) SI-117 (F-5) u SI-302 (F 3) SI-153 (F-1) i
Response
These valves (1" og 2" check valves in the LPSI, HPSI, CS pump discharge j recirculation lines) will be included in the IST program as Category C { valves and exercised to the open positioniquarterly. These valves per- -1 form no safety function in the closed position. These valves are not j presently in the.IST program. 1 } { Ouestion H-15 -) ) How are valves SI-208, -212, -216,.and -220 full stroke exercised? l Resoonse Check valves SI-203, 212, 216 and 220 on the 12" safety injection lines immediately upstream of the RCS injection point. These valves are par-tially stroke tested during refueling outages. OPPD will evaluate the practicality of full stroke testing. Question H-16 Do the following valves perform a pressure boundary isolation function and should they be categorized A/C7 i SI-207 SI-219 SI-216 SI-195 SI-211 SI-208 SI-220 SI-196 j SI-215 SI-212 SI-194 SI-197 SI-198 SI-200 SI-202 SI-204 SI-199 SI-201 SI-203 SI-205
Response
The following twelve valves are identified in Technical Spe<.ifications as Pressure Isolation Valve,s (PIV's) and are leak rate tested: SI-198 f SI-201 SI-203 SI-208 SI-216 SI-!95 SI-212 SI-220 SI-197 SI-200 SI-194 SI-204 These valves are categorized A in the IST program and tested according-ly. The remaining valves do not perform / function as PIV's. Thus, no change will be made to the IST program. l
F.% 3997 ~,.g = n. 9g.[ nin[ t m i ' H.- Safet'vilkiection Sys' tem (E 23866-210-130)~(Continued) g wy a h j Question'H-17 Review the containmentiisolation function' of the following valves to de-k* ? t' ermine if they should-be included in the ~ IST program, categorized A/C, and-leak ~ tested;in accordance with Appendix J... (Sheet 2)- SI-222'(H-1)- ~SI-188 (H-5) SI-190-(H;7) SI-187 (H-5)' .SI-189 (H-6). . Response. i N 'These thermal relief valves are inside containment and discharge into S[. 'per Appendix J, therefore, need not be categorized A in the IST program. the containment. These -valves are not required to be leak rate tested i hhp, LI.. Raw Water System (11405-M-100) 9y -Ouestion I W Review the safety function of the following valves to determine if they l should be included in'the-IST program: j i -HCV-400E (F-1) HCV-403E (F-2) HCV-482A (F-3) ,s k HCV-400F (G-1) HCV-403F. (G-2)_ HCV-4828. (G-3) F HCV-401E'L(F-1) HCV-2898C (F-2) HCV-483A- (F-3) .HCV-401F :(G-1), HCV-2898D (G-2). HCV-4838- (G-4) HCV-402E~ (F-1) HCV-2899C-(F-2)- HCV-2813C (D-5) 9~ i HCV-402F; (G-1) HCV-2899D.(G-2) 'HCV-2813D-(E-5) HCV-2808C (E-5) HCV-2812C (E-5) HCV-2809C (F-5) HCV-2808D (E-5)' .HCV-28120 (E-5) HCV-2809D'(F-5) b .HCV-2810C-(E-5) HCV-2811C (F-5) HCV-2815C (F-5) W HCV-2810D (E-5). HCV-28110 (F-5) HCV-2815D (F-5) I. HCV-2814C (F-5) HCV-2814D (G-5) CW-188 (C-4) { u f CW-189 (C-4) ~ Resoonse I ' 0 PPD will determine if the raw water to CCW interface valves perform an active safety function within the' scope of our safety analyses. 7 4 Ouestion I-2 ~. Do valves RW-115, -117, -121, and -125 perform a safety function in both the open ar.d shut positions? If so, they should be exercised to both 3 positions.
Response
These raw water pump discharge checks do perform a safety function in .:( the closed positio'n and must be verified to close quarterly. These i valves are presently verified to open quarterly in the IST program. Therefore, the IST program will be revised accordingly. r ] O a
m IJ. - Main Steam' System (11405-M-252) .0uestion J Reviewithe safety fun'ctions.of the unidentified check valves installed.in the auxiliary feedwater pump turbine' steam' supply lines.to determine if they should be included in the. IST program and individually verified to full-stroke exercise. / Resoonse. 1 + There are no' unidentified check valves on the current P&ID's. This ques-l tion refers to MS-351 and MS-352,. 2". check valves on the steam line to - the turbine driven auxiliary feedwater pump, FW-10. AFW. turbine steam supply check valves MS-351 and 352 perform a safety function in the open i position _ to supply. steam to the AFW turbine and are partial stroked open 1 at least quarterly. OPPD will determine a method and frequency of full stroke exercising these check valves-and will determine if these check valves perform a safety function in the closed position. These valves are not presently 1 in the IST program. 1 Ouestion J-2 1 1 Review the safety function of the following valves to determine if they 1 should be: included in the IST program. HCV-1041B (B-1) HCV-1042B (B-2) l HCV-1040 (B-1) i
Response
j 1 HCV-1041B'and 10428 (28" mai% team reverse flow check valves) are assumed j to fail open in the' accident analysis for steam line break and are iden-1 tified as non-code class valves. These valves need not be included in the IST program. This represents no change to the IST program. i HCV-1040 (4" atmospheric steam dump) is non-code class and non-safety j related and need not be included in the IST program. This represents no change to the IST program. 4 Ouestion J-3 Provide a detailed technical justification for not full-stroke exercising valves HCV-1041A and -1042A during cold shutdowns?
Response
HCV-1041A and 1042A, MSIV's will be full stroke exercised and stroke timed during cold shutdowns. The test frequency in the present IST program is once per refueling outage.
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- K.'
Steam Generator Feedwater System (11405-M-254 and 253) Ouestion K-1 l Do valves FW-161'and FW-162 perform a safety function in the closed posi-H tion? If so, they.should be exercised to that position. 1 P,esconse '.FW-161 and 162 are 16" check valves in the main FW line inside contain-1 ment., It is OPPD's position that,these. valves perform no safety function .( 'in the closed position.: The. upstream motor operated valves perform the. feedwater header isolation. function. It also appears that.these valves ' perform no safety function in the forward flow direction. The licensee .is investigating removing.these valves from the IST program. 1 Ouestion K-2 How are the. valves FW-173 and FW-174 full-stroke exercised quarterly? Resoonse FW-173 (4" check valve on discharge of motor driven AFW pump) can only be full stroke exercised during cold shutdowns as stated in the new relief request. ' FW-174 (4" check valve on discharge of turbine driven AFW pump) is disassembled every refueling outage in lieu of ~ full stroke testing. These valves will. be verified closed quarterly. A quarterly closure test is an addition to the.present IST program. 1 Ouestion K-3 1 1 Review the safety function of valves FCV-1368 (C-5), FCV-1369 (D-5), and i FW-672 (D-5), P&ID M-253, to determine if they should be included in the IST program. Resoonse j 1 FCV-1368 and 1369 (1" and 2" globe valves on AFW pump recirculation lines) are normally open and failure in the open position would not re-sult in less than accident flow rate to the steam generators. These valves need not be included in the IST program. (No change to the pre-sent IST program). y FW-672 (2" check valve on the AFW pump recirculation line) will be in-cluded in the IST program and verified to open quarterly during AFW pump i testing. This valve is not presently in the IST program. 4 I .l
J t a ) ., t Sa l.' /Li ' Reactor Cool' ant' System (E-23866-210d10) ' d l0uestionLl-i l
- R
TheLNRC. position fis' that' the. PORVs should be included ' n th'e IST program - i .and'should be exercised during cold' shutdown'or prior to' establishing--
- conditions where the;PORVs are utilized for low-temperature-overpressure.
+ l protection.~ Additionally, normally open PORV. block valves should be' , ;: included in:the IST ^ program and, exercised in accordance with Section XI-to provide 1 isolation protection-in.the event that the PORVs should faili r topen. Resconse HCV-150 and 151 (21" block valves under the PORV's) will be included in.- the1IST program as. Category B valves and exercised on a cold shutdown ~ frequency.. These valves-_are not : presently in 'the IST program. PORV'sia're never exercised, however, the ~ pilot valves may be' exercised ~
- during surveillance test-ST-PORV-1 prior to cooldown below 300'F.
The PORV's (PCV-102-1-and 2) perform no safety function at' operating con--- -ditions. During.heatup and cooldown the PORV's provide..the only sourcel of low temperature overpressure protection. A surveillance-test isfin place that functionally tests lthe:PORV low temperature setpoint function,. butistops short'of. opening the PORV's.. These valves are pilot. operated . valves.that require pressure across the valve'in order to open'.. Experi- ~ ence indicates that stroke testing the PORV at temperature and pressure-can be potentially damaging to the valve. -It is OPPD's position that it =j .is not practical to stroke test the PORV's. -l u i 1 j p = -
.i %, i II. PUMP TESTING' PROGRAM t. it l0uestion A Provide a more detailed' technical explanation' stating why pump test data cannot - be. analyzed.within.96 hours ' of completion ' of pump.? testing. .ij
Response
Pump test data'will be' evaluated within 96 hours after completing pump testing.- 1 j 'I ] 1 i --_=_-
_7_-_____ 1 t u..
- y -
s. b E j 'Ouestion Bs ~,The' NRC. position is; that both' flow and differential _ pressure'be measured during : 'the performance of pump testing,.;i.e., all quantities required by Table;IWP- ' 3100-1 should be recorded and that lack of installed instrumentation is notLa-suitable long term justification for not performing.the required Section.XI' test- .ing.
Response
A discussion:of measurement of pump flow rate and differential pressure was ' held j and it-is OPPD's understanding Lthat we need not' install any more instrumentation: to satisfy ~the.Section XI' requirements. ] l -i l 7 i f 1 i i i -~__a---__-_-_:_.-. i
a s, m w s
- 3.,
} [ '00e'stion C ~ Provide the documentation'n'that: demonstrates that.the-low pres'sure safety injec- . tion and containment spray pumps are tested,in accordance with Section.XI?
Response
. f-- The test parameters atithe bottom of page 19' of the.IST program apply to all- . pumps listed 'on that page. and not only the HPSI pumps. 'i 1 .I -1 J f li. l l l 1 d 1 .j l l 1 1 s ) { i I 1 J i j
gj 1: n, ~ ADDITIONAL COMMENTS'- gn, y en ai - 1., (Pump rot'ative speed'will be measured lfor the' turbine. driven auxiliary - L . feedwater pump during quarterly testing.. This.is an additional test requir~ement that ' arises out' of the. variable speed nature of a: turbine - drive. This does not-apply to other IST pumps'because they.'are: induction motor driven. l l 1 1 1 ~l t i l l i i ['. ___m -____m m}}