ML20236T650

From kanterella
Jump to navigation Jump to search
Forwards Draft Info Provided to Util on 871124 to Assist in Responding to NRC Concerns on Plant
ML20236T650
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 11/25/1987
From: Haughey M
Office of Nuclear Reactor Regulation
To: Mcknight J
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8712010431
Download: ML20236T650 (17)
v • d • e


Text

. _ - _ _ _ _ - _ . _ _

Q t.'EC

.#  %, UNITED STATES

-[

g :;

g

,y NUCLEAR REGULATORY COMMISSION

. wAssiwarou, o. c.rosss

. % .... / A&ra&c.pgns?

i' Docket No. 50-410 NOTE TO: Jim McKnight, Document Control FROM: Mary Haughey, Project hdnager for Nine Mile Point, Unit 2 Project Directorate I-l .

Division of Reactor Projects I/II

SUBJECT:

DRAFT INFORMATION PROVIDED TO NIAGARA M0 HAWK POWER CORPORATION

< ON NINE MILE POINT, UNIT ?

The enclosed information was provided to Niagara' Mohawk on //-2f-87 to assist them in responding to NRC concerns on Nine Mile Point. Unit 2.

cop of th note the enclosed information should be placed in the R

99 E heze S Mar ughey,Pr6Te~ctManaae Project' Directorate I-1 Division of Reactor Projects I/II cc: PDR LPDR i

871201043187Mkto PDR ADOCK O PDR P

L

v EG&G Idaho, Inc.

FORM EG&G-460 N0TEGRAM (Rev. 05-84)

Date November 23, 1987 To Horace Shaw From C. B. Ransom /R. S. Hartley

-+

Org. NRC/MEB Org. Mechanical Systems Evaluations l Address Bethesda, MD Address INEL-Idaho Falls. ID NINE MILE POINT NUCLEAR STATION, UNIT 2 PUMP AND VALVE INSERVICE TESTING PROGRAM REVIEW REVISED OVESTIONS Attached is a list of questions and comments generated from our review of the Niagara Mohawk Power Corporation pump and valve inservice testing (IST) program dated July 30, 1987, for Nine Mile Point Nuclear Station, Unit 2.

These questions and comments replace the questions and comments transmitted to you on October 23, 1987, and are intended to serve as an agenda for the working meeting. Many of the questions and comments in the October 23, 1987, request for additional information (RAI) have been deleted from this RAI since the concerns that led to their inclusion have been satisfactorily addressed in the most recent program submittal. Some of the original questions have been modified due to program changes and the following questions were added to this RAI as a result of our review of the July 30, 1987 program: A-13, A-14, J-9, Q-13, Q-14, S-1, T-1, 2-12, and 2-13. Formal written responses need not be provided prior to the working meeting. If you have any questions, please contact us at (FTS) 583-4362 or 583-9405.

/

Attachment:

l As Stated  ;

cc: D. L. Caphton, NRC/ Region I M. F. Haughey, NRC/PD11 C. F. Obenchain H. C. Rockhold E. J. Sullivan, NRR/EMEB 4 l

ed L_________

NINE MILE POINT NUCLEAR STATION, UNIT 2

._ PUMP AND VALVE INSERVICE TESTING PROGRAM ,

c QUESTION 5'AND COMMENTS. .

1. VALVE TESTING PROGRAM A. General Ouestions and Comments
1. If a manual cherator is used to full-stroke exercise check valves that cannot be full-stroke exercised with flow, is the force or torque that is applied to the mechanical exerciser measured to assure compliance with IWV-3522(b)?
2. The NRC has concluded that the applicable leak test procedures and requirements for containment -isolation valves are determined by 10CFR50, Appendix J. Relief from paragraphs IWV-3421 through 3425 ,

for containment isolation valves presents no safety problem since

'the intent of IWV-3421 through 3425 is met by Appendix J requirements, however, the licensee shall comply with Paragraphs IWV-3426 and 3427. General Relief Request GVRR-1 does not comply with this staff position.

3. Provide a listing of all valves that are Appendix J, Type C, leak t

rate tested which are not included in the IST program and J

Categorized A or AC?

4. The NRC staff has identified rapid-acting power operated valves as '

those which stroke in 2 seconds or-less. Relie'f may be obtained from the trending requirements of Section XI, Paragraph IWV-3417(a), however, in order to obtain this Code relief the staff

^

does require that the licensee assign a maximum limiting stroke time of 2 seconds to these valves and comply with the requirements of IWV-3417(b) when the 2 second limit is exceeded. General valve relief request GVRR-3 does not comply with this staff position. q i

I 1

l

- . _ _ _ _________-__________-___--___a

..f 5. Provide the limiting. values of full-stroke times for the power operated valves in the Nine Mile Point Nuclear Station, Unit 2, IST program for our review. What are the bases used to assign the limiting values of full-stroke time for these valves?

6. When flow through a check valve is used to indicate a full-stroke exercise of the valve disk,- the NRC staff position is that verification of the maximum flow rate identified in any of the plant's safety analyses through the valve would be an adequate ^

demonstration of the" full-stroke requirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differential pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve. Does the Nine Mile Point Nuclear Station, Unit 2, IST

, program conform to this staff position?

7. 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.
8. Which valves at Nine Mile Point Nuclear Station, Unit 2, are currently leak rate tested to verify a pressure boundary isolation function?
9. Provide a more detailed technical justification for not testing the excess flow check. valves quarterly during power operations and ,

during cold shutdowns (refer to General Relief Request GVRR-2).

10. How are the remote position indicators being verified for solencid operated valves in the Nine Mile Point Nuclear Station, Unit 2, IST program?

l 11. Deleted 4

2

12. Provide P& ids 52A AND 52G for our review.
13. When a cold shutdown justification addresses a frequency in,terval greater than each cold shutdown (not to exceed one test every three months) it should be presented in the form of a relief request (refer to the discussion in the " Cold Shutdown Testing" section of' Cold St.utdown Test' Justifications'CSH-VCS-3 and ICS-VCS-4).
14. What is the basis for using ANSI /ASME OM-1, 1981 as the alternative criteria for testing safety and relief valves instead of the criteria as outlined in ASME PTC 25.3-1976 and specified in the ASME Code Section XI,1983 Edition through Summer of 1983 addenda?

B. Reactor Buildina Closed looo Coolina System

1. Review the safety-related function of valves 2CCP*V143,.V148,'V161, and V277 (P&ID No.13E-5) to determine if they should be included in the IST program and tested to the Code requirements..

C. Hiah Pressure Core Sorav System

1. Provide a more detailed technical justification that explains why valve 2CSH*A0V108 cannot be exercised utilizing system flow quarterly during power operations (refer to cold shutdown test justification CSH-VCS-1).
2. How is the reverse flow closure of valves 2CSH*V17 and V55 individually verified 7
3. Relief Request No. CSH-VRR-1 indicates that the reverse flow closure of valve 2CSH*V59 will be verified by disassembly and inspection of the valve during refueling outages. ' Valve disassembly and inspection is an acceptable method to verify the

. riverse flow closure of a check valve, but this is not the preferred method. What other test methods have been considered for this valve?

3 ,

j

4. How is valve 2CSH*V7 verified to full-stroke exercise open during quarterly testing?

D. Lou Pressure Core Soray System  !

1. Provide a more detailed technical justification that explains why ,

valve 2CSL*A0V101 cannot be exercised utilizing system flow quarterly during power operations (refer to cold shutdown test justification CSL-VCS-1).

2. Provide a more detailed technical justification for not exercising valve 2CSL*MOV104 quarterly during power operations (refer to cold shutdown test justification CSL-VCS-1).
3. How is the reverse flow closure of valves 2CSL*V14 and V21 individually verified?
4. How is the reverse flow closure verified for valve 2CSL*.V9 during quarterly testing?
5. Does valve 2CSL*V4 perform a safety-related function in the closed position? If so, how is the reverse flow closure of this valve verified?

E. Standby Diesel Ger.erator System

1. How is the reverse flow closure capability verified individually for valves 2EGA*V62A, V62B,.V63A, and V63B?
2. feview the safety-related function of the emergency diesel generator air start valves (2EGA*PCV25A, PCV25B, PCV26A, PCV268, A0V323A, and 10V323B) and the associated in-line check valves (2EGA*V12A, V12B, V14A, and V14B) to determine if they should be included in the IST program.

4

F. Fire Protection Water' System a

1. Are the valves'on either side of containment penetration Z-46C (P&ID No. 43G-6 coordinates'H-4) Appendix J, Type C, leak rate

' tested as containment isolation valves? If so they should be

-included in the IST program and tested to the Code requirements.

G. Feedwater System -

1. What type of leak test do valves 2FWS*M0V2]A and V21B receive? - The leak test type is not specified in the NMP-2 IST program valve- '

tables.

2. Provide a more detailed technical justification for not verifying the reverse flow closure of valves 2FWS*V12A and V128 during cold' '

shutdowns.

H. Nitroaen System ,,

1. - Deleted I. Instrument & Service Air System f
1. Provide a more detailed technical justification for not verifying reverse flow closure for the' valves identified in relie'f request )

4 No. IAS-VRR-2 quarterly and during cold shutdowns.. Identify the specific concerns that make this testing impractical to perform quarterly and during cold shutdowns.

]

2. Deleted
3. Deleted l

5 m

.l I Reactor Core Isolation Coolina System J.

1. Provide a more detailed technical justification that explains why i- valves 2ICS*A0V156 and A0V157, cannot be exercised open utilizing system flow quarterly during power operations. How is the reverse flow closure of these valves being verified during testing at cold shutdowns (refer to cold shutdown test justification ICS-VCS-2)?

i

2. Is design accident flow verified through valve 21CS*V29 during quarterly valve testing? If not, how is this valve full-stroke exercised (refer to the comment in Item A.6 of this' report)?
3. How is it verified that valve 21CS*V38 is' full-stroke exercised during the quarterly valve testing? I
4. Provide a more detailed technical justification that explains why-it is not possible to perform the special air test to verify the forward flow capability of valves 2ICS*V39 and V40 either quarterly during power operations or during cold shutdowns (refer to Relief Request No. ICS-VRR-1).
5. Does valve 2ICS*PCV115 (P&ID PID-35C-5 coordinates D-4) have a reauired fail-safe position? If so, in addition to testing its fail-safe function, this valve must be exercised and have its full-stroke time measured in accordance with the Code.
6. Review the safety-related function of valve 21CS*FV108 (P&ID PID-35D-3 coordinates D-2) to determine if it should be included in the IST program.
7. Is credit taken in any of NMP-2 safety analyses for the reverse J flow closure of either valve 21CS*V27 or 2ICS*V249?
8. Are valves 21CS*MOV150 and HYV151 skid mounted components? Does quarterly testing of the RCIC turbine verify the operability of these valves?

i 6

9.

~

Valve 2!CS*V28 is addressed in both ICS-VRR-2 and'ICS-VCS-4. There is no indication that this valve will.ever be full-stroke exercised as required by the Code. What alternate. testing methods have'been considered to verify the full-stroke capability of this valve?

K. Main Steam System

1. If valves 2 MSS *S0V97A, S0V978, S0V97C, and 50V97D have fail-safe actuators, they should be fail-safe tested in accordance with the Code requirements. .
2. Provide a more detailed technical justification that explains why repeatable test conditions cannot be established when testing the ADS valves during reactor refueling outages to allow measurement of-meaningful valve stroke times in order to provide a means to detect valve degradation (refer to Relief Request No. MSS-VRR-1).
3. Are the ADS and main steam safety relief discharge'line. vacuum '

breakers actually relief valves as shown on the P& ids 'or are they simple check valves? If they are check valves, they should be exercised as Category C valves in accordance with the requirements of IWV-3520. ,

l L. Reactor Coolant System

1. Deleted M. Control Rod Drive Hydraulic System
1. Provide a discussion that_ explains how it was determined that "the technical specification for control rod scram insertion time testing meets the intent of Section XI testing requirements" (refer to Relief Request No. RDS-VRR-1).

1 a j

{.  !

7 i

~.

c- .rv. .

~ . .

. . . . x w 2.- ' What is the frequency for scram testing the control rods at Nine-Mile Point, Unit 2 (how many rods are tested at what interval)?

3. Provide a more detailed technical justification for not exercising the 2RDS*ll5 valves during cold shutdowns (refer to Relief Request. j No. RDS-VRR-2).
4. Provide a more detailed discussion about the alternate testing being performed to verify.the reverse flow closure of the 2RDS*138 a, valves (refer to Relief Request No. RDS-VRR-3).

~

Ni Residual Heat Removal System

1. Provide a more detailed technical justification that explains why valves 2RHS*A0V16A, A0V16B, and A0V16C cannot be exercised utilizing system flow quarterly during power operations (refer to cold shutdown test justification RHS-VCS-1).
2. Provide a more detailed technical justification that explains why valves 2RHS*A0V39A and A0V39B can1ot be exercised utilizing system flow quarterly during power operations (refer to cold shutdown test justi fication- RHS-VCS-1) .

i

3. Deleted
4. Deleted i
5. How is it verified that valves 2RHS*V7, V8, and V9 are full-stroke .

exercised during quarterly testing?

l

6. What percent of a full-stroke is-possible using the air operator I when exercising testable check valve 2RHS*A0V150?
7. Is valve 2RHS*MOV26A Appendix J, Type C, leak rate tested to verify its leak tight capability?

i a

8

.( ..

s

.-c

8. Review the safety-related function of valves 2RHS*V19, V.20, V117, and V118 (P&ID PID-310-4 coordinates B-2 and P&ID PID-31E-5 coordinates J-2 respectively) to determine if they should be included in the IST progr'ma and tested in accordance with the Code.
9. Review the safety-related function of valves 2RHS*LV17A and LV178 (P& ids PID-31D-1 and 31E-1 coordinates G-5"and D-6 respectively) to determine if they should be included in the IST program.
10. Are 2RHS*RVV35A, RVV358, RVV36A, and RVV368 relief valves or simple check valves? If they are check valves, they should be exercised as Category C valves in accordance with the requirements of IWV-3520.

, 11. Deleted l

12. If valves 2RHS*V47, V48, V60, and V61 perform a safety-related function in the closed position as identified in the IST program valve table, then their reverse flow closure should be individually verified.
13. Deleted
14. Do valves 2RHS*V17 and V18 perform a safety-related function in the closed position? If so, reverse flow closure should be verified for ng.h of these check valves in accordance with the Code requirements.
15. Deleted
16. Deleted
17. Does valve 2RHS*V3 perform a safety-related function in the closed position? If so, reverse flow closure should be verified in accordance with the Code requirements.

9 U.

18. Is credit taken'in any Nine Mile Point,' Unit 2, accident analyses l for the operation of the steam condensing mode of the residual heat removal system? If so, valves 2RHS*V13 and V14 (P&ID PID-31D-4 coordinates H-5 and H-2'respectively) should be' included in the IST program and tested in accordance with the Code.

O. Fuel' Pool Coolina and Clean Uo System

1. How are'the following valves full-stroke exercised quarterly?

2SFC*V300A 2SFC*V301A 2SFC*V302 2SFC*V300B 2SFC*V3018 2SFC*V303

2. Review the safety-related function of valves 2SFC*HV35A, .HV35B, HV54A, and HV54B (P& ids PID-38A-1 and 38B-1) to determine if they should be. included in the IST program. Do these valves have

, reauired fail-safe positions?

3. What safety-related systems provide cooling to the spent fuel pool? Are all of the safety-related pumps and-valves in' these systems included in the IST program and tested to the Code requirements?

P. Standby Liauid Control System

1. Provide a more detailed 'echnical justification for not verifying forward flow operability of valves 2SLS*MOV5A, MOV58, and V10 during cold shutdowns (refer to Relief Request No. SLS-VRR-1).
2. Provide a more detailed technical justification for not verifying reverse flow closure of valves 2SLS*V12 and V14 during cold shutdowns (refer to Relief Request No. SLS-VRR-2). How is forward  !

flow operability of these valves verified during testing?  :

3. Review the safety-related function of valve 2SLS*HCV116 (P&ID  !

PID-36A-6 coordinates I-3) to determine if it should be included in I the IST program and tested to the Code requirements. )

i 10

- _ _ _ _ _ _ - _ _ - . l

]

Q. Service Water System

)

1. Review the safety-related function of the following valves to determine if they should be included in the IST program and tested to the Code requirements. .

2SWP*MOV93A 2SWP*FV47A 2SWP*V1028 2SWP*M0V938- 2SWP*FV54A -

2. Provide a more detailed technical justification for not exercising ,

valves 25WP*V202A, V1024, V1025, and V1027 during cold shutdowns (refer to Relief Request No. SUP-VRR-2). ,,

3. Review the safety-related function of valves 2SWP*MOVIA, M0VlB, MOVIC, MOVID, MOVIE, and MOVlF (P& ids PID-11A-7 and 11B-5) to #

determine if they should be included in the IST program and tested to the Code requirements.

4. Deleted
5. Deleted
6. The Nine Mile Point, Unit 2 IST program valve table does not indicate that remote valve po'sition indication verification is performed for valves 2SWP*A0V78A and A0V78B. Are these valves equipped with remote valve position indication? If so, this indication should be verified in accordance with the Code requirements.
7. Where " periodic testing" is identified in the remarks section for service water system valves, if t,his testing frequency is less than quarterly then a cold shutdown justification or relief request must be provided for the increased interval.
8. Provide a more detailed technical justification for not exercising valves 2SWP*MOV77A and M0V778 during cold shutdowns (refer to Relief Request No. SWP-VRR-1).

I1 w ___- _ ___ _____ _ __ _ _ . _ _ _ _ . -- _. . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ .

p.

3 --

, G)

<f 4, <

! s i

1

,. p 9.' Deleted I s

,. v ,!

g. , ,

i '

L. r. 1 '/ > ! ;y i' .

' i' i

[/ 10. The valve listing table lndicates that valve,s 2Sily*Va9A and V219B $ '

q-perform a safety-relata' function in the closed position, '

therefore, the reverre*p/ low closure of these valves should be i

/ ,,

s  ;- t /,

verip',e'Lduring quar.terly testing?

i ,

c "p ,

,j .

u v .~. } V, (? } '

11. Do valves 2$WP*ht35A and TV35B (P&ID PID-11J-6, coordinates G-6 and '

,& [ g' B-61 hvef.nd;yind fail-safe positions? Ifso,Iheyshouiabe f pincludedin,theISTprdgramandtestedinaccordancewiththeCody,  ;

regJiremerkk '

(

/ /

12. N! b is the reverse f\ow closudjdi wlves 2SWP"V75A and VISBk,h ,

ve'rified during. quarterly testing? [

,\

j i j ]

13.

Provideamoredetailedtechnic41 jus;,tiNeationfornotexercising <

' s N* valves 2SWP*MOV50A and M0V508 quarterly during power operations. /

1 N*

~ ;f. . y,; 1~

14. y Neser verifying the full-stroke capability of valves 2SWP*V1002A andV10028isnotana;ceptah'J7oroposal. What other alternate ' ', (

testing methods and frequencies have been coasidered for verifying ,

the full-stroke capability of these valves (refer to Valve Relief , ,

Request SW'.P-VRR-3)l' l } .

1 4(t ,/ 7 i , j f. \it!\ Rector Water Cleant/cSystem  !

( 4

[ ,

s ,

1. Provids M cor'e"detaiMA. .tachnical jy tificat/tn for rot exercising

. 4 s

s

' fl. a valve 2WCS*MOVll2 and M0 00 quarter 1h in accordance with.the Code  ;

requirements (refertocoldshutdowatestjustificationpCS-VCF-1). j v i

2. Review the safety-related function of valves 2WCS*MOV128 and M0)129

~ g,1 (P&ID PID-67A-6, coordinates E-9) to determine if they'should be 1 included in the IST program and tested to the Code requirements.

t

'? \ 12

_ s

_ _ - - - - - - - - - - - - 'll9

-4 L k

1

  • s '
v. s'lN '
i. . .' . .

(:

it

1) S. Reactor Vessel instrumentation W ,,
c. t
1. How are valves 2ISC*RV33A, RV33B, RV34A, RV348, RV35A, RV358, v RV36A, and RV36B verified to full-stroke exercise quarterly? Ars hj. these valves simple check valves?

T. Hydrocen Recombiner System a

1. Provide a more detailed technical justification for not exercising
//; 2HCS*MOV26A and MOV26B quarterly (refer to valve relief request j 2HCS*VRR-1.)

s b

)['

i

)

'/ ' <

. /,

,]'

/

T t'

I r6 l'

?. {

, a i

I-Y

, 13 e . ';t 1 1

~ \

l l I ,

' ^

f,[ ,

~

[.((I pg g!!(c

.. a. v; y . fg >

f w

F 2. PUMP TESTING PROGRAM hy .

g I.. Deleted

)

+

2. Deleted 9 .,..

r iN e., 3. What is the technical basis for the allowable vibration velocity

'4 4,3 '

ranges identified in General Pump Relief, Request No. GPRR-17 Are

.' 'the indicated ranges based on peak vibration readings' or on RMS.

' values? ,

, 4 s

E 4r Tite' Nine Mile Point Nuclear Station, Unit 2. pump inservice testing

$J program does not address the observation of pump; lubricant level or-

%  %. pressure. Describe how this IST test quantity is observed as M; - required'by Section XI, IWP-3100.

g./.

5. ' General re' lief 'cannot b'e granted from the pump 6 earing temperature measurement requirements for all safety-related pumps in:the IST e ~ program (refer to Relief Request No. GPRR-3). afor. pumps With Linstalled temperature sensors, .the annual measurement of' bearing-l temperatures shbuld be performed since'it is not excessively

[ burdensome to measure this parameter as re. quired by the Code. '

6. Relief Request No. EGF-PRR-l' for the diesel . fuel oil transfer pumps' indicates that flow rpte is determined by measuring day tank level '

versus time during hump quarterly testing. The system P&ID shows a

^

flow instrument in the normal flow path to the day tank, why isn't 1,

this instrument used to perform this testing? If the change in day i

s tank level versus time method is utilized, does it meet the accuracy requirements of IWP-4110?
7. Review the safety-related function of the ICS system pressure pump i.' 2ICS*P2 (P&ID PID-350-3, coordinates G-5) to determine if it should beincludedintheISTprogramandtettedtotheCoderequirements.

^'

f' : ,\,.

f.

'A l ', , s.

L b9 .

g d fl s

4

__.___.__'___..m _ _ _ _

y ,

8. Lack of adequate instrumentation is not an acceptable justification for not measuring standby liquid control pump flow rates to the Code required accuracies during pump quarterly testing (refer to Relief Request No. SLS-PRR-1). Can new instrumentation be obtained or the existing instrumentation be calibrated differently such that the measured pump flow rates meet the requirements of IWP-4110?
9. Deleted
10. Deleted
11. Deleted
12. The proposed testing, for condenser water pumps 2SWP*P2A and P28, does not provide sufficient information to utilize to determine pump hydraulic condition and detect hydraulic degradation (refer to Relief Request No. SWP-PRR-1). What other alternative testing methods have been considered for determination of the hydraulic condition of these pumps? What is the safety-related function of these pumps?
13. The Code specifically allows expanded ranges for pump test parameters when the Code specified ranges cannot be met. Where the  !

licensee cannot meet the Code specified ranges for specific pumps  ;

in the IST program less restrictive limits may be used. However, a general relaxation from the Code requirements for all pumps in the j NMP-2 IST program cannot be granted. (Refer to General Pump Relief Request No. GPRR-2.)

f l

I i

i 15 l

l  !

Retrieved from "https://kanterella.com/w/index.php?title=ML20236T650&oldid=3172858"