ML20237B479

Trip Rept of 871117 & 18 Visit to Plant Site Near Russellville,Ar Re Pump & Valve Inservice Testing Program. Program Changes Indicated in Response to Questions

ML20237B479
Person / Time
Site:	Arkansas Nuclear
Issue date:	12/02/1987
From:	Hartley R, Ransom C EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	Masciantonio A NRC
Shared Package
ML20237B468	List: ML20237B467 ML20237B479
References
NUDOCS 8712160289
Download: ML20237B479 (37)

Text

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• ENCLOSURE 2

- EG&G Idaho, Inc.

( *., FORM EG&G-460 NOTEGRAM

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(Rev. 05-84) l I

Date December 2, 1987 Y

R. S. Hartley/C. B. RansomOCA-To Armando Masciantonio From Org. NRC/EMEB Org. Mechanical Systems Evaluations Address Bethesda, MD Address INEL-Idaho Falls, ID TRIP REPORT FOR THE PUMP AND VALVE INSERVICE TESTING PROGRAM WORKING MEETING FOR ARKANSAS NUCLEAR ONE, UNIT 1 On November 17 and 18, 1987, a working meeting was held at the Arkansas l Nuclear One Plant site near Russellville, Arkansas with Arkansas Power and Light Company, NRC, and EG&G Idaho, Inc., representatives to discuss the questions resulting from the review of the Arkansas Nuclear One, Unit 1 pump and valve inservice testing (IST) program.

i Attached is a list of meeting attendees, the questions that served as an agenda for the meeting, and the responses to those questions as taken from the meeting minutes. The utility representatives were given a brief introduction outlining the agenda and the methods used for the documentation of questions and responses. This was followed by detailed discussions concerning specific pumps and valves in the Arkansas Nuclear One, Unit 1, IST program. q j

These discussions resulted in 13 OPEN ITEMS for the licensee and 6 OPEN ITEMS for the NRC which are identified in this sip report. There are several additional items where the licensee has agreed to make corrections or changes to their IST program as indicated in the responses to the questions.

The Arkansas Nuclear One, Unit 1 IST program submitted to the NRC dated February 20, 1985, which was reviewed for the generation of these questions, has undergone significant revision as indicated by the licensee a during our discussions. These revisions have not been submitted to the NRC for review and approval. Some of these IST program changes are indicated in the responses to our questions. {

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Attachment:

g712160289 871209 i As Stated ADOCK 0500 3 gDR l cc: G. Dick NRC/ANO-1 Project Manager l C. F. Obenchain H. C. Rockhold @C, E. J. Sullivan NRC/EMEB  ;

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'4 ARKANSAS NUCLEAR ONE, UNIT 1 IST PROGRAM WORKING MEETING NOVEMBER 17, 18, 1987 NAME REPRESENTING R. Scott Hartley INEL/EG&G Idaho-Clair Ransom INEL/EG&G Idaho N. Bradley Stockton INEL/EG&G Idaho Sandy McGregor AP&L Charles Zimmerman AP&L Alan Cox AP&L David Crabtree AP&L, Engr. Services Rick Lane AP&L Robert McWilliams AP&L, Engr.' Services George Woerner AP&L, Nuc. Engr. & Lic.

Don Lomax AP&L, Plant Licensing Armando Masciantonio NRC/NRR/EMEB Bill Johnson NRC/ SRI i

George Dick NRC/NRR/PD4 I l

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o w-ARKANSAS NUCLEAR ONE, UNZT 1 PUMP AND VALVE INSERVICE TESTING PROGRAM

. QUESTIONS AND COMENTS l

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1. VALVE TESTING PROGRAM A. General Questions and Comments i 1. The Arkansas Nuclear One, Unit 1, IST program valve listing table does:not identify the testing being performed or the testing j frequency for each individual valve. Therefore, it was assumed that unless indicated otherwise in a comment or a relief request, that the Code required tests are being performed at the Code specified frequencies. The.NRC staff's position is that this l

information should be provided in the IST program submittals for

! our review.

Response

Typical IST program content was discussed with the licensee and also the need for additional details in their IST program resubmittal. .The licensee should evaluate the inclusion of additional information in their program. The licensee has stated that Arkansas Nuclear One, Unit 1, IST

{ program tests valves at the Code specified frequency unless indicated otherwise in a comment (cold shutdown justification) or a relief request.

2. Provide a list of valves that are Appendix J, Type C, leak rate tested that are not included in the Arkansas Nuclear One, Unit 1, IST program and categorized "A" or "AC"?

Response

All. valves that are Appendix J, Type C, leak rate tested will be included in the IST program and categorized A or A/C. Valves SF-42, SF-43, SF-44, SA-45, and IA-52 are not I

currently listed in the IST program tablos but will be

- included in the IST program resubmittal. Any changes in the licensee's Appendix J program will be reflected in changes to their IST program.

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3. 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 l- 3425 for containment isolation valves presents no safety problem l since the. intent of IWV-3421 through 3425 is met by Appendix J requirements, however, the licensee shall comply with Paragraphs l

IWV-3426 and 3427.

Response:  ;

The licensee has stated that the Arkansas Nuclear One, Unit 1, IST program complies with Paragraphs IW-3426 and 3427 of the ASME Section XI Code.

4. The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them dur'ng 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 curing 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 co'd shutdowns. Cold shutdown testing of valves identified by the licensee is l l

acceptable when the following conditions are met:

a. The licensee is to commence testing as seen 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 comple e or the plant is ready to return to power.

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

Any testing not completed during one cold shutdown should be c.

l performed during any subse'quent cold shutdowns starting from 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 accomplished, 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.

1 If the Arkansas Nuclear One, Unit 1, IST program does not conform to this staff position for valves tested on a cold shutdown frequency, provide the justification for any deviations.

Response

The licensee will comply with this position or test all valves identified for testing during cold shutdowns each cold shutdown (not to exceed once per quarter).

5. Provide the limiting values of full-stroke times for the power operated valves in the Arkansas Nuclear One, Unit 1, IST program for our review. What are the bases used to assign the limiting values of full-stroke time for these valves?

Response

The ANO-1 IST program valve stroke time limits are based on reference valve stroke times multiplied by 1.25. Upon exceeding this limit the valve testing frequency is j increased as required by the Code and the valve is flagged for maintenance. Upon exceeding the specified value, this valve is declared inoperable and corrective action is taken in accordance with the Code.

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When flow through a check valve is us::d to indicato a full-stroke 6.

- exercise of the valve disk, the NRC staff position is that verification of the maximum flow rt.te identified in any of the f

! 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. If there are any check valves in the Arkansas Nuclear One, Unit 1, IST program whose full-stroke testing does not conform to this staff position, provide a discussion on how their full-stroke capability is verified.

Response

This topic was discussed with the licensee. It remains an OpEN ITEM for the licensee to further evaluate some method for verifying the full-stroke capability of valves'CS-293 and 294, the emergency feedwater (EFW) suction from the condensate storage tank (CST). Other valves affected by this position will be specifically addressed in other questions and responses, j

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, e damaging equipment, or resulting in a plant shutdown.

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Response

1 This topic was discussed and the licensee will provide this information in future relief requests and cold shutdown justifications.

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8. Are any valves at Arkansas Nuclear One, Unit 1, currently leak rate tested to verify a pressure boundary isolation function? If so, provide a listing of those valves and identify the testing that is being performed.

Response

Valves SH-13A, B, 14A, B, 17, and 18 are identified in ANO-1 Technical Specifications as Event V valves. These valves are tested by monitoring pressure downstream of the pressure interface. The NRC staff's position is that these valves should be individually leak rate tested in accordance with IWV-3420. Where these valves are tested in groups the acceptance criteria will be based on the maximum leakage through the most limiting component and a request for relief will be provided.

9. The NRC staff position is that valves 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. Identify the val' ves, if any, at Arkansas Nuclear One, Unit 1, that serve both a pressure boundary isolation function and a containment isolation function. What leak rate testing is performed on these valves?

Response

The licensee stated that there are no valves at ANO-1 that perform both a containment isolation and a pressure boundary isolation function.

10. Identify any cases where the remote position indicators are not being verified in accordance with the requirements of Section\XI, I IWV-3300 for applicable valves in the Arkansas Nuclear One, Unit 1, IST program?

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Response

This remains an OpEN ITEM for the licensee to review further.

11. The NRC staff's position is that the emergency diesel generators perform a safety-related function and that the appropriate valves l

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

The Licensee stated that the appropriate pumps and valves in the emergency diesel generator air start, cooling water, and fuel oil transfer systems will be included in the IST program and tested in accordance with the Code requirements. Requests for relief will be provided where this testing cannot be performed as required by the Code.

12. Identify any valves with fail-safe actuators in the Arkansas v.

Nuclear One, Unit 1, IST program that are not tested in accordance with the requirements of Section XI, IWV-3415?

Response

The licensee stated that Arkansas Nuclear One, Unit 1, tests valves with fail-safe actuators in accordance with the Code requirements.

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B. Reactor Coolant System

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1. Valve relief request #2 does not provide the technical justification for not exercising valves CF-1A and 1B quarterly during power operations; what is this justification? Provide a more detailed technical justification for not exercising these valves during cold shutdowns. What alternate testing methods have been considered to verify the full-stroke capability of these valves?

Response

Full-stroke exercising of valves CF-1A and IB quarterly is impractical due to the pressure differential between the accumulator and the reactor coolant system. Full-stroke exercising these valves during cold shutdown could result in low temperature over-pressurization of the reactor coolant system. Disassembly and inspection to verify the ,

full-stroke capability of these valves requires the removal of all fuel from the reactor core per ANO-1 Technical Specifications. This remains an OPEN ITEM for the licensee to further evaluate some method of verifying the full-stroke i

capability of these valves. Relief request #2 will be i revised.

2. Is design accident flow verified through valves DH-14A and 14B when they are tested? If not, how are these valves full-stroke exercised (refer to the comment in A.6 above)?

Response

l Valves DH-14A and 148 receive a significant partial-stroke exercise of approximately 3000 GPM during cold shutdowns.

This remains an OPEN ITEM for the licensee to further evaluate some method of verifying the full-stroke capability of these valves. A relief request will be provided.

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3. Are valves DH-13A, 130, 17, and 18 full-stroke exercis;d 1

i quarterly during power bperations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4. l 1

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Response

No. Flow cannot be established through these valves to  ;

verify their full-stroke capability quarterly during power operations due to the large pressure ' differential across these valves. A cold shutdown justification will be provided. >

4. Are valves MU-34A, 348, 34C, and 340 full-stroke exercised quarterly during power operations? If not, provide the justification for not performing this testing auarterly as discussed in Item A.4.

Response

No. These valves cannot be full-stroke exercised quarterly during power operation since the flow necessary to verify the full-stroke capability could result in thermal shock'to the injection nozzles and cause pressurizer level transients which could lead to reactor trip. Full-stroke exercising these valves during cold shutdown is undesirable since this could result in a low temperature over-pressurization of the reactor coolant system. This remains an OPEN ITEM for the licensee to further evaluate some method of verification of l full-stroke capability for these valves.

5. Are valves SV-1077 and 1079 full-stroke exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

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j Response:

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! No. A cold shutdown justification will be provided to address the consequences of exercising these pressurizer vent valves quarterly during power operations (citing possible valve seat damage due to operation).

6. The NRC has adopted the position that the pressurizer pilot operated relief valves should be included in the IST program as Category B valves and be tested to the requirements of Section XI. However, since the PORVs have shown a high probability of sticking open and are not needed for overpressure protection during power operation, the NRC has concluded that quarterly exercising during power operation should not be performed.

The PORVs function during reactor startup and shutdown is to protect the reactor vessel and coolant system from low-temperature overpressurization conditions, therefore, they should be exercised prior to initiation of system conditions for which vessel protection is needed.

The recommended test schedule is to full-stroke exercise, measure the full-stroke time, and observe the fail-safe actuation of the pilot operated relief valves at each cold shutdown and refueling outages, not to exceed once every three months. The PORV block valves should be included in the IST program and tested quarterly I

to provide protection against a small break LOCA should a PORV l fail open.

Response

The PORVs are exercised during cold shutdowns as Category B valves. The block valves are exercised quarterly in j i

accordance with the Code requirements. This testing )

i frequency is acceptable.

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ADDITIONAL DISCUSSION Rapid acting power operated valves (valves that normally stroke in 2 seconds or less) were discussed with the licensee. The licensee may choose to assign a maximum limiting stroke time to valves whose normal stroke times are

! two seconds or less and obtain relief from the trending l

requirements of IWV-3417(a) provided that upon exceeding the maximum limiting stroke time of 2 seconds corrective action must be taken in accordance with IWV-3417(b). A general relief request may be provided for the ANO-1 rapid acting power operated valves.

7. Review the safety-related function of valves OH-12 and 16 (P&ID M-230 coo'rdinates G-5) to determine if they should be included in the IST program.

Response

This remains an OPEN ITEM for the NRC to determine if Branch Technical Position RSB 5-1 requires ~ that valves OH-12 and 16 be utilized to reach safety grade cold shutdown for ANO-1.

If so, these valves should be included in the IST program and tested in accor(ince with the Code requirements.

8. If valve CS-26 (P&ID M-230 coordinates H-3) is required to be Appendix J 1eak rate tested to verify a containment isolation function, it should be included in the IST program and be categorized A/C.

Response

This valve is not required to be Appendix J 1eak rate tested and need not be included in the IST program.

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9. Provide the P&ID that shows the RCS loop TH vent valves for our review. Identify the testing that is performed on these valves.

Response

l The P&ID was provided. Valves SV-1081, 1082, 1083, and 1084 and 1091, 1092, 1093, and 1094 are the RCS loop TH vent valves and are in the IST program as Category B valves. l These valves will be tested during cold shutdowns and a cold shutdown justification will be provided discussing the technical concerns for not exercising these valves quarterly.

10. How are the reactor vessel internal vent valves full-stroke exercised quarterly during power operations?

Response

_ The reactor _ vessel internal vent valves are located in the reactor vessel an'd cannot be exercised quarterly during power operations or during cold shutdowns. These valves are exercised during refueling outages utilizing a spring gauge to measure their resistance. A relief request will be provided in the IST program resubmittal.

11. Review the safety-related function of the reactor vessel head vent valves to determine if they should be included in the IST program.

Response

Reactor vessel head vent valves SV-1071, 1072, 1073, and 1074 have been added to the IST program as Category B valves and a cold shutdown justification will be provided.

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12. Provide the P&ID that shows valves CV-1814, 1816, and 1845 for Identify the testing that is performed on these our review.

valves.

Response

The P&ID was provided. Valves CV-1814 and 1816 have been

! included in the IST program as Category B valves. Valve CV-1845 is included in the IST program as Category A. These valves are exercised quarterly in accordance with the Code.

C. Steam Generator Secondary System

1. Provide the P&ID that shows the turbine driven auxiliary feedwater pump turbine for our review.

Response

The p&ID was provided.

ADDITIONAL COMMENT:

Emergency feedwater turbine steam supply check valves MS-271 and 272 are included in the IST program. These valves are full-stroke exercised open during quarterly pump testing (at full-flow). A relief request will be provided to verify reverse flow closure capability during refueling outages by valve disassembly and inspection.

2. Identify the testing that is performed on valves CV-2691 and 2692 (MSIVs) quarterly during power operations. If these valves are only partial-stroke exercised quarterly, provide the justification for not performing a full-stroke exercise.

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Response: l Valves CV-2691 and 2692 receive a partial-stroke exercise of l

approximately 10% quarterly during power operation. Closure 1 of one of these valves during power operations would cause a loss of feedwater flow to an operating steam generator and  ;

could result in a plant trip. A cold shutdown justification will be provided for testing these valves on a cold shutdawn frequency. l

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3. Review the safety-related function of valves CV-2618 and 2668 (P&ID M-206 coordinates H-1 and H-7) to determine if they should l be included in the IST program. (

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Response

This remains an OpEN ITEM for NRC to determine if Branch Technical Position RSB 5-1 requires the irclusion of valves CV-2618 and 2668 for safety-grade cold shutdown for ANO-1.

If so, these valves should be included in the IST program and tested in accordance with the Code requirements.

4. How are valves FW-7A and 78 verified in the closed position (their safety-related position) quarterly during power operations? .

Response

Exercising either valve FW-7A or 7B quarterly during power operations would disrupt flow to an operating steam generator and cause the loss of the heat sink to an RCS Loop, which would cause high RCS temperature and/or pressure and possibly cause a plant trip. This information will be presented in the form of a cold shutdown justification.

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5. Identify the testing that is performed on valves CV-2630 and 2680

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(the main feedwater isolation valves) quarterly during powcr operations. If these valves are only partial-stroke exercised quarterly, provide the justification for not performing a full-stroke exercise.

Response

These valves receive a partial-stroke exercise (approximately 5%) quarterly during power operation. A cold shutdown justification will be provided for full-stroke exercising these valves on a cold shutdown frequency.

D. Makeup and Purification System

1. Are valves CV-1214, 1216, and 1221 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

Yes. These valves are full-stroke exercised quarterly during power operations. ,

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2. Are valves CV-1219, 1220, 1227, and 1228 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4

Response

I Yes. These valves are full-stroke exercised quarterly during power operations.

3. Is valve CV-1234 exercised quarterly during cower operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

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Response

Yes. This valve is full-stroke exercised quarterly during power operations.

4. Provide the P&ID that shows the RCP seal bleed off valves (CV-1270, 1271, 1272, and 1273) for our review.

Response

P&ID M231 sheet 2 was provided. No further questions.

5. Are valves CV-1270, 1271, 1272,'1273, and 1274 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

No. Failure of any one of these valves in the closed position during quarterly testing could result in damage to the reactor coolant pump seals. Cycling these valves during power operations would impose transient conditions on the reactor coolant pump seals which could result in seal damage. These valves will be exercised at cold shutdown and a cold shutdown justification will be provided with this information.

6. Are valves CV-1300 and 1301 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

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No. Closing eith'er of these valves during normal operations could damage the operating makeup pump by isolating the mini-flow line. These valves will be exercised at cold shutdowns and a cold shutdown justification will be provided addressing this concern.

7. Are valves MU-19A,19B, and 19C full-stroke exercised quarterly during power operations or during cold shutdowns? If not, provide a relief request for these valves.

Response

These valves are not full-stroke exercised quarterly or during cold shutdowns. This remains an OPEN ITEM for the licensee to further evaluate a method to verify the full-stroke capability of these valves.

8. Are valves MU-1211, 1212, 1213, 1214, and 1215 full-stroke exercised quarterly during power operations or during cold

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shutdowns? If not, provide a relief request for these valves.

Response

These valves are not full-stroke exercised quarterly or l during cold shutdowns. This remains an OPEN ITEM for the licensee to further evaluate a method to verify the full-stroke capability of these valves.

9. Are valves BW-2 and 3 full-stroke exercised quarterly during power operations or during cold shutdowns? If not, provide a relief request for these valves.

Response

No. This remains an OPEN ITEM for the licensee to further evaluate a method to verify the full-stroke capability of these valves.

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10. Review the safety-related function of valve MU-13 (P&ID M-231 coordinates B-3) to determine if it should be included in the IST program.-

Response

This valve will be included in the IST program resubmittal to be tested during cold shutdowns and a cold shutdown justification will be provided. Exercising this valve during operation could cause an inadvertent boration of the RCS.

11. Review the safety-related function of valves MU-22A, 22B, and 220 (the primary makeup pump minimum flow recirculation line check i valves) to determine if they should be included in the IST program.

Response

The NRC staff's position is that these valves perform a safety-related function (make-up pump minimum flow) and should be included in the IST program and tested to the Code requirements. This remains an OPEN ITEM for the licensee to further evaluate testing these valves.

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12. What are the emergency boration flow paths for which credit is taken in the various operating modes at Arkansas Nuclear One, Unit 17 Identify any active pumps and valves in these flow paths l which are not included in the IST program and being tested in accordance with the Code.

Response

This remains an OPEN ITEM for the licensee to evaluate further, 17

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13. What' valves, if any, at containment penetration P-16 are leak

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• rate tested to verify their ability to perform a containment isolation function?

Response

The licensee stated that there are no. valves at this penetration which are required to be leak rate tested.

E. Decay Heat Removal System

1. Are valves CV-1400 and 1401 exercised quarterly during power operations? If not, provide the justification for. not performing this testing quarterly as discussed in Item A.4.

Response

Yes. Valves CV-1400 and 1401 are full-stroke exercised quarterly in accordance with the Code requirements.

2. Are valves CV-1405 and 1406 exercised quarterly during power operations? If not, provide the-justification for not performing this testing quarterly as discussed in Item A.4.

Response

Yes. Valves CV-1405 and 1406 are exercised quarterly in accordance with the Code requirements.

3. . Are valves CV-1407 and 1408 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

Yes. Valves CV-1407 and 1408 are exercised quarterly in accordance with the Code requirements.

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4. Are valves DH-2A and 2B full-stroke exercised quarterly during power operations? If not, provide a justification for not performing this testing quarterly as discussed in Item A.4.

Response

Yes. Valves DH-2A and 2B are full-stroke exercised quarterly in accordance with the Code requirements S. Are valves BW-4A and 4B full-stroke exercised quarterls during power operations? If not, provide a justification for not performing this testing quarterly as discussed in Item A.4.

Response

No. However, these valves receive a significant partial-stroke of approximately 60 percent design flow quarterly during power operation. This remains an OPEN ITEM i for the licensee to further evaluate a rethod to verify the 1

! full-stroke capability of these valves.

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6. Are valves CV-1050,1404, and 1410 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

l Valve CV-1404 is exercised quarterly in accordance with the Code requirements. Valves CV-1050 and 1410 are tested at j cold shutdowns since these valves are interlocked with RCS pressure and cannot be operated with RCS pressures greater than approximately 400 psi. A cold shutdown justification will be provided to address these conce ns.

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7. Are valves CV-1414 and 1415 exercised quarterly during power operations? If not, provide the justification for not performing

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this testing quarterly as discussed in Item A.4.

Response

Yes. Valves CV-1414 and 1415 are exercised quarterly in accordance with the Code requirements.

8. Do valves CV-1428,1429,1432, or 1433 have required fail-safe positions? If so, they should be exercised in the IST program.

Response

No. These valves do not have a required fail-safe position and need not be included in the IST program.

9. Review the safety-related function of valves CA-61 and 62 (P&ID M-232 Coordinates D-2) to determine if they should be included in the IST program.

Response

4 Valves CA-61 and 62 are in the IST program and receive a partial-stroke exercise quarterly. To full-stroke exercise these valves would require introducing sodium hydroxide into the low pressure injection (LPI) suction piping. This remains an OPEN ITEM for the licensee to further evaluate a method of verifying the full-stroke capability of these valves. .

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10. Review the safety-related function of valve PSV-1412 (PSID M-232 coordinates H-2) to determine if it should be included in the IST program.

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Response

This remains an OPEN ITEM for the licensee to further evaluate the function of valve PSU-1412 to determine if it needs to be added t'o the ANO-1 IST program and tested to the Code requirements.

11. Review the safety-related function of valve SF-21 (P&ID M-232 coordinates B-6) to deter:nine if it should be included in the IST program.

Response

This valve does not perform a safety-related function and need not be included in the IST program.

12. If valves SV-1440 and 1443 (p&ID M-232 coordinates C-6 and A-6) are required to be Appendix J 1eak rate tested to verify their ability to perform a containment isolation function, they should

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be included in the IST program as category A valves.

Response

These valves are not required to be Appendix J 1eak rate i tested and need not be included in the IST program.

F. Reactor Building Spray System i

1. Are valves CV-2400 and 2401 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

Valves CV-2400 and 2401 are exercised quarterly in accordance with the Code.

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[ 2. 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 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 d % ssembly 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.

How does the Arkansas Nuclear One, Unit 1, sample disassembly and inspection program for valves BS-4A and 4B differ from this staff ,

position?

Response

Arkansas Nuclear One, Unit 1, inspects these valves as recommended by the NRC staff. These valves are disassembled and manually full-stroked once every other refueling outage (i.e., one per refueling outage on an alternating basis).

3. Are valves BW-6A and 6B full-stroke exercised quarterly during power operations? If not, provide a justification for not performing this testing quarterly.

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Response.

Valves BW-6A and 6B are full-stroke exercised quarterly in accordance with the Code requirements.

4. Review the safety-related function of valves CA-90A and 90B, i CV-2410 and 2411, and PSV-2423 (P&ID M-236 Coordinates G-3) to determine ~if they should be included in the IST program. i

Response

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

G. Core Flooding System 1

I

1. Review the safety-related function of valves CV-2415, 2417, 2419, and 2420 (the core flood tank vent and isolation valves) to determine if they should be included in the IST program. Are

.these valves required to change position in order to place the plant on decay heat removal cooling?

Response

This remains an OPEN ITEM for the NRC to determine if Branch Technical Position RSB 5-1 requires the inclusion of valves CV-2415, 2417, 2419, and 2420 for safety-grade cold shutdown for ANO-1. If valves 2415 and 2419 (the core flood tank vent and isolation valves) are included in the IST program a cold shutdown justification will be provided.

2. If valves CV-2416, 2418, and the associated valve downstream (P&ID M-236 coordinates C-5 and B-6) are required to be Appendix J leak rate tested to verify their ability to perform a containment isolation function, they should be included in the i

IST program as category A valves.

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Response

i l These valves are not required to be Appendix J 1eak rate tested and need not be included in the IST program. The valve downstream (CF-2) is a Category E valve (locked closed).

3. If valves MU-35A, 35B, 36A, and 368, and N 2-3 and 5 (P&ID M-236 coordinates D-2 and D-6) are required to be Appendix J 1eak rate tested to verify their ability to perform a containment. isolation function, they should be included in the IST program as category A or A/C valves as applicable.

Response

These valves are not Appendix J 1eak rate tested and need i

not be included in the IST program. These are also Category E (locked closed) valves.

H. Emergency Feedwater System

1. Are valves FW-10A and 10B full-stroke exercised quarterly during power operations? If not, provide a justification for not performing this testing quarterly as discussed in Item A.4. j

Response

No. Valves FW-10A and 10B are exercised quarterly, however, no method exists to verify their full-stroke capability.

Flow instrumentation is scheduled to be installed during refueling outage 1R-8 (September 1988). A relief request may be provided for these valves until the flow instrumentation is installed.

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2. . Are valves CV-2620, 2626, 2627, and 2670 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

' Response:

Valves CV-2620, 2626, 2627, and 2670 are exercised quarterly in accordance with the Code requirements.

3. Identify how the Arkansas Nxlear One, Unit 1, sample disassembly and inspection program for valves SW-11 and 13 differs from the staff position explained in Item F.2?

Response

The licensee will perform sample disassembly and inspection for valves SW-11 and 13 as discussed in Item F-2 of this.

report.

4. Provide a more detailed technical justification for not full-stroke exercising valves FW-13A and 13B during cold shutdowns. What alternate testing methods have been considered to verify the full-stroke capability of these valves?

Response

This remains an OPEN ITEM for the licensee to further evaluate full-stroke exercising these valves. The licensee may consider verification of full-stroke capability of these valves by performing sample disassembly and inspection in accordance with the discussion in Item F-2 of this report.

5. Provide a more detailed technical justification for not individually verifying the full-stroke capability of valves p CS-98, 99, 261, and 262. What alternate testing methods have I been considered to verify the full-stroke capability of these valves?

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Response

c '.

With the addition of the new seismic condensate storage tank, valves CS-87, 99, 261, and 262 are no longer in the primary flow path for emergency feedwater and will be deleted from the IST program.

6. Are valves CV-2800 and 2802 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

Yes. Valves CV-2800 and 2802 are exercised quarterly during power operations.

7. Provide the P&ID that shows the following emergency feedwater system valves for our review. Identify the testing performed on these valves.

CV-2645 CV-2613 SV-2613 FW-56A i

CV-2646 CV-2663 SV-2663 FW-56B CV-2647 CV-2869 FW-55A FW-61 i CV-2648 CV-2870 FW-55B FW-62

Response

The P&ID was provided. With the exception of valves FW-61 and 62, these valves are exercised quarterly in accordance with the Code requirements. The licensee will reevaluate valves which are used for turbine prestart and do not perform a safety-related function. If it is determined that valves SV-2613 and 2663 do not perform a safety-related function, they may be deleted from the IST program.

Presently flowrate cannot be measured through valves FW-61 l

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and 62 for verification of valve full-stroke capability,

- however, flow measurement devices wi.ll be installed during refueling outage IR8 (September 1988). A relief request may be provided for these valves until this instrumentation is installed.

I. Service Water System

1. Are valves CV-3641, 3643, and 3645 exercised quarterly during power operations? If not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

No. Valves CV-3641, 3643, and 3645 are exercised during cold shutdowns. A cold shutdown justification will be provided for valve 3643. The licensee will reevaluate valves CV-3641 and 3645 to determine if they are passive Category B (perform no active safety-related function) and may delete these valves from their IST crogram. If it is determined that these valves perform an active safety-related function, the licensee will. include them in a cold shutdown justification.

2. Are valves SW-1A, IB, and 1C full-stroke exercised quarterly during power operations? If not, provide a justification for not performing this testing quarterly as discussed in Item A 4.

Response

Valves SW-1A, B, and C will be full-stroke exercised quarterly in accordance with the Code requirements. Reverse flow closure of these valves will be verified during cold I shutdowns and quarterly when system loads allow. A cold f shutdown justification will be providec.

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, 3. Is valve CV-3823 exercised quarterly during power operations? If

. not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

No. Valve CV-3823 is not exefcised quarterly. This remains an OpEN ITEM for the licensee to further evaluate exercising this valve quarterly. (Having both service water discharge valves open simultaneously could result in transferring the pond contents to the fiume due to the height difference between the two discharges.) The licensee may provide a cold shutdown justification citing these and other concerns.

i

4. Is valve CV-3824 exe*cised quarterly during power operations? If l not, provide the justification for not performing this testing quarterly as discussed in Item A.4.

Response

No. Valve CV-3824 is not exercised quarterly. This remains an OPEN ITEM for the licensee to further evaluate exercising this valve quarterly. (Having both discharge valves open simultaneously could result in transferring the pond contents to the fiume due to the height difference between the two discharges.) The licensee may provide a cold shutdown justification citing these and other concerns.

5. provide the P&ID that shows the following service water system valves for our review. Identify the testing performed on these valves.

CV-3730 CV-3732 CV-3734 CV-3736 CV-3731 CV-3733 CV-3735 l

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Response

These valves correspond to sluice gates SG-1 through.7 on P&ID M-209. These valves are exercised quarterly in

.accordance with the Code requirements. The P&ID was provided.

J. Intermediate Cooling System

1. If valve ICW-114 (P&ID M-234 coordinates C-4)'is required to be Appendix J leak rate tested to verify a containment isolation function, it should be included in the IST program and be categorized A/C.

Response

ICW-114 is not Appendix J 1eak rate tested and need not be included in the IST program.

2. How are valves CV-2214 and 2233 fail-safe tested? Explain whether this testing method verifies the reverse flow closure of the check valves in the air supply lines to the valve operator air accumulators?

Response

To verify reverse flow closure of valves CV-2214 and 2233 the air supply header is depressurized and air accumulator pressure is monitored for leakage.

3. Provide the P&ID that shows valves CV-2220, 2221, 2234,.and 2235 for our review. Identify the testing performed on these valves.

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Response

l The P&ID was provided. These valves provide intermediate cooling water to the reactor coolant pump seals and other components in containment. Closing these valves could result in equipment damage form loss of cooling and a cold shutdown justification will be provided for testing these valves at cold shutdown.

K. Spent Fuel Cooling System

1. What is the safety-related cooling system for the spent fuel storage pool? Identify any active in-line valves in this system

~

that are not included in the IST program and being tested in accordance with the Code?

Response

This remains an OPEN ITEM for the NRC to'look into the plant licensing basis to determine if the spent fuel cooling system needs to be included in the IST program. If the licensee is taking credit in their accident analyses for the service water hose connection supplying makeup to the spent fuel cooling system, then valve SW-72 on P&ID No. M-210 should be included in the IST program and exercised quarterly in accordance with the Code requirements.

2. If valves SF-42, 43, and 44 (P&ID M-235 coordinates E-6) are required to be Appendix J 1eak rate tested to verify a containment isolation function, they should be included in the IST program as Category A valves.

Response

l Valves SF-42, 43, and 44 are Category A-passive and are Appendix J leak rate tested and will be included in the IST I l program.

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4 L. Chilled Water System

1. Provide the P&ID that shows valves CV-6202, 6203, and 6205 for our review. Identify the testing performed on these valves.

Response

This P&ID was provided. Valves CV-6202, 6203, and 6205 will be exercised at cold shutdown. A cold shutdown justification will be provided to discuss the concerns for not exercising these valves quarterly.

2. Is the chilled water system utilized to meet the post accident control room habitability requirements? If so, all active system pumps and valves used for this function should be included in the IST program and be tested to the Code requirements unless specific relief is requested and granted.

Response

No. Service water is supplied to an integral cooler from Unit 2 for habitability.

M. Heating, Ventilation and Air Conditioning System

1. Provide the P& ids that show all of the HVAC valves in the IST program for our review. Identify the testing performed on these valves.

Response: i l

These valves are on P&ID 261, sheet I which was provided.

Valves CV-7401, 7402, 7403, and 7404 are required to be  !

keylocked closed during power operations by ANO-1 Technical l Specifications and a cold shutdown justification will be provided.

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.7 The remaining HVAC valves listed below are faill-stroke exercised quarterly:

CV-7443 CV-7444 CV-7445 'CV-7446 CV-7447 CV-7448 CV-7449 CV-7450 CV-7453 CV-7470 CV-7471 CV-7472 CV-7473 CV-7454 CV-7456 CV-7510 CV-7512 N. Miscellaneous Systems

1. Provide-the P& ids that show the following valvesf'or our review.

' Identify the testing performed on these valves.

l System Valve f

l Chemical Addition CV-1616 i CV-1617

!' CA-61 l CA-62 i

l Fire Protection CV-5611 CV-5612 Dirty Waste Drain CV-4400

CV-4446 Nitrogen CV-1667 Waste Gas Radwaste CV-4803 CV-4804 i

Response: .

These P& ids were provided and reviewed. Valves CV-5611,  ;

5612, 4400, 4446, 1667, 4803, 4804, 1616, 1617, CA-61, and l 62 are stroke tested at power or during cold shutdown.

Where these valves are exercised on a cold shutdown i

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frequ:ncy cold shutdown justification (s) should be provided.

VALVE P&ID VALVE P&ID CV-1616 M-233 Sheet 1 CV-4400 .M-213 Sheet 1 CV-1617 M-233 Sheet 1 CV-4446 M-213 Sheet 1 CA-61 M-232 Sheet 1 CV-1667 M-233 Sheet 1 CA-62 M-232 Sheet 1 CV-4803 M-215 Sheet 1 CV-5611 M-219 Sheet 1 CV-4804 M-215 Sheet 1 CV-5612 M-219 Sheet 1 4

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- 2. PUMP TESTING PROGRAM

1. Are any of the'following pumps supplied by emergency power and used to mitigate the consequences of an accident, shut the plant down to the cold shutdown condition, cr maintain the plant in a safe shutdown condition? If so, they should be included in the IST progren and tested to the Code requirements.

Emergency Diesel Fuel Oil Transfer Pumps Chilled Water Pumps

. Boric Acid Transfer Pumps Spent Fuel Cooling Pumps l

Response

The NRC staff's position was explained to the licensee. The licensee will evaluate inclusion of the emergency diesel fuel oil transfer pumps in their IST program.

The chilled water pumps do not perform a safety-related function and need not be included in the IST program.

This remains an OpEN ITEM for the NRC to determine if the boric acid transfer pumps perform a safety-related function and need to be included in the IST program.

This remains an OPEN ITEM for the NRC to determine if the l

spent fuel cooling system performs a safety-related function

!. as part of the plant licensing basis.

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2. What is the basis for selecting the lower driver bearing as the alternate location for measuring the pump vibration for the j service water pumps?

l

Response

1 The upper bearings on these pumps are inaccessible. l Measurements taken at the lower pump bearings should be indicative of pump condition.  !

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3. Lack of adequate instrumentation is not an acceptable justification for not measuring the pump flowrate for the service water pumps during pump quarterly testing (refer to pump relief request B.2). -Provide a more detailed technical justification for not measuring service water pump flowrate quarterly in accordance with the Code to allow the detection of pump degradation.

Response

The service water pump flowrate measurements are now included in the IST program. The licensee will provide a relief request for comparing the pump flowrate and d/p for these pumps to reference pump curves because of the difficulties in obtaining repeatable reference values.

4 The Arkansas Nuclear One, Unit 1, IST program pump listing table does not identify the testing being performed or the testing frequency for each individual pump. Therefore, it was assumed that unless indicated otherwise in a comment or a relief request, that the Code required tests are being performed at the Code specified frequencies. The NRC staff's position is that this information should be provided in the IST program submittals for our review.

Response

Arkansas Nuclear One, Unit 1, IST program tests pumps in accordance woth the Code unless indicated otherwise in a comment or a relief request.

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