ML20236Q425

Forwards Summary of NRC 871021-22 Meetings W/Util at Plant Site Re Questions Raised During NRC Preliminary Review of Proposed Inservice Testing Program.Encl Identifies NRC Questions & Comments & Util Responses

ML20236Q425
Person / Time
Site:	Hatch
Issue date:	11/12/1987
From:	Crocker L Office of Nuclear Reactor Regulation
To:	James O'Reilly GEORGIA POWER CO.
References
TAC-59202, TAC-59203, NUDOCS 8711200018
Download: ML20236Q425 (44)

Text

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^,, UNITED STATES 8" o NUCLEAR REGULATORY COMMISSION g ;p WASHINGTON, D. C. 20555

%.....# NOV 121987 Docket Nos.: 50-321 and 50-366 Mr. J. P. O'Reilly Senior Vice President - Nuclear Operations Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302

Subject:

Inservice Testing Program - Hatch, Units 1 and 2 (TACs 59202/59203)

On October 21-22, 1987, a meeting was held at the Hatch site to discuss questions raised during the NRC's preliminary review of the proposed Inservice Testing (IST) program for Hatch Units 1 and 2. The results of that meeting are provided in the enclosed sumary, which identifies the NRC questions and comments and the GPC responses. As noted in the enclosure, several issues remained open at the end of the meeting.

One item discussed at length during the meeting was inclusion of the emergency diesel generator auxiliary systems in the IST. program. GPC representatives' argued that since the subject systems were not designed according to the ASME Section III rules, they do not have to follow the Section XI inspection and testing rules. However, the NRC's position is that 10 CFR 50.55e requires pumps and valves in safety-related systems to be included in the IST program. Pumps and valves that are not safety-related, even if they were ASME Section III de-signed and constructed, are not required to be included in the IST program. The emergency diesel generator auxiliary systems, including the diesel engine service wcter cooling system, the diesel fuel transfer system (from the main storage tank to the day tank), and the air start system (from the compressor discharge check valves to the engine including the air start solenoids) have safety-related functions and they must be included in the IST program. Skid mounted diesel generator equipment need not be included in the program since inclusion of this equipment typically results in numerous relief requests without an increase in testing beyond'that perfonned under the Technicti Specification.

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. j4 Mr. J. P. O'Reilly -

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It 'is requested that the results of .the meeting, as documented in the enclosed ' l summary, and the NRC position regarding the emergency diesel generator auxiliary j systems be reflected in the resubmittal of the 'IST program for Hatch . Units '1 and 2.

Please contact me if you have any questions on this matter. o Sincerely, )

i s\: ,

1 Lawrence P. Crocker, Project, Manag'er l Project Directorate II-3 ,

Division of. Reactor Projects. I/II_- J q

Enclosure:

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cc: See next page DISTRIBUTION:

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'NRC PDR Local PDR H PRC System PD23 Reading MDuncan ,

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4 Mr. J. P. O'Reilly- . l l It is requested that the results of the meeting, as documented'in the enclosed summary, and the NRC position regarding the emergency diesel generator auxiliary.

systems be reflected in_ the resubmittal of the IST program for Hatch Units.1 and 2.

Please contact me if you have any questions on this matter.

l Sincerely, 0

gl f. .AK4Lr Lawrence P. Crocker, Project Manager.

Project Directorate 11-3  !

l Division of. Reactor Projects, I/II , !.

Enclosure:

As stated cc: See next page l

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EDWIN J. HATCH NUCLEAR PLANT UNITS 1 & 2

. TUMP- AND VALVE INSERVICE TESTING PROGRAM .]1 REVII:W QUESTIONS AND COMMENTS.

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1. VALVE TESTING PROGRAM A. General Questions and Comments

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

Response: ,

All valves that are Appendix J, Type C, leak rate tested are included in the IST program and Categorized A or A/C. Any changes in the Appendix J program will be reflected in IST.

program changes.

2. The NRC has concluded that the applicable leak test procedures 4 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 f

since the intent of IWV-3421 through 3425 is met by Appendix J I requirements, however, the licensee shall comply with Paragraphs IWV-3426 and 3427.

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Response

The licensee's IST program will be revised to indicate that l it complies with the requirements of IWV-3426 and 3427. The discussion in Section 6.0 of the Hatch IST program, )

" Containment Isolation Valves", will be expanded to include i

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e a discussion of the methodology (i.e., the assignment of specific leakage limits to either individual CIVs or groups -

of valves associated with a penetration) used in leak rate testing thess valves. A listing will be provided of the valves tested in containment penetration groups.

ADDITIONAL DISCUSSION:

The licensee will provide specific information to address problems they have in complying with the requirements of IWV-3427(b) in the form of a request for relief.

3. 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 licensee provide a technical justification for -

each valve that cannot be exercised quarterly during power operations that clearly explains the difficulties or hazards that would be encountered during that testing. The NRC staff will then verify that it is not practical to exercise those valves and that the testing should be performed during cold shutdowns. Cold shutdown testing of valves identified by the licensee is acceptable when the following conditions are met:

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

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

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. -l Any testing not completed.during one cold shutdown should be

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. performed during any subsequent cold shutdowns. starting from 3 the last test' performed at the previous cold shutdown. ,

d. For planned cold shutdowns, where ample time is available and testing all the valves: identified for the cold shutdown test frequency in the IST' program will be accomp1.ished, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken. j I

Do the Edwin.I. Hatch Nuclear Plant Units 1 & 2, IST. programs corform to this staff position for valves tested'on a cold shutdown frequency? j Response: j The licensee has stated that their IST. program will conform with these conditions for cold shutdown. testing. .Further, .:

cold shutdown justifications may be provided in a " Cold Shutdown Justification" section in their IST program rather than in the form of relief requests as they are presently presented.

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

Response

The limiting values of full-stroke times were provided on site for inspection for all applicable Unit I andl2 valves.

A statement will be added to the IST program to demonstrate that the limiting values of full-stroke' times are' assigned-based on component considerations. ' Valve stroke' times are:

presently derived utilizing the light to light method.

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5. When flow throughia check valve is used to indicate.a full-stroke exercise of-the valve disk, the NRC staff position is that -

verification of the maximum flow rate identified in any'of the plant's safety analyses-through the valve would be an 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 l

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

Response

The verification of check valve full-stroke utilizing system. .

flow was discussed with the licensee. The licensee will ~

review their IST program to determine if flow may be used to demonstrate check valve full-stroke. Where this option is feasible, revisions to the IST program will be submitted.

6. The relief request and cold shutdown justification bases 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

The need for more detail in relief request and cold shutdown justification bases was discussed with the licensee.

7. Those valves, if any, that serve both a pressure boundary isolation function and a containment isolation function must be leak tested to both the Appendix J and the Section XI '

requirements. The Edwin I. Hatch Nuclear Plant Units 1 & 2,.IST 4

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programs s.1ould conform to this staff position, therefore, provide.. clarification of the leak rate testing discussed under l

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

Response: I l

The discussion concerning PIV testing in-Section 6.0 of the- ,

Hatch IST program will be revised to clarify the types of-testing performed. The licensee has stated that their testing meets the applicable requirements of Appendix J and Section XI'for these valves. I

8. The NRC staff position is that the errergency diesel generators perform a safety-related function and that the appropriate valves in the emergency diesel air start, cooling water, and. fuel oil transfer systems should be included in the IST program and be tested in accordance with the Code. Engine driven pumps are -

considered to be part of the diesel and need not be tested  !

separately. Provide the P& ids that show these emergency diesel generator subsystems for our review.

Response: ,

e The NRC will provide written direction to the licensee within 30 days of this meeting to address the inclusion of the appropriate emergency diesel generator subsystems.in their IST program. No further action concerning the '

emergency diesel generator subsystems will be taken by Georgia Power Company (GPC) until this written direction is i-received. t

9. Solenoid operated valves are not exempted from the stroke time measurement requirements of Section XI; their stroke times must '

be ceasured and corrective action taken if these times exceed the I 5

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limiting value of full-stroke time. The'NRC staff will' grant-relief-from-the trending requirements'of'Section XI (paragraph ~ , j IWV-3417(a)) for these' rapid-acting' valves; however, in order to obtain this relief, the licensee must assign a maximum' limiting I

stroke time.of two seconds.to these valves.

Response

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The licensee will provide a request for relief from the trending' requirements of IWV-3417(a) for their. rapid' acting valves (valve's which normally stroke in two secon'ds or less) in their IST program resubmittal.

10. The NRC staff position is that excess flow check valves perform a-

' safety-related function and should be included in the IST program. '

-I Response: '

, The excess flow check valves will be included -in the IST program and Categorized A/C to be exercised to the~ closed position during refueling outages. A relief request will be ,

provided demonstrating the impracticality of. exercising these valves quarterly or during' cold shutdowns, a

11. Clarify the definition of " Passive Power Operated Valves"  !

contained in Section 6 of the IST Program. Why are these valves. -j cycled?

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Response

1 This remains an OPEN ITEM for the licensee to review further i and address this.in their IST program re' submittal'.

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12.

Relief Requests and Notes that reference the FSAR, Technical Specifications, and other documents should be expanded to provide a brief discussion of the applicable technical information j

contained in the referenced document, i

I Response: i f

l 1 This topic was discussed and it remains an OPEN ITEM for the }

J licensee to review further.

I 13.

The NRC staff has concluded that a valve sample disassembly and inspection utilizing a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke capability. This program involves grouping similar valves together and testing one valve in each group during each refueling outage. The sampling technique requires that each l

valve in the group be of the same design (manufacturer, size, "

model number and materials of construction) and have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

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

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Response: ',

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The' check valve sample disassembly and inspection program .

was discussed. GpC will develop a list of valve groupings and submit this information in a' relief request with sufficient detail to evaluate their sampling proposal. GPC has an extensive list of candidate valves for disassembly.

and inspection.

14. ADDITIONAL COMMENT:

The NRC staff has determined that the following control rod hydraulic system valves perform'a function that is safety-related and should be included in the IST program and tested in accordance with the Code requirements:

i 1(2)C11-114 1(2)C11-115 1(2)C11-138 ..

l l 1(2)C11-126 1(2)C11-127 1(2)C11-F010A l 1(2)C11-F010B 1(2)C11-F011 1(2)C11-F037 1(2)C11-F035A 1(2)C11-F035B B. Main Steam and Feedwater System

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

Response

i Exercising tnese valves during power operation could result in a plant trip. Full-stroke exercising these valves during cold shutdown could delay plant start-up since closure must

. be verified by leak test. A more detailed technical 1

justification will be provided in the IST program resubmittal.

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2. Review the safety-related function of the main steam relief valves,121-f013A, B, C, D, E,.F, G, H, J, K, L, and M to ]

determine if they should be categorized B/C. If they are power: l operated.. provide'a detailed technical justification for notL full-stroke. exercising them and measuring stroke times quarterly.

Response

These valves.will be categorized B/C. Full-stroke-exercising these valves during power operation could result" in a Loss of Coolant Accident (LOCA) if one of-these valves struck open. Relief.will be requested from the Code stroke timing requirements since these valves are 'e'xtremely fast  !

acting and repeatable stroke times cannot be obtained H

without using special equipment and test methods- '

i Additionally, information will be.provided.in the IST:

program resubmittal describing other. testing performed on. ~

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these valves. I i

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3. Provide Relief Request 6.1.23 for our review. Does this request apply to both IST programs or to the inboard MSIVs at Unit 1 and I the outboard MSIVs at Unit 27 j

Response

0 This relief request has been deleted from the IST program.-

4. Describe how the MSIVs are full-stroke exercised quarterly.

Response

These valves are full-stroke exercised (fast strok'de closed and reopened) quarterly during' power operation and their stroke times are recorded. GPC may reevaluate the quarterly j j

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full-stroke exercising of these MSIVs and provide a cold' '

i shutdown justification for full-stroke exercising these. ~

valves on a cold shutdown frequency.

5. provide a more detailed technical justification'for not 1 full-stroke' exercising valves.B21-F032A and -F032B_ quarterly during power operation and cold shutdowns.l(Unit 1)L ~!

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Response

Exercising'these valves during power operation could result in a plant trip.- Full-stroke-exercising'these valves during cold shutdown could delay plant start-up since closure must ll 1

be verified by leak test. A more detailed' technical justification will be provided in the IST program

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resubmittal.  !

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6. Is valve B21-F032A required to perform a safety-related function. I in both the open and closed positions? P&ID H-16188 does not appear to agree with P&ID H-16062. (Unit 1)

I Response: l i

B21-F032A performs a safety-related function in' the. closed position only. The current revision of this P&ID shows the correct p* ping configuration for this valve an' dwas provided at the meeting. (Credit is not taken for operation of the RCIC system in plant safety. analyses.)

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

-F0778 quarterly during power operation.

Response

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Exercising these valves during power operation could result in 4 plant trip. Full-stroke exercising these valves during cold shutdown could delay plant start-up since closure can be verified only by leak testing. A more detailed technical justification will be provided in the IST program resubmittal.

8. Review the safety-related function of the following valves to ,

determine if they should be included in the IST program: l B21F525 B21RV-F110A B21RV-F1100 B21RV-F110G B21RV-F110H

Response

Valve B21F525 has been deleted from the system. Valves 1821F110A, F1100, F110G, and F110H have been added to the '

IST program and relief requested from exercising these valves quarterly (see valve relief request no. 6.1.3). This relief request will be expanded to include full-stroking of these valves during cold shutdowns when de-inerted and refueling outages. These valves are located inside the drywell and are inaccessible during operation.

I C. Reactor Recirculation System

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

-F017B quarterly during power operation and cold shutdowns.  !

Response

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Exercising-these valvesiquarterly during plant operation '

could result:in_ pump seal? damage from loss oficooling.

The only practical method to. verify closure of'these valves is leak rate testing which will be performed on a' refueling outage frequency.,

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

Response

These valves'are inside.the drywell and duesto'the hostile-environment are inaccessible during power operations.

Failure of these valves in the closed. position during power operation would stop recirculation pump flow and' result in plant shutdown.

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'D. . Standby Liouid. Control System

1. Provide a more detailed technical justification for not full-stroke exercising valves C41-F006 and'-F007 quarterly.

Response

Full-stroke exercising these valves quarterly during power operation or at cold shutdown is impractical since it would' require. firing the~squibb valves (explosively actuated-valves) and replacing the explosive charges.

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

Response

These valves can be verified closed only by local' leak rate testing which is performed on a refueling outage frequency.-

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. 3. How are valves C41-F033A and -F033B full-stroke exercised I quarterly. -

Response: .

l The full-stroke of valves C41-F033A and F033B is verified by pumping demineralized water through these valves and into the test tank and calculating the flowrate by the rate of tank level change.

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E. Residual Heat Removal System i

1. Provide a more detailed technical justification for not  !

i full-stroke exercising valves E11-F008 and -F009 quarterly. i

Response

These valves are interlocked with reactor coolant system  !

l J pressure to prevent operation when the plant is at normal operating pressure. Exercising the'se valves quarterly could result in overpressurization of the residual heat removal

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system suction piping. I

2. Review the safety-related function of valves E11-F021A and -F021B to determine if they should be categorized A. l i

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Response

1 These valves are not included in the Appendix J program to be Type C leak rate tested and need not be included in the IST program as Category A valves.

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3. Provide a more' detailed technical justification for not '

full-stroke-exercising valves E11-F078A and -F078B quarterly.

How are these valves presently being full-stroke exercised 7

Response

These valves do not perform a safety-related function and need not be included in the IST program.

ADDITIONAL CONNENT:

Valves 1(2)E11F073A&B, 75A&B, and 119A&B also do not perform a safety-related function and need not be included in the IST program. These valves will be deleted from the resubmittal. .

4. Review the safety-related function of valves E11-F024A, -F024B, "

-F027A, and -F027B to determine if they should be categorized A.

Response

These valves are not. included in the Appendix J program to be Type C leak rate tested and they need not be included in the IST program as Category A.

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

Response

These valves are leak rete tested in accordance with Section XI and will remain Category A in the IST program I resubmittal.

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6. How are valves E11-F046A, -F046B, -F046C, and -F046D verified to full-stroke exercise quarterly? provide Note 29 for our review-(Unit 2).

Response

The' licensee will investigate a method for verification of full-stroke utilizing flow through the miniflow.line during quarterly pump testing. .If no method can be devised, then verification will,be by sample disassembly and inspection.

The correct reference is Note 5 and not Note 29.

7. How is long term reactor cool down accomplished if credit is not taken for the operability of valves E11-F06BA and -F068B?

Response

Credit is taken for the operability of these valves, however, stroke timing of these valves could result in pump .

damage since operating these valves to the full open position would cause pump runout. These valves.are interlocked with the RHR service water pumps and the pumps i

must be running to operate these valves. A relief request will be provided describing why it is impractical to 1 exercise these valves quarterly during power operation and {

I during cold shutdowns.

8. Review the safety-related function of the following valves to determine if they should be included in the IST program and tested in accordance with Section XI-E11-F040 E11-F049 E11-F089 E11-F090 j E11-122A E11-F1228 E11-F005A E11-F0058 E11-F005C E11-F005D l

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Response: ']

Valves E11-040 and'049 have~been added to the.IST program.

Valves E11-F089 and'F090 are for operating convenience only. Their only function is to prevent'back flow into th'e-condensate transfer system when-F088 is open while manually.

backflushing the.RHR system and they need not be, included'in I the IST program. Valves E11-F005A-D will be. included in'the IST program and verified.in:the open and closed positions.

Valves E11-122A&B will.be included in.the IST program as Category A-passive valves.

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9. Provide a discussion that justifies not measuring the stroke time of valves E11-F200A-0, and 2E11-F207A-D quarterly. How are these

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valves fail-safe tested quarterly? .

Response

OpEN ITEM for the' licensee to determine if these-valves have'

. reauired fail-safe positions. The NRC staff's position is

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that if a valve has a reouired fail-safe position, then it- I should be included in the IST program and tested to the Code g requirements. ,

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

Response

These valves have been removed from the system and' deleted l from the IST program, i l

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

Response

Valves 2E11-F201A-D have been removed from the system and will be removed from the IST program.

F. Core Soray System

1. How are valves E21-F036A and -F036B' individually verified to full-stroke exercise quarterly?

Response

The licensee will investigate a method for verification of j

flow through these valves during quarterly' pump testing. If - i no method can be devised, then verification will be by j i

, sample disassembly and inspection.

2.

Nhat is the P&ID location of valves 2E21-F044A and -F044B7 l

Response

l' P&ID H-26019, coordinates E-1 and E-9 respectively, this l

will be corrected in the IST program resubmittal.

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

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E21-F029A E21-F029B E21-F030A E21-F030B E21-F037A E21-F037B 17

Response: ,

Valves E21-F029A, B, F030A,.and B are for o convenience only. perating Their only function is to prev flow into the condensate transfer system ent wh back en F088 is open while manually flushing the core spray system not be included in the~IST program. and they need 0378 are pIVs and will be categorized A andValves E2 rate tested to the Appendix J and Section XI will be leak requirements.

G.

High pressure Coolant In.iection System 1.

If failure of valve E41-F002 during quarterly t render an entire safety system inoperableesting would valve during cold shutdowns should be considered, then te Response: .

Quarterly testing of this valve could rerender an ent safety system inoperable.

will be provided with applicable technical jus exercising this valve on a cold shutdown cation for freque ncy, 2.

Is valve E41-F007 accessible during power o failed during testing, could it be reopened peration? If it manually?. Why is there a concern with failure of this val when valve E41-F002, which is inaccessibleve during power op quarterly? , is exercised Response:  ;

Valve E41-F001 is located outside of the pri and will be exercised quarterly mary during containment power op eration or a cold shutdown justification will be provided e with th applicable technical justification for testing thi a cold shutdown frequency. s valve on 18

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3 '. Describe the containment isolation function performed by valve E41-F008.Section XI, Table IWV-3700, requires that passive Category A containment isolation valves be leak rate tested.-  !

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Response

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Valve E41-F008 is not a containment isolation valve. It will be full-stroke exercised quarterly _and reference to Note 1 will be deleted from the IST program. I

4. Valves E41-F008 and -F011 must change position to prevent ,

diversion of flow if an initiation signal is received while the system is in the test mode. The NRC staff position is that these valves should be included in the IST program and tested in accordance with Section XI.

Response: ..

Valve E41-F008 will be full-stroke exercised. quarterly.

Valve E41-F011 will be full-stroke exercised quarterly and j reference to Note 14'will be deleted from the IST program.  !

5. Relief Request 6.1.12 may not be necessary for the HPCI System j because the NRC staff position concerning full-stroke exercising )

of check valves is that if the valve'is exercised by passing full' i design basis flow through it, then the valve is considered to have been full-stroke exercised. This position is satisfied by f'ull flow tests of the HPCI pump and turbine.

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Response: l i

Check valves F021, F022, F040, and F049 are considered to be  ;

full-stroke exercised during quarterly testing of the HPCI d system since the steam flow through these valves durin's this quarterly testing is the maximum amount taken credit for in their accident analysis. Relief request no. 6.1.12 may be deleted from the IST program.

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6. The NRC staff position concerning the disassembly of valve E41-F045 is that disassembly to verify valve operability be.

performed each refueling outage instead of every other refueling outage. l

Response

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The licensee has stated that technical data concerning- "

previous disassembly and inspections of valve E41-F045 may justify increasing the interval for valve disassembly and

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inspection to every other refueling outage.. This ,

information will be presented in a request for relief in their IST program resubmittal.

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

Response

This valve is not verified to full-stroke quarterly. The '

licensee has stated that technical data concerning previous disassembly and inspections of valve E41-F046 may justify increasing the interval for valve disassembly and inspection to every other refueling outage. This information will be presented in a request for relief in their IST' program resubmittal.

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8. Review the safety-related function of. valves E41-F103 and -Fill .i to determine if they should be included in the IST program and ,.

tested in accordance with Section XI. ]

Response

Valves E41-F102 and F103 will be included in the IST~ program and functionally verified to close quarterly,and verified to f open during refueling by blowing air through them during leak rate testing.

I

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

. I Response: 1 1

Valves E41-F057 and F048 can be demonstrated operable only during yearly bearing temperature testing. These valves will be included in the IST program and a request for relief will be provided to indicate that this testing is impractical since bearing temperatures do not stabilize during quarterly pump turbine testing. I

.]

10. Review the safety related function of valves 2E41-F025 and -F026 to determine if they should be included in the IST program and tested in accordance with Section XI.

Response

Valves 1(2)E41-F025 and F026 perform no safety-related function and will be deleted from the IST program. l l

4 6

21

H. Reactor Core 1 solation Cooling System ADDITIONAL COMMENT: j k

i The licensee does not take credit for the operability of.the ]

RCIC system in any of their accident safety analyses. With' the exception of those valves performing a containment isolation function, this system need not be included in the IST program.

i

1. Relief Request 6.1.12 may not be necessary for the RCIC System  ;

because the NRC staff position concerning full-stroke exercising of check valves is that if the. valve is exercised by passing full l design basis flow through it, then the valve is considered to i have been full-stroke exercised. .This position is satisfied by- ,

i full flow tests of the RCIC pump and turbine.

Response

RCIC valves E51-F001, F002, F028, F040 are included in the ,

Appendix J program and will remain in the IST program and be leak rate tested during refueling outages.

2. Provide a more detailed technical justification for not measuHng l the stroke time of valve E51-F019 quarterly. i

Response

Valve E51-F019 will remain in the IST program and have its stroke time measured quarterly.

22

3. How is valve E51-F021 verified to full-stroke exercise quarterly?

Response

Valve E51-F021 is included in the Appendix J program and will remain in the IST program and be leak rate tested during refueling outages. '

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

Response: 1 There was a typographical error in the IST program. Valve.

E51-F105 is normally open and will be stroke timed and '

i verified to close quarterly. Relief request 6.1.2 applies to both valves.

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

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

Response

Credit is not taken for operability of the RCIC system in any plant safety analyses. These valves r.esd not be included in the IST program.

23

6. Review the safety-related function of valves E51-F102 and -F103 to detePmine if*they should be included ,n the IST. program and ,.

tested in accordance with Section XI.

Response

These valves perform no safety-related function and need not be included in the IST program.

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

Response

The P&ID was provided. No further questions.

I. Reactor Water Clean-up System

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

i

Response

Valve G31-F039 is not a passive containment isolation valve. This valve will be leak rate tested during refueling outages and a technical justification will be provided for not exercising this valve quarterly or at cold shutdowns since.this testing would shut off half the vessel feedwater. Unit 2 has a different piping configuration and this valve in Unit 2 does not perform a containment  !

isolation function.

j 24 O _ __________m_-m___

J. Torus Drainaoe and purification System

1. Why.is valve G51-F002 categorized AE7

Response

Valve 651-F002 is a Category A-passive valve. The AE designation is a typographical error and will be changed in the IST program resubmittal.

2.

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

Response

Valve 651-F001 does not perform a safety-related function and need not be included in the IST program. -

3.

What is the normal position of valves G51-F011 and -F012? The normal position indicated on P&ID H-16135 does not agree with Note 1 of the program. (Unit 1)

Response

The P&lD will be revised to indicate that these valves are normally closed and fail closed. These valves are Category A-passive and will be leak rate tested at refueling outages.

4.

Why are valves 2G51-F011 and -F012 categorized AE7

Response

Valves 2651-F011 and F012 are Category A-passive. The AE designation is a typographical error and will be changed in the IST program resubmittal.

25

K. Demineralized Water System

1. Why are-Unit 1 valves P21-F353 and -F406 and Unit 2 valves 2P21-F032 and -F034 categorized'A/E7 Response: '

Valve 1P21-F353 and Unit'2 valves F032 and F034 are Category A-passive and leak rate tested during refueling-outages. Valve P21-F406 does not perform a containment isolation function and need not be included in the IST-program.

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

Response: -

Valve P21-F420 has been included in the IST program as '

Category A passive.

L. Hydrogen and Oxygen Analyzer' System

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

Response

j valves P33-F005 and F013 have been added to the Unit l' program as Category A valves (CIVS) and will be full-stroke I exercised quarterly. j i

26

M. Plant Service Water System

1. Relief Request 6.1.14 does not meet the NRC staff position explained in Item A.13 of these questions,1 therefore, provide the appropriate relief requests that include an exercising frequency .

1 and groupir.g of valves that meets this staff position. I

Response

The licensee will investigate a method for verification of full-stroke exercising for these valves and present relief requests for these valves where necessary.

1

2. Review the safety-related function of valves P41-F064 and -F065 j to determine if they must also close to perform their safety -

function. (Unit 1)

Response: .j These valves perform no safety-related function in the )

closed position. These valves will remain in the IST {

program and be tested to the open position quarterly. These l valves will be confirmed to pass rated system flow by virtue f of adequate system function.

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

l Response: l These valves perform no safety related function and need not  ;

be included in the IST program.

27 j

.-___--______m

4. Provide a discussion that justifies not measuring the stroke time of valves PH -F208A, -F2088, -F208C, and -F208D quarterly. How- )

are these valves fail safe tested quarterly? (Unit 1) l

Response

l j

Valves p41-F208A, F2088, F208C, and F2080 perform no safety-related function and need not be included in the IST program.

l l

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

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

Response

(

A relief request or cold shutdown justification will be -

provided to include the technical justification for not full-stroke exercising valves P41-F310A, F3108, F3100, and F3100 either quarterly or during cold shutdowns. P&lD H-11600 was provided which shows these valves.

0

6. How would failure of valve p41-F311A, -F311B, -F3110, or.-F3110 in the open position affect plant operation? Should these valves also be verified to shut?

1

Response

These valves perform a safety-related function in the closed position but can be verified shut only when a pump is secured. This cannot be performed quarterly and a relief' request will be provided to address these technical considerations.

28 L _ __--__--_---___ - - _ . -

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

Response

No.further questions. The P&ID locations are as follows:

Valve P&ID and coordinates 208A D11001 E-2 1 208B D11001 E-4. )

208C D11001 E-3 l 208D D11001 E-5 310A H11600 0-6  ;

310B H11600 F-5 3100 H11600 0-6 310D H11600 F-5 311A D110D1 E-2 ,

311B D11001' E-5

{

311C D11001 E-3 J 311D D110D1 E-6

8. Review the safety-related function of valves P41-F438A and -F438B to determine if they should be included in the IST program and tested in accordance with Section XI. (Unit 1)

Response

Valves P41-F438A and F438B will be included in the IST program and verified to full-stroke exercise open quarterly using the inline sight glass flow indication.

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

l 1

l ,

29

l

- ]

Response: ,

These valves do not perform a safety-related function and i need not be included in the IST program.

10 Valves 2P41-F315A and -F315B have not been identified as passive valves, therefore, they must be tested in accordance with the 1 l

Sectirn XI requirements for Category B valves. 4 1

l

Response

4 These valves are Category B-passive, are.not required to perform a safety-related function, and will be removed from j the IST progran.  :

1 y

1

. 4

11. What are the consequences of full-stroke exercising valves 2P41-F316A, -F316B, -F3160, and -F316D quarterly during power "

operation? {

1 1

Response

]

A relief request or cold shutdown justification will be provided to include.the technical justification for not full-stroke exercising valves 2P41-F316A, F3168, F316C, and F3160 either quarterly or during cold-shutdowns (if necessary).

P&ID H-11600 shows these valves and was provided.

12.

Have valves 2P41-F319A-D been removed from the system? If not, they should be tested in accordance with Section XI.

Response

i These valves have been removed from the system.

30 '

__ .-. d

13. Provide a discussion that justifies not measuring the stroke time of valves 2P41-F320A, -F3208, -F3200, and -F320D quarterly. How are these valves fail-safe tested quarterly?  !

Response

Valves 2P41-F320A, F320B, F3200, and F3200 perform no 1 safety-related function and need not be included in the IST program.

l

14. Review the safety-related function of valves 2P41-F306A and j

-F306B to determine if they should be included in the IST program and tested in accordance with Section XI. q Response: j l

Valves 2P41-F306A and F306B will be included in the IST

program and verified to full-stroke exercise open quarterly l using the inline sight glass flow indication.

15. Provide a more detailed technical justification for not measuring the stroke time of valves 2P41-F339A and -F339B quarterly.

Response

Relief request 6.1.15 will be revised and will include more details concerning the difficulty encountered in attempting to obtain repeatable stroke times for those valves.

16. What is the P&ID location of valve 2P41-F340?

Response

This valve has been renamed IP41-F340; the P&ID location is H-11600, coordinates B-5. Note 7 in the IST program will be deleted and this valve will be included in relief request 6.1.15.

31

17. Review the' safety-related function of valves 2P41-F321, 2P41-F312A, and -F3128 to determine if they should be included in the IST program and tested in accordance with Section XI. '

Response

Valve 2P41-F321 will be included in the IST program resubmittal and will have full-stroke verified during I

quarterly testing of the standby diesel generator service water pump. Valves 2P41-F312A and F312B do not perform a safety-related function. They~are used only for maintenance and need not be included in the IST program.

' N. Reactor Building Closed Cooling Water System

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

Response

A cold shutdown justification will be provided to address  !

the technical considerations for these valves. Operating l these valves quarterly could result in pump damage. l

0. Service Air System

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

Response

This is a typographical error and will"be corrected in the resubmittal. These valves are Category A-passive.

1 32 1

9

i

, P. Drywell pneumatic System I

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

B21-F024A B21-F024B B21-F024C B21-F0240 l

I B21-F036A B21-F036B B21-F036C B21-F0360 B21-F036E B21-F036K B21-F036F B21-F036G B21-F036H B21-F036J B21-F036L Response: I i Valves B21-F024A, B, C, and D do not perform a

]

safety related function and need not be included in the IST ,

program. Credit is not taken in the Hatch Units 1 and 2 .

FSAR safety analyses for the air accumulators to provide.

motive force in closing the MSIVs.

] )

I l

Valves B21-F036 A, B, C, D, E, K, F, G, H, J, and L will be l included in the IST program and leak tested during refueling l l

outages.by verifying that accumula' tor pressure'does not decay when the air supply header is depressurized.

Q. Containment Purge and Inerting System i

1. What is the normal position of valves T48-F11BA and -F11BB? The body of the IST program does not agree with the P&ID. (Unit 1) ,

l

Response

The normal position for these valves is closed and they fail closed. The IST program will be revised to reflect this.

33 i

s

2. What is the normal position of valves T48-F319 and'-F320? The  !

body of.the iST program does not agree with the P&ID. (Unit 1) 1 I

Response

The normal position for valves T48-F319 and -F320 is closed and they fail closed. The P&ID will be revised to reflect ] ,

this.

l l

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

Response: q l

]

l I Valves T48-F318 and T48-F326 and Unit 2 valve 2T48-F318 are ,

normally closed and the IST program will be revised to reflect this.

Provide a detailed technical justification for not measuring the i 4.

stroke time of valves T48-F323A-L quarterly.

Response

These valves are testable check valves; however, no meaningful stroke time can be obtained. The description column for these valves will be revised and the A0 will be deleted.

l l 5. Provide a detailed technical justification for not measuring the  ;

stroke' time of valves T48-F328A and -F328B quarterly.

Response: j l

These valves are testable check valves and no meaningful  !

l stroke times can be obtained. The description column for these valves will be revised and the A0 will be 6eleted.

I i

34 I

M u________ _ _ _ _ _ _ _ _ _ _ __ _

d .;

j 4

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

Response

These valves perform a containment isolation function and a relief request will be provided since the only practical method for verification of valve closure is leak rate testing which will be performed during refueling outages. 1

7. What is the normal position of valves 2T48-F209, -F210, -F211, i and -F212? The body of the IST program does not agree with the l P&ID.

Response:  !

The normal position of these valves is closed. The IST program will be revised to reflect this.

R. Traversing In-core probe System

1. Review the safety-related function of the TIP shear valves to I

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

Response

l l

l These valve will be included in the IST program as Category D and tested to the Code requirements.

l 35

, i

2. Is the TIP nitrogen purge supply line equipped with an isolation -

check valve?- If so, it should be included in the IST program and its closed position verified.

Response

This check valve in each unit will be included.in the IST program as Category A/C. Leak rate testing is the only method available to verify these valves in the closed position and this testing will be performed on a refueling l outage frequency.

S. Fission Products Monitoring System

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

Response: -

Valve 2011-F053 is normally open and this valve is exercised quarterly in.accordance with the Code.

1 i  !

l

2. Why are valves 2011-F058 and -F061 categorized AE?

l

Response

l Valve 2011-F061 has been deleted from the IST program and valve 2011-F065 has been added. Valves 2011-F058 and F065 are Category A-passive and the IST program will be revised to indicate this. A relief request will be provided for leak rate testing F065 in the reverse direction.

36

's_ _a_____-_--

.c T. MSIV Leak' age Control System

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

Response

Valves 2E32-F006, -F007, -F008, and -F009 cannot be operated l i

with steam line pressures >5 psig. This information will be added to a cold shutdown justification.

U. Radwaste System l

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

Response: "

l These valves are Category A passive and the IST program will l

, be revised to reflect this.

V. ILRT System

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

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

Response

Valve:i 2T48-F363A and F364B have been added to the IST program as Category A valves. These valves.will be exercised quarterly and leak rate tested during refu.eling outages. These valves are in the containment purge and inerting system section of the IST Program.

i 37

W.- Fire Protection System

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

-F160. Why is valve -F160 categorized AE?

Response

These valves have been removed and the penetration has been cut and capped. The P&lD is not necessary.

X. Reactor and Radwaste Building Service Air System

1. Review the safety-related function of valves 2P51-F513 and -F651 to determine if they should be included in the IST program and categorized A. .

Response

These valves are locked closed and have been added to the IST program as Category A-passive and will be tested in l accordance with the Code.

i i

1 i

i l

38 i o

a - -- . . _ . - - _ _ _ _ - - -

?

1

e. '

s

. Pump Testing Program

.j

1. What is the basis for establishing a minimum vibration reading.of.

1.5 mils for._all. service water pumps in the_IST program? How are vibration measurements of less than 1.5 mils trended from test to )

test? ~

Response: -

The licensee will provide a request for relief for these I

pumps and' include the technical justification for l establishing these minimum. vibration values and for not I trending the. lower values.  !

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

l

Response

The licensee will provide a relief request with the j technical bases for expanded ranges of reference values for'-

flow and differential pressure. This will be based on their  ;

review of OM-6, draft 8.

3. Describe the test flow path utilized when measuring the flow rate -

of the standby liquid control pumps, i i

^

Response

This path is from the demineralized water line through the pumps and to the test tank. Flowrate is calculated from the i rate of test tank level change. i a

39

[- ,

l

4. Why were the spent fuel pool' cooling pumps excluded from the IST program? De these pumps perform a safety-related function? - ,

Response

The speht fuel pool cooling pumps are not safety-related.

Credit is taken in the FSAR for RHR as a safety grade backup for the spent fuel; pool cooling system. The spent fuel pool cooling pumps need not be included in the IST program.

l ADDITIONAL COMMENTS: q Keep full stop-check valves E11-F126A&B and E21-F040A&B will.

be included in the IST program and manually verified to  ;

close quarterly. Unit 1 and 2 Jockey pumps 2A, 28, 3A, and 3B are not safety-related and need not be included in the )

IST program.

i 1

1 4

l 40

Mr. James P. O'Reilly Edwin -1. Ha tch Nuclear Plant, Georgia-Power Company Units Nos. I and 2 cc:

G. F. Trowbridge, Esq.

Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.

Washington,.D.C. 20037 1

Mr. L. T. Gucwa 1 Engineering Department Georgia Power Company P. O. Box 4545 Atlanta, Georgia . 30302 Nuclear Safety and Compliance Manager Edwin I. Hatch Nuclear Plant Georgia Power Company P. O. Box 442 Baxley, Georgia 31513 Mr. Louis B. Long Southern Company Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 Resident Inspector U.S. Nuclear Regulatory Commission Route 1, Box 725 Baxley, Georgia 31513 Regional Administrator, Region II '

U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georiga 30323 Mr. Charles H. Badger Office of Planning and Budget j

Room 610 270 Washington Street, S.W.

Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Commissioner Department of Natural Resources ]

270 Washington Street, N.W. l J

Atlanta, Georgia 30334 Chairman i Appling County Commissioners County Courthouse '

Baxley, Georgia 31513

~

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