ML20236P938
| ML20236P938 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/15/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-MA0264, TAC-MA264, W3F1-98-0131, W3F1-98-131, NUDOCS 9807170214 | |
| Download: ML20236P938 (13) | |
Text
,
y Ente gy Operation 3,Inc.
Killona, LA 70066 Tel 504 739 6242
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C. Ewing,111 i u ear Safety & Regulatory Affairs W3F1-98-0131 A4.05 PR July 15,1998 U.S. Nuclear
- igulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Response to item 3 of the Request for Additional information Regarding the Waterford 3 Second 10-Year Interval inservice Testing Program and Associated Requests for Relief (TAC Number MA0264)
Gentlemen:
On June 15,1998 via Letter W3F1-98-0068, Entergy Operations, Inc. provided additional information regarding the Second 10-year Interval inservice Testing (IST)
Program for Waterford 3 Steam Electric Station. The June 15 letter responded to an
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NRC Request for Additional Information (RAl) dated April 15,1998. The RAI response provided the requested information with the exception of parts of item 3.
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Attached is Entergy's resnonse to the remaining item 3 questions which includes the nocessary revisions to the associated relief requests.
The attachments are as follows:
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Item 3 RAI Response I
Waterford 3 SES IST Program Revised Relief Request VRR-01
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Waterford 3 SES IST Program Revised l
-e 3$vJ Relief Request VRR-02
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.'9007170214 990715 PDR ADOCK 05000382 P
POR u__________
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Response to item 3 of the Request for Additional Information Regarding the Waterford 3 Second 10-Year Interval inservice Testing Program and Associated Requests for Relief (TAC Number MA0264)
W3F1-98-0131 Page 2 July 15,1998 Waterford 3 SES IST Program Revised Relief Request VRR-03 Waterford 3 SES IST Program Revised Relief Request VRR-05 If you have any questions concerning this submittal, please contact me at (504) 739-6242 or Walter Lowe at (504) 739-6212.
Very truly yours, P
E.C. Ewing Director Nuclear Safety & Regulatory Affairs ECE/ PRS /rtk Attachments (w/ Attachments) cc:
E.W. Merschoff, NRC Region IV C.P. Patel, NRC-NRR NRC Resident inspector (w/o Attachments) cc:
J. Smith, N.S. Reynolds l
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l ATTACHMENT 1 TO W3F1-98-0131 RESPONSE TO ITEM 3 OF THE REQUEST FOR ADDITIONAL INFORMATION REGARDING THE WATERFORD 3 SECOND 10-YEAR INTERVAL INSERVICE TESTING PROGRAM l
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Response to item 3 of the Request for Additional Information Waterford 3 Second 10-Year Interval inservico Testing Program
- 1. Scope / Status of Review The staff is reviewing the second 10-year interval inservice testing program and associated requests for relief for Waterford Steam Electric Station, Unit 3 (Waterford 3), submitted by letter dated December 1,1997.
- 2. AdditionalInformation Required Based on the above review, the staff requested additionalinformation.
Responses to items 1,2,4, 5 and part of item 3 were submitted by letter dated June 15,1998. The remaining item 3 questions and responses are as follows:
Item 3 RELIEF REQUESTS VRR-01, VRR-02, VRR-03, AND VRR-05:
It is nci 9vident based on the information presentedin VRR-01, VRR-02, VRR-03, and VI R-05 that stroke timing is impractical or would result in hardship without a compensating increase in the level of quality and safety. If the stroke timing requirements cannot be met, please provide a basis in sufficient detail tojustify a proposed allemative, following the applicable guidelines in NUREG-1482, section 4.2.3,
- Measurement of Valve Stroke Time," Section 4.2.8,
- Solenoid-Operated Valve," and Appendix A, pp A-24 to A-34. The basis should also address the following anomalies:
3.1 The statement in the relief requests that "there is no criticallimit on the stroke time" appears to be inconsistent with the NRC guidelines in GL 89-04, position 5,
" Limiting Values of Full-Stroke Times for Power-Operated Valver," and NUREG-1482, Appendix A, " Position, Questions, Responses, and Current Considerations Regarding GL 89-04,"pp A-24 to A-34.
3.2 Some valves in question have a safety function to close; therefore, the basis should be expanded, as necessary, to include discussions on stroke timing in the closed direction.
3.4 The basis does not address non-intrusive techniques or assigning a reasonable, objective acceptance criterion to an observable parameter, such as a flow rate or AP, l
to measure stroke times and assess degradation.
1 Response to item 3 Item 3.1 The statement in the relief requests that "there is no critical limit on the stroke time"
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has been changed in the affected relief requests to more accurately state that "there are no safety analysis or design basis stroke time limits for these valves." The odginal statement was intended to imply that the valves had no safety analysis or design basis stroke time limits that would need to be considered in addition to any stroke time limits that may be imposed by Inservice Testing. See Attachments 2,3, 4, and 5 for the corrections to this statement in the affected relief requests.
Item 3.2 The Relief Requests VRR-01, VRR-02, VRR-03, and VRR-05 have been revised to include discussions on the closed functions of the affected valves. VRR-02 regarding the N2 Accumulator Outlet isolation Valves was also revised to include a discussion of the closure testing due to these valves recently being assigned a closed safety function. See Attachments 2,3,4, and 5 for the revised relief
- requests, item 3.4
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Waterford 3 does not currently use non-intrusive (acoustics, magnetics, etc.)
techniques for determining so:enoid operated valve stroke times. Waterford 3 readests that relief from the stroke time requirements for the valves F"ed in relief requests VRR-01, VRR-02, VRR-03, and VRR-05 be granted for one year (until July 15,1999) to allow adequate time to evaluate and validate possible testing methodologies for use in obtaining stroke times for solenoid operated valves. This time period is necessary to ensure that any potential test methods are properly evaluated to confirm that test accuracy and repeatability are sufficient for degradation monitoring. At the end of this year, the testing of solenoid valves will be in full compliance with OM-10 or additional relief will be requested. If additional relief is requested, the results of Waterford's evaluation will be discussed in any additional relief requests. Waterford will continue to verify that the solenoid valves change position in accordance with current procedures while methodologies for stroke tim lng are being evaluated. The continuation of the current testing will provide reasonable assurance that the solenoid valves are capable of performing their safety functions.
It is not feasible to obtain consistent and repeatable stroke times for the HRA valves in VRR-01 by timing some other observable parameter such as flow. The indication currently used to verify that HRA-201 A(B) and HRA-202A(B) are closed is the Hydrogen Analyzer low flow alarm. It can take up to five minutes from the time the valves are closed until the alarm is actuated. The valves themselves stroke in a fraction of a second. The results obtained by timing flow would be very inconsistent
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and would result in many false failures without effectively monitoring for degradation.
. See' revised Relief Request VRR-01, Attachment 2.
.The N2 Accumulator Outlet isolation Valves in VRR-02 cannot be effectively timed using an observable parameter due to the inability to accurately determine when to begin timing the valve stroke. These valves are controlled by system pressure and do not have any control switches that would allow positive identification of the initiation of valve actuation. Temporarily lifting leads and/orjumpering around pressure switches in order to positively detect or induce valve actuation signals for testing would alter the plant configuration such that proper system accident response
.would not be possible during the period of time required for preparation, performance, and completion of the test activities. See revised Relief Request VRR-02, Attachment 3.
No means exists to measure the stroke times of the Diesel Generator Standpipe Level Control Valves in VRR-03. These solenoid valves cannot be effectively timed using an observable parameter due to the inability to accurately determine when to begin timing the valve stroke. These valves are controllad by standpipe level and do not have any control switches that would allow positive identification of the initiation oivalve actuation. Attempting to measure the time interval between the level at which the valve should open and then the actual observance of rising level would give widely varying test data and result in many false failures without effectively monitoring for degradation. Temporarily lifting leads and/or jumporing around level switches in order to positively detect or induce valve actuation signals for testing would alter the plant configuration such that proper system accident response would not be possible during the period of time required for preparation, performance, and completion of the test activities. See revised Relief Request VRR-03, Attachment 4.
The Chilled Water (CHW) Expansion Tank Level Control Valves of VRR-05 cannot be effectively timed using an observable parameter due to the inability to accurate!y determine when to begin timing the valve stroke. These valves are controlled by Expansion Tank level and do not have any control switches that would allow positive identification of the initiation of valve actuation. Attempting to measure the time interval between the level at which the valve should open and then the actual observance of rising level would give widely varying test data and result in many false failures without effectively monitoring for degradation. Temporarily lifting leads and/orjumpering around level switches in order to positively detect or induce valve actuation signals for testing would alter the plant configuration such that proper system accident response would not be possible during the period of time required for preparation, performance, and completion of the test activities. See revised Relief Request VRR-05,' Attachment 5.
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I ATTACHMENT 2 TO l
i W3F1-98-0131 RELIEF REQUEST VRR-01 l
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ENTER 3Y OPERATIONS, INC.
S:cond IST Intarval WATERFORO 3 PUMP AND VALVE INSERVICE TEST PLAN e sion 0 7.5 Requests for Relief from OMa-1988 Part 10 Testing Requirements, Page 1 of 8 VRR-01
- Hydrogen Analyzer Containment and Annulus Sample" Component (s) Affected HRA-0101 A HRA-0201B HRA-0101B HRA-0202A HRA-0201A HRA-0202B Test Requirement OMa-1988 Part 10 Article 4.2.1.4(b) requires that the stroke time of all ;ower-operated valves shall be measured to at least the nearest second.
Basis of Relief No physical means exists to measure the stroke times of these solenoid operated valves. These valves do not have position indicators. In addition, the stems are not visible from the exterior of the valves. Also, there are no safety analysis or design basis stroke time limits for these valves. Valve design does not facilitate partial stroke testing.
It is not feasible to obtain consistent and repeatable stroke times for the HRA valves in VRR-01 by timing some other observable parameter such as flow. For example, the indication currently used to verify that HRA-201 A(B) and HRA-202A(Ei) are closed is the Hydrogen Analyzer low flow alarm. It can take up to five minutes from the time the valve s are closed until the alarm is actuated. The valves themselves stroke in a fraction of a second. The results obtained by timing flow would be very inconsistent and would result in many false failures without effectively monitoring for degradation.
Alternate Testing Verification of normal sample flow through the appropriate Hydrogen Analyzer demonstrates that the valves identified in the Components Affected section above move from a close to an open position. Verification of the Hydrogen Analyzer low flow alarm demonstrates that HRA-201 A(B) and HRA-202 A(B) are closed. Valve stroke time will not be measured.
Stat (s, Rehef granted (Number 3.1.38) for first ten-year interval per NRC SER dated February 7,1989.
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4 ATTACHMENT 3 TO W3F1-98-0131 RELIEF REQUEST VRR-02 L
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ENTERGY OPERATIONS, INC.
Second IST Int:rval i
l WATERFORD 3 ENTERGY PL/MP AND VALVE INSERVICE TEST PLAN Rcvision 0 7.5 Requests for Relief from OMa-1988 Part 10 Testing Requirements, Page 2 of 8 VRR-02 *N2 Accumulator Outlet ' Isolation Valve" Component (s) Affected NG-609 NG-809 NG-610 NG-810 l
NG-709 NG-909 NG 710 NG-910 Test Requirement OMa-1988 Part 10 Article 4.2.1.4(b) requires that the stroke time of all power-operated valves shall be measured to at least the nearest second.
Basis of Relief No physical means exists to measure the stroke times of these solenoid operated valves. These valves do not have control switches and associated position indicating lights. In addition, the stems are not visible from the exterior of the valves. Also, there are no safety analysis or design basis stroke time limits for these valves. Valve design does not facilitate partial stroke testing.
l The N2 Accumulator Outlet Isolation Valves in VRR-02 cannot be effective ly timed using an observable parameter due to the inability to accurately determine when to begin timing the valve stroke. These valves are controlled by system pressure and do not have any control switches that would allow positive identification of the initiation of valve actuation. Temporarily lifting leads and/or jumpering around pressure switches in order to positively detect or induce valve actuation signals for testing would alter the plant configuration such that proper system accident response would rt be possible during the period of time required for preparation, performance, and completion of the test activities.
Alternate Testing Verification of flow from the appropriate Nitrogen Accumulator demonstrates that the valve moves from a closed to an open position. Verification of normalInstrument Air pressure in the appropriate IA/N2 header and observation that the header relief valve is not lifting demonstrates that the appropriate accumulator isolation valve and regulator pair are satisfying their conibined closed function. Valve stroke time will not be measured.
Status Relief granted (Number 3.1.52) for first ten-year interval por NRC SER dated February 7,1989.
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6 ATTACHMENT 4 TO W3F1-98-0131 RELIEF REQUEST VRR-03 1
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ENTERGY OPERATIONS, INC.
Second IST Int:rval WATERFORD 3
~ ENTERGY PUMP AND VALVE INSERVICE TEST PLAN e sion 0 7.5 Requests for Relief from OMa-1988 Part 10 Testing Requirements, Page 3 of 8 VRR-03 " Diesel Generator Standpipe Level Control "
l Component (s) Affected CMU-0524A CMU-0524B Test Requirement OMa-1988 Part 10 /,rticle 4.2.1.4(b) requires that the stroke time of all power-operated valves shall be measured to at !nst the nearest second.
Basis of Relief No physical means exists to measure the stroke times of these solenoid operated valves. These valves do not have control switches or position indicators. In addition, the stems are not visible from the exterior of the valves. Also, there are no safety analysis or design basis stroke time limits for these valves. Valve design does not facilitate partial stroke testing.
No means exists to measure the stroke times of the Diesel Generator Standpipe Level Control Valves in VRR-03. These solenoid valves cannot be effectively timed using an observable parameter due in tha inability to accurately determine when to begin timing the valve stroke. These valves are controlled by standpipe level and do not have any control switches that would allow positive identification of the initiation of valve actuation. Attempting to measure the time interval between the level at which the valve should open and then the actual observance of rising level would give widely varying test data and result in many false failures without effectively monitoring for degradation. Temporarily lifting leads and/orjumpering around level switches in order to positively detect or induce valve actuation signals for testing would alter the plant configuration such that proper system accident response would not be possible during the period of time l
required for preparation, performance, and completion of the test activities.
Alternate Testing Demonstration of valve exercising will be performed by monitoring changes in the diesel generator standpipe level quarterly. Specifically, level rising indicates the valve is open and the cessation of level rise indicates that the valve is closed. Valve stroke time will not be measured.
Status Relief granted (Number 3.1.68) for first ten-year interval per NRC SER dated February 8,1994.
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W3F1-98-0131 RELIEF REQUEST VRR-05 l
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l ENTERGY OPERATIONS, INC.
S:cond IST Int:rval WATERFORD 3 PUMP AND VALVE INSERVICE TEST PLAN sion 0 7.5 Requests for Relief from OMa-1988 Part 10 Testing Requirements, Page 5 of 8 1
VRR-05 *CHW Expansion Tank Level Control "
Component (s) Affected CMU-0532A CMU-0532B CMU-0532AB Test Requirement OMa-1988 Part 10 Article 4.2.1.4(b) requires that the stroke time of all power-operated valves shall be measured to at least the nearest second.
Basis of Relief The only indication of valve position for these valves is by computer point. These valves do not have control switches. la addition, the stems are not visible from the exterior of the valves. Also, there are no safety analysis or design basis stroke time limits for these valves. Valve design does not facilitate partial stroke testing.
The Chilled Water (CHW) Expansion Tank Level Control Valvec of VRR-05 cannot be effectively timed using an observable parameter due to the inability to accurately determine when to begin timing the valve stroke.
These valves are controlled by Expansion Tank level and do not have any control switches that would allow positive identification of the initiation of valve actuation. Attempting to measure the time interval behueen the level at which the valve shou'd open and then the actual observance of rising level would give widely varying test data and result in many false fai!ures without effectively monitoring for degradation. Temporarily lifting I
leads and/or jumpering around level switches in order to positwely detect or induce valve actuation signals for testing would alter the plant configuration such that proper system accident response would not be possible during the period of time required for preparation, performance, and completion of the test activities.
Alternate Testing Demonstration of valve exercising w;il be performed by monitoring changes in the CHW Expansion Tank level and valve p >sition indication by ccmputer point quetterly. Valve stroke time will not be measured.
Status Request for relief is submitted as part of the submittal of the IST Plan for the second ten-year interval.
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