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JLE 1S G86 Docket No.: 50-443 MEMORANDUM FOR: Victor Nerses, Project Manager PWR Project Directorate #5 Division of PWR Licensing-A FROM: Charles E. Rossi, Assistant Director for PWR-A Division of PWR Licensing-A
SUBJECT:
SEABROOK STATION SER INPUT ON EQUIPMENT QUALIFICATION Plant Name: Seabrook, Unit 1 Docket No.: 50-443 Licensing Stage: OL Responsible Branch: PWR Project Directorate #5 Responsible Project Manager: V. Nerses Review Status: Continuing The enclosed inputs for the Supplemental Safety Evaluation Report (SSER) were prepared by PAEB, Mechanical Engineering Section and cover the following items in the subject report:
(1) Seismic and Dynamic Qualification of Seismic Category I Mechanical and Electric Equipment (Enclosure 1).
. (2) Pump and Valve Operability Assurance Program (Enclosure 2).
j (3) Purge and Vent Valve Operability (TMI II.E.4.2(6)) (Enclosure 3),
(4) Inservice testing of Pumps and Valves (Enclosure 4).
The SER input incorporates the results of the site audit at Seabrook during November 5-8, 1985 and applicant submittals thru June 13, 1986. There are two generic confirmatory items under Enclosure 2 of this SSER that need particular attention.
Item 4 required confirmation that all pre-service tests had dated December been completed prior to fuel load. The applicant stated in a letter 31,1985 to conrnercial operation. (SBN-919) that these testEwill be provided prior The staff has concurregthe schedule adjustment; however, it remains as a confirmatory item. Item 5 required written confirmation from the applicant that all pumps and valves important to safety had been qualified. Confirmation has not yet been received. As written, the SSER indicates that confirmation was received, but leaves blank the date of thf confirmation letter; as instructed by memorandum from T. Novak to addresse dated June 6,1986.
The SALP input was provided with a prior issue of this SER.
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As stated
. Victor Nerses g gg g cc: C. Rossi V. Noonan R. Ballard L. Magleby, INEL C. Kido, INEL J. Singh, INEL G. Bagchi N. Romney ,
l DISTRIBUTION:
DRB Docket Files PAEB Reading Files PAEB Plant Files ,
l See Previous Concurence Sheet *
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PAEB* PAEB* PAEB ,-
NRomney:vt GBagchi RLBallard o si 6/ /86 6/ /86 6/ /f /86 6/ /86
- _ - _ . - _ _ - - _ - - _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ ._____ -._-_-._- ____________s
Docket No.: 50-443 MEMORANDUM FOR: Victor Nerses, Project Manager l PWR Project Directorate #5 Division of PWR Licensing-A FROM: Charles E. Rossi, Assistant Director j for PWR-A ;
Division of PWR Licensing-A
SUBJECT:
SEABROOK STATION SER INPUT ON EOUIPMENT QUALIFICATION i Plant Name: Seabrook, Unit 1 Docket No.: 50-443 Licensing Stage: OL Responsible Branch: PWR Project Directorate #5 Responsible Project Manager: V. Nerses Review Status: Continuing The enclosed inputs for .the Supplemental Safety Evaluation Report (SSER) were prepared by PAEB, Mechanical Engineering Section and cover the following items in the subject report:
(1) Seismic and Dynamic Qualification of Seismic Category I Mechanical and Electric Equipment (Enclosure 1).
(2) Pump and Valve Operability Assurance Program (Enclosure 2).
(3) Purge and Vent Valve' Operability (TMI II.E.4.2(6)) (Enclosure 3).
(4) Inservice testing of Purps and Valves (Enclosure 4).
The SER input incorporates the results of the site audit at Seabrook during November 5-8, 1985 and applicant submittals thru June 13, 1986.
The SALP input was provided with a prior issue of this SER.
J Charles E. Rossi, Assistant Director Division of PWR Licensing-A l
Enclosure:
As stated j cc: C. Rossi DISTRIBUTION:
V. Noonan DMB Docket Files R. Ballard PAEB Reading Files L. Magleby, INEL PAEB Plant'Eiles C. Kido, INEL J. Singh, INEL '
G. Bagchi N. Romney l PAEB N Q
PAE8V4 PAEB PWR:A:AD Q Romney:vt GBagchi RLBallard CERossi 6/ /t/86 6/// /86 [6/g/86 6/ /86 1
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Docket No.: Sg-443
\
MEMORANDUM FOR:\ Victor Nerses, Project Manager
\PWR Project Directorate #5 Division of PWR Licensing-A FROM: Charles E. Rossi, Assistant Director for PWR-A
)
Division of PWR Licensing-A '
SUBJECT:
SEABROOK STATION SER INPUT ON EQUIPMENT QUALIFICATION Plant Name: Seabrook, Unit 1 Docket No.: 50-443 Licensing Stage: OL Responsible Branch: PWR Project Directorate #5 Responsible Project Manager: V. Nerses Review Status: Continuing The enclosed Safety Evaluation Report (SER) was prepared by PAEB, Mechanical Engineering Section and covers the following items in the subject report:
(1) Seismic and Dynamic Qualification of Seismic Category I Mechanical and Electric Equipment.
(2) Pump and Valve Operability Assurance Progran.
J The SER input incorporates the results of the site audit at Seabrook during November 5-8, 1985 and applicant submittals thru April 8,1986.
The SALP input was provided with a prior issue of this SER.
Charles E. Rossi, Assistant Director l for PWR- A Division of PWR Licensing-A
Enclosure:
As stated cc: C. Rossi DISTRIBUTION:
V. Noonan DMB Docket Files ;
R. Ballard PAEB Reading files l L. Magleby, INEL PAEB Plant Files I C. Kido INEL J. Singh, INEL ,
G. Bagchi N. Romney '
Contact:
N. Romney G. Bagchi X-24709 X-27070 PAEB g ' PA PAEB PWR:A:AD NRomney:vt agchi RLBal ard CERossi j /2.(/86 /g/86 g/7 /86 / /86 i
__ ____._j
I ENCLOSURE 1 OIVISION OF PWR-A LICENSING .
ENGINEERING BRANCH INPUT FOR SAFETY EVALUATION REPORT 4 SEABROOK STATION UNIT 1 DOCKET NO. 50-443 3.10 Seismic and Dynamic Qualification of Safety-Related Mechanical l and Electrical Equipment 3.10.1 Seismic and Dynamic Qualification 3.10.1.1 Introduction Evaluation of the applicant's program for seismic and dynamic qualification of safety-related electrical and mechanical equipment consists of: (1)a detennination of the acceptability of the procedures used, standards followed, and the completeness of the program in general, and (2) an audit of selected equipment items to develop a basis for the judgment of the completeness and adequacy of the implementation of the entire seismic and dynamic qualification program.
Guidance for the evaluation is provided by Section 3.10 of the Standard Review Plan (SRP, NUREG-0800) and its ancillary documents: Regulatory Guides (RGs) 1.61,1.89,1.92, and 1.100; NUREG-0484; and Institute of Electrical andElectronicsEngineers(IEEE) Standards 344-1975 and 323-15 74. These !
docum2nts define acceptable methodologies for pejlsmjcyalification i of '
equipment. Conformance with these criteria is adWesosito latisfy the applicable portions of General Design Criteria (GDC) 1, 2, 4,14. and 30 of Appendix A to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50); Appendix B to 10 CFR 50; and Appendix A to 10 CFR 100 !
The program is evaluated by Seismic Qualification Review Team (SORT) that consists of engineers from NRC and the Idaho National Engineering Laboratory (INEL,EG&GIdaho). l
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3.10.1.2 Discussion .
i The SQRT reviewed the equipment dynamic qualification information in the '
Final Safety Analysis Report (FSAR) Sections 3.9.2 and 3.10 and visited the plant from November 5 through November 8, 1983, to determine the extent to which the equipment installed at Seabrook Unit I meets the criteria described above. A representative sample of safety-related electrical and mechanical equipment as well as, instrumentation, in both the nucle 6r steam supply system (NSSS) and the balance of plant (BOP) scopes, was selected for the audit. Table 3.1 identifies the equipment audited. The plant-site visit included field observations of the actual, final equipment configuration and its installation. Observing the field installation of the equipment is necessary to verify and validate equipment modeling employed in the o;alifi-cation program. These observations were followed by a review of the, corresponding design specifications and test and/or analysis documents maintained in the applicant's central files. The applicant also provided details of the maintenance, startup testing, and in-service inspection.
The audit identified both generic and equipment-specific concerns.
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Subsequently, the applicant submitted additional infomation resolving all of the issues. A surrnary of the issues and their disposition is presented in the following sections and Table 3.1.
3.10.1.3 Generic Items During the field observation of the nuclear instrumentation system cabinet, the SQRT noted that the clearance between this unit and the adjacent solid state protection system train B was nct adequate. The team also learned that this problem was associated with many other cabinets. However, the applicant was aware of the problem and indicated that the problem was being analyzed and its resolution was being actively pursued. Subsequent documentation submitted by the applicant confirmed the resolution of this problem on a generic basis. Therefore, this issue is closed.
During the documentation review of the reactor makeup water valve (RMWV-30:
NSSS-5),i was discovered that the g-loading assumed for the valve qualifi-cation ha not been reconciled with the as-built condition. In addition, this hadnot been done for other valves. However, the applicant indicated that a reconciliation program was in progress. Subsequent documentation provided by the applicant confirmed the completion of this program. Therefore, this issue is closed.
The life-span of nonmetallic patts for 3-inch air-operated valves had not been evaluated, nor had such an evaluation been performed for many other equipment items. The applicant subsequently submitted documentation providing maintenance and replacement schedules indicating that a program is in place that takes life-span into account. Therefore, this issue is resolved.
3.10.1.4 Equipment-Specific Item The SQRT review of the Wyle Laboratories report on the diesel generator relay control cabinet (BOP-16) tests revealed a number of anomalies. These are
. detailed in the report. The applicant provided additional information noting that the pulling out of the stud will not make it an daternal missile; con-sidering its configuration and point of separation,[ tis is acceptable to the staff. Further cracking of insulators did not affect operability. Therefore,
, this issue is resolved.
3.10.1.5 Confirmatory Items The Wyle Laboratories tests on the emergency feedwater p, ump,turbi (Terry Turbine: B0P-5) revealed many anomalies, some of which'M to equire field modifications. The applicant had to confirm that all the anomalies
.aee, satisfactorily resolved.
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-4 Subsequent to SQRT review at the site, the applicant canplated the review of new documentation based on a 1979 Terry turbine test and 1985 scismic analysis and found it acceptable with the two following explanations.
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- 1. That the Seabrook turbine has a different governor system precluding I the tripping problem, and
- 2. A support bracket was added to stiffen the lube-oil piping to eliminate the problem of excessive displacement.
The response is satisfactory. This issue is closed.
During the field observation of the emergency feedwater pump turbine (B0P-5),
it was found that a temporary 3 inch drain line was installed. It was also reported that the line might become a permanent fix. Subsequent documentation j p,ovided by the applicant indicated that the 3 inch drain line is to become a permanent fix and is seismically qualified. This issue is closed.
3.10.1.6 Sunnary and Conclusion On the basis of the observation of the field installation, the review of the qualification documents, and the applicant's responses to SQRT's questions during the audit, the staff finds that the applicant's seismic and dynamic qualification program is well defined densrud and adequately implemented.
The applicant has demonstrated compliance with the applicable portions of , i GDC 1, 2, 4,14,. and 30; Appendix B to 10 CFR 50; and Appendix A to 10 CFR 100.
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3.10.2 Operability Qualification of Pumps and Valves j 3.10.2.1 ' introduction ,
i The NRC staff performs a two-step review of each applicant's pump and valve ' I operability assurance program to determine whether the program can ensure that all pumps and valves important to safety will operate when required for the 1 life of the plant under normal and accident conditions.
The first step is a '
review of FSAR Section 3.9.3.2. However, the information in the FSAR is general in nature and lacks sufficient detail to allow the staff to determine the scope of the overall equipment qualification program as it pertains to pump and valve ! j operability. Thus, the staff also conducts an onsite audit, the second step of '
l the review process. !
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A Pump and Valve Operability Review Team (PVORT), consisting of engineers from j the NRC and INEL, conducts the audit, which reviews a representative sample of '
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installed pump and valve assemblies and their supporting qualification documents '
at the plant site. On the basis of the results of both the audit and the FSAR 1
review, the PVORT determines whether the applicant's overall program conforms '
to the licensing criteria in SRP Section 3.10. The applicant must conform to l SRP Section 3.10 to satisfy the applicable portions of GOC 1, 2, 4,14, and 30 and Appendix B to 10 CFR 50.
3.10.2.2 Discussion The PVORT reviewed the pump and valve operability assurance information in FSAR S:ction 3.9.3.2 and conducted an onsite audit to determine the extent to which the pumps and valves important to safety meet the criteria listed above. The results of the FSAR evaluation appeared in the SER (dated March 10,1983).
These were supplemented by specific comments presented at a pre-audit meeting h21d August 7,1985. Several of these issues were adequately resolved by the i applicant in a letter dated September 24, 1985. The remaining issues were I addressed and resolved during the onsite audit.
Table 3.2 summarizes the status of the 10 items identified in the SER. The l staff has determined (1) that the applicant's position on these iteins has been ad:quately clarified and (2) that the applicant has committed to actions that I will adequately address the concerns. l Seabrook SSER 3-6 /
1
The onsite audit, which was conducted November 5 through November 8,1985, consisted of field observations of equipment configuration and installation for a representative sample of plant equipment. The PVORT selected for evaluation three NSSS and six BOP pump and valve assemblies. Table 3.3 summarizes the status of each assembly that was audited. The field observations were followed by a review of the design and purchase specifications, test / analysis documents, and other documents related to equipment operability that are maintained in the applicant's central files.
In addition to reviewing information concerning the selected assemblies, the PVORT reviewed information on the plant's overall equipment qualification program. Included within this broad evaluation were those programs and procedures necessary to ensure that equipment qualification issues and concerns will continue to be addressed for the life of the plant.
One such program--concerning the, deep draft pump issue (refer to IE Bulletin 79-15)--was reviewed in depth i
The PVORT resolved all but five of the specific operability concerns that were identified. These five concerns follow.
(1) Auxiliary feedwater pump turbine operability with moisture in the steam I was not addressed.
(2) The auxiliary feedwater pump turbine end seal was cracked and the cause I i
had not been determined.
(3) Operability of the auxiliary feedwater pump turbine trip and throttle valve was not ensured af ter an overspeed trip.
(4) /%
Timing requirements were not addressed for control check valve FW-V-331.
(5) Cooling tower pump SW-P-110A 0-ring maintenance procedures were not addressed in accordance with the manufacturer's requirements.
p In addition, the applicant was informed of five generic issues that most be addressed before fuel load. These five issues follow.
(1) Not all of the preservice tests required before fuel load W Ma kri i completed. i (2) Approximately 10 to 15% of all pumps and valves important to safety were not yet qualified and installed.
(3) The plant maintenance procedures were not complete enough for the staff to determine that safety-related equipment will be maintained in its qualified state for the life of the plant.
(4) BOP valves less than 2 inches in size were not included in the Seabrook pump and valve operability assurance program.
(5) The FSAR active valve lists were not current.
W These concerns and issues 1we confirmatory and form the basis for the discussion presented in Section 3.10.2.3 below.
Seabrook SSERf J
3-7 *f
s hurI,11%,d ymtf M64) the applicanti FM e TA-(
After the site aud' submitted letters dated December 31, 1985, which resolved Ms of the specific issues ar.d d' ':Jof and the genericApril 8,1986,D issues P ^ :~""in" "' ^ : ' ' k . - - t L . m i m : , ,,;ii'j ty ef it: :u i'ie., '-- O t r ;-7 1 .L.m. t. i; :-d t":ith d:: 'F r ' ; r
- 7:M t-i; (itu : .f 1 w i': . m_a). The manner in which each con-firmatory issue was addressed is briefly discus ed in Section 3.10.2.3 and is .
indicated in Table 3.3. ,.g g, jT , gpfg- c The PVORT has found that the applicant is dealing with the equipment qualifica-tion issue in a positive manner. All of the SER items were adequately resolved hyM .C through additional clarifications and appropriate commitments provided by the applicant. During the audit, the applicant addressed all questions posed by the PVORT and committed to resolve all audit issues before fuel load. Further-more, the applicant d'iscussed significant aspects of the overall equipment qualification program--such as amplified' response spectra reconciliation, equipment modification and reconciliation of original qualification reports, nozzle load verification, and review of non-safety-related equipment located in close proximity to safety-related equipment. Consequently, the PVORT believes that the continuous implementation of the applicant's overall program should provide adequate assurance that the pumps and valves important to safety will operate as r,equired for the life of the plant.
3.10.2.3 Confirmatory Issues Based on the PVORT's evaluation of the Seabrook pump and valve operability g assurance program, the staff)afidentified to the applicant the following five '
(
equipment-specific issues and five gener c confirmatory issues that.Jr.nt be resolved before fuel load: '( q Equipment-Specific Confirretory Issues j j
~(1) The applicant shall confirm that the auxiliary feedwater pump (FW-P-37A) '
l turbine operability is addressed in regard to the potential of having I moisture in the driving steam.
Applicant Response During hot functional testing, problems were identified involving water slug formation in the steam supply lines to the turbine-driven emerggcycfeedwater (EFW) pump. The applicant explained that de-I sign changes are being implemented, which will protect the piping and supports as well as minimize associated problems with the EFW pump turbine.
The changes include the addition of drains, resloping lines, adding time-sequenced valves, heat tracing, modification of the turbine governor, and the use of a lower viscesity hydraulic fluid in the turbine governor. The commitment to complete 6he modifications before fuel load, as well as the '
onsite review of the qualification documents providelconfidence that the .
EFW pump turbine will function as required. X this commitment k met. The staff MD' .. y. M" d that
./ lam (2) Before the audit, the turbine end of the auxiliary feedwater pump (FW-P-37A) was found to have a cracked seal. The cause of the seal failure had not been determined nor had steps been taken to prevent a recurrence. The applicant confirm that this failure 4+ investigated and resolved.
c.u T, ud seae,asse,/ 3-e
V Applicant Response After a 48-hour endurance run during ho.t functional testing, minor leakage was identified at the seal. A dimensional check discovered that the rotor was mismachined in the area of the seal. This machining error prevented the seal from being properly secured to the rotor. The applicant stated that the rotor has been remachined by Inger- y soll and is now reinstalled. Retesting before fuel load will verify seal integrity. The staff .wHT v3.rify that this commitment M met.
I vv&I t . 4..<
(3) Operation of the auxiliary feedwater pump (FW-P-37A) turbine trip and throttle valve was not investigated when a maximum differential pressure existed across ti lve (such as a turbine overspeed trip condition).
The applicant confirm that the trip and throttle valve can be oper-ated easily during an emergency condition.
Applicant Res1onse Igf t the~ ppitcanT. s, mot pro idep a respume
- d . , = w anat t p-a dnrottle a W f ra dgd sily 'V ring an'JBadgencyI[I tio_ Ih(s iS Gdimai
- 45 a { miktory itN d:- /gMM (4) Check valve FW-V-331 was changed from a swing check to a control check valve that has specific opening and closing times. The operating times for this control check valve were not addresgin the startup, testing, or operating procedures. The applicant"iIdL confirm that the operating times have been investigated and the timing requirements identified and met.
Applicant Response The applicant provided several reasons why the in-service test (IST) program will not include closing time requirements for the valve. (1) For the purpose of controlling waterhammer effects, a valve
- closure time slower than design is acceptable. (2) The valve closure time is not very likely to speed up during its qualified life. (3) The valve closure time requirements were established based upon faulted plant condi-tions. (4) Any test performed at less than faulted plant conditions will not be meaningful, because the closure times will always be slower than the critical limit. This explanation combined with the onsite review of the qualification documents provides confidence that this component will function as required. This issue is resolved.
(5) The maintenance procedures for the cooling tower pump (1-SW-P-110A) were i
still in draft form at the time of the audit. The procedures did not l address the two 0-rings lo t the lateral supports for the pump column. The applicant onfirm that the final maintenance procedures
) specify the special handling and replacement of the 0-rings.
l Applicant Res >onse The applicant has submitted copies of the repetitive task sheets (RT5s) for the service water pump. The implementation of these tasks combined with the onsite discussion of the overall maintenance pro-gram adequately resolves this issue.
Generic Confirmatory Issues woe le (1) At the time of the audit, the maintenance proce res were available for review in draft form only. The applicant confirm that the final maintenance procedures will be consistent with the component manufacturer's recommendations. The applicant sha44 describe how limited-life coeponents Woo C; Seabrook SSER 3-9
l INSERT (page 3-9, Seabrook SSER 4)
The applicant indicated that during one phase of the plant hot functional tests, the turbine trip and throttle valve was deliberately tripped and manually opened three times. Only one person from plant operations was needed to manually open the valve. During this test the steam inlet pressure was approximately 1100 psig, developing the full differential pressure across the valve. This test demonstratiorg together with the review of the qualification documentsj providd confidence that the valve will perform its safety function as needed. This issue is closed.
O O
i G
l y
are identified, and how the equipment will be maintained in an h
and oualified state for the life of the plant. The applicant %ealaprovide le several examples procedures for review.(at least one pump and one valve) of the final maintenance Applicant Response The applicant has submitted copies of the repetitive tasks will be performed.illustrate task sheets (lT5s) that the manner by which various maintenance Each RfS includes necessary information such as task description, equipment identification, acceptance criteria, references to pertinent vendor procedures, and safety precautions. This material combined withissue.
resolves this the onsite discussion of the maintenance program adequately WMW <
(2) The applicantda.a.14 provide w.-itt'en confirmation in the FSAR that all $
)
active BOP valves are covered by the Seabrook pump and va assurance program.
valves smaller than 2In particular, inches the applicant have been included j g, e$re44[
4Ly _' confirm tha
\
j Applicant Response The appropriate sections of the Seabrook FSAR have been revised by Amendment 56, resolving this generic issue.
(3) At the conclusion of the PVORT audit, it was apparent that a complete list of active valves had not been provided in the FSAR. The applicant ehe&1 M confirm that all active valves are correctly identified in the FSAR.
Applicant Response The safety related B0P and NSSS valves have been identi-fied in FSAR Table 3.9 (B)-25 and 3.9 (N)-11 by Amendment 56. This issue is resol (4) Atpleted.
the time btithe audit, most construction tests had already been com-
?-
applicant Howe k, the hot functional tests were still in progress. The fuel load have been completed,1 confirm that all pre-service tests that are require Q 4g f- ,f gfd'... Q g .f-b -
M Applicant Response b d&d V" B,4996, he applicant mmit-ted to omplete the preservice testing before commercial operation [. The
((
3(c
\.
s
>g' gl --ill. verify thapgi -
, ommitment is met. i
$'(5) b At the time of the aud[t, approximately 10 to 15% of all pumps and valves important to safety had not been qualified. The applicant shall confirm
$ that all pumps and valves important to safety are properly qualified and s~ installed. In addition, the applicant shall provide written confirmation that the original loads used in tests or analyses to qualify pumps and valves important to safety are not exceeded by any new loads, such as those imposed by a loss-of coolant accident (hydrodynamic loads) or as-built conditions.
<aps4 .
lia Applicant Response In-e-letter dated April 8,1986, The applicant committed t to complete the qualification of all safety-related active pumps and valves before fuel load. The e4edd wR Mfj that this commitment isseo4.m er#
.__ ,fgj$3% cisbA .
SaabrookSSERg 3-10 V L --_---- _
l 3.10.2.4 Summary On the basis of the results of (1) the component walkdown and the review of the qualification document packages, (2) the additional explanations and informa-tion provided by the applicant throughout the audit, and (3) the resolution of the SER unresolved items, the staff concludes that an appropriate pump and valve operability assurance program has been defined and implemented. The con-tinuous implementation of this overall program should provide adequate assurance that all pumps and valves important to safety will perform their safety related functions as required for the life of the plant.
Provided the commitments iden-tified in Section 3.10.2.3 have been met, the staff concludes that the applicant has qualified those pumps and valves important to safety to meet the applicable Appendix of portions GDC B to 1, 2,50.
10 CFR 4,14, and 30 (Appendix A to 10 CFR 50), as well as s
9 Seabrook SSER 3-11
Table 3.2 Status of pump and valve operability assurance items SER items 1 Finding /
resolution Status Eased on the summaries in FSAR Tables 3.9(B)-14 and Satisfactory Closed 2
'.B (Amendment 53), it is not clear if the applicant as completely qualified the emergency feedwater and f uel oil transfer pumps. The applicant should pro-
.ide the appropriate information in each table to demonstrate that these pumps are qualified in a ranner consistent with FSAR Section 3.9(B).3.2a
( Amendment 53).
s It is not clear from FSAR Table 3.9(B)-2 and Sec- Satisfactory Closed 3 tion 3.9(B).3.1 (Amendment 48) that LOCA loads have teen specified in the design load combinations for EDP Class I components and supports. The applicant s90uld confirm that LOCA loads have been applied to the appropriate BOP equipment in a manner similar to that given in FSAR Section 3.9(N).1.6 for NSSS equipment.
FSAR Section 3.9(B).3.2b (Amendment 48) describes Satisfactory Closed 3 c;erability assurance for active BOP valves 2 inches and larger. The applicant should include all sizes c' active B0P valves in the operability assurance p ogram.
The applicant should provide specific information Satisfactory fer the BOP pumps and valves similar to the infor- Closed 2 tration provided in FSAR Tables 3.9(N)-10 and -11 fcr NSSS pumps and valves.
FSAR Table 3.9(B)-2 (Amendment 47) summarizes the Satisfactory Closed 2 lead combinations for Class 1, 2, and 3 BOP compo-nents and supports. The applicant should identify the stress criteria used to qualify Class 1 BOP valves.
i FSAR Tables 3.9(B)-3 and 3.9(N)-7 provide the stress Satisfactory Closed 2 criteria for Class 2 and 3 non-active BOP and NSSS pumps, respectively. The applicant should identify i these non-active pumps. '
The applicant should clearly show the extent to Satisf actory Closed 3 l which RG 1.148, ANSI /ASME N551.1 draft standards, and ANSI B16.,41 are met.
l See footnotes at end of table.
SeabrookSSER[@ 3-15
/
i Table 3.2 (Continued) ,
Finding /
SER items 1 resclution Status The applicant should clarify the methods used for Satisfactory Closed 3 qualification. Specific information should be pre-sented in the FSAR, and be available for review at the site. The applicant should demonstrate:
'The extent to which operational testing is per-formed at design-basis conditions (full flow, pressure, temperature, etc.).
The technical basis for qualifying equipment by similarity analysis and prototype testing.
Qualification of the equipment as an assembly rather than individual components.
The applicant should clearly show how implementation Satisfactory Closed 3 of the initial test program, maintenance and sur-veillance, in-service inspection, and quality as-surance programs will maintain equipment operability throughout the 40 year plant life. Specific cri-teria should be presented in the FSAR, and be avail-able for review at the site.
The following actions by the applicant would enhance Satisfactory Closed 2 the staff's understanding of the plant:
The terms "DSL" and "LOCA DISPL" in FSAR Table 3.9(B)-6 (Amendment 48) should be defined.
The seismic accelerations discussed in FSAR Sec-tion 3.9(B)3.2a should be specified and how they were used to qualify " rigid" and " flexible" BOP pumps, should be described.
FSAR Sections 3.9(B)3.2b and 3.9(N)3.2a(2) de- .
scribe B0P and NSSS programs for testing valves of various designs and sizes during simulated faulted conditions. The criteria used to select the valves for testing and specify the range of sizes that are covereo should be discussed.
See footnotes at end of table.
i
.S*
Seabrook SSER[ 3-16 V
Table 3.2 (Continued)
SER items 1 Finding /
resolution Status Confirm that the evaluation of NSSS check valves will include " stress analysis of critical parts which may affect operability, including faulted condition loads," as is the case for BOP check valves. i 11tems were identified in the SER and supplemented by specific comments presented at a pre audit meeting on August 7,1985.
2This the item was adequately resolved on the basis of information submitted by applicant in a letter from R. Sweeney, Bethesda Office Manager Seabrook Station, to V. Nerses, NRC Seabrook Project Manager, dated September 24, 1985, entitled " Advance Copies of Annotated FSAR Pages and System Turnover Status."
- This item was adequately resolved on the basis of information reviewed by the staff during the site audit on November 5-8, 1985. The applicant committed to close out this item in a manner and time that are acceptable to the staff.
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1 ENCLOSURE 3 3.10.3 Purge and Vent Valve Operability (TMI II.E.4.2(6)) .
Demonstration of operability of the containment purge and vent valves, particularly the ability of these valves to close during a design basis accident, is necessary to assure containment isolation. This demonstration of operability is required by GDC 1, 2, 4,16, 54, and 56 of Appendix A to 10 CFR Part 50. Guidance for meeting these requirements is provided in Standard Review Plan Sections 6.2.4 and 3.10.
The applicant's containment purge and vent valve qualification program has been reviewed and evaluated by the staff with technical assistance provided by Idaho National Engineering Laboratory (INEL). A Technical Evaluation Report prepared by INEL is included as Appendix to this SER Supplement.
Information which formed the basis of this evaluation included the applicant's Final Safety Analysis Report and the following applicant submittals:
letter from J. DeVincentis of PSNH to G. W. Knighton of NRC, Seabrook l Station Units 1 and 2 Response to RAI 271.12, Containment Purge and Vent Valve Operability, dated November 6,1985; Operability Demonstration of the PSI C0P Valves for Public Service Company of New Hamphsire, et al, performed by Stearns Roger Manufacturers. Inc., dated January 22,1985; Nuclear
, seismic and LOCA Analysis, performed by Posi-Seal International, Inc., dated August 22, 1985; letter from J. DeVincentis of PSNH to V. Noonan of NRC, Request for Additional Infonnation, C0P System Isolation Valves dated May 13, 1986; and, letter from G. S. Thomas of PSNH to V. Noonan of NRC, Request for Additional Infonnation C0P System Isolation Valves - Further Clarification, dated June 4,1986. Operability of the applicant's purge valves was based upon aerodynamic flow tests which simulated the as-built configuration of the valves and worst case load combinations. Stress analyses were performed to consider the effects of a combined LOCA and seismic event.
Based on the review of the applicant's FSAR and test reports concerning the containment on-line purge valves the staff concludes that the applicant has demonstrated the ability of these valves to close against the buildup of containment pressure following LOCA or DBA and to provide containment isolation. The applicant's program to demonstrate the operability of the purge valves is acceptable and does meet the applicable portions of GDC 1, 2, 4,16, 54 and 56 of Appendix A to 10 CFR Part 50.
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ENCLOSURE 4 l
9 3.9.6 Inservice Testing of Pumps and Valves By letters dated December 31, 1985 and June 6, 1986, the applicant for Seabrook Station submitted an inservice testing (IST) program for pumps and valves. The applicant has stated that the IST program will meet the l requirements of 10 CFR 50.55a(g), including the 1980 Edition of the ASME l Boiler and Pressure Vessel Code,Section XI through the Winter 1981 Addenda. The applicant has requested relief from these code requirements pursuant to 10 CFR 50.55a(g)(5)) for certain pump and valve tests.
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The staff has completed a preliminary review of the Seabrook Station IST j prog ram. This preliminary review includes an evaluation of the applicant's I general IST program and evaluation of the applicant's request for relief from certain ASME Code requirements for certain pumps and valves. The requests for relief ar' based on the applicant's determination I
i that ASME Code requirements for certain pumps or valves are impractical I within the limitations of design, geometry, and accessibility. The staff will recommend granting the relief where the applicant's request has satisfied the requirements of 10 CFR 50.55afg)(6)(1).
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Based on our review of the IST Program, the staff concludes l
that the applicant's general program meets the requirements of 10 CFR 50.55a(g) for low power (5%) plant operation. The relief that the i
applicant has requested from certain of the pump and valve testing i
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requirements of the 1980 edition of the ASME Code Section XI through Winter 1981 Addenda is acceptable on an interim basis, pending the staff completing the review of each relief request, for low power (5%) plant 1 operation. This conclusion is based on the fact that the minimum interval for inservice testing is 90 days and the staff will complete its review and have a fully approved program in less than 90 days. Interim relief from certain ASME Code requirements will not endanger life, property, or the common defense and security of the public and is in the public interest giving due consideration to the burden on the applicant that could result if the requirements were imposed.
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3.9.6 )
I The applicant may not exceed low power plant operation until a detailed review of the justifications for each relief request has been completed in l accordance with the requirements of 10 CFR 50.55a(g)(6)(i) and the final IST program is accepted. If the detailed review results in any request for relief being denied the applicant will be required to comply with the appropriate Section XI requirements. In addition if the detailed review identifies any pumps or valves which are not categorized as ASME Code Class 1, 2, or 3 but perform a safety function, those pumps or valves will be included in the IST program.
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J'? ) 21 y Docket Nos.: 50-443 l and 50-444 APPt.ICANT: Public Service Company of New Hampshire i
FACII.ITY: Seabrook Station, Unit I and 2 l
SUBJECT:
MEETING
SUMMARY
On May 13 and 14, 1986, a working meeting was held in Bethesda, Maryland with Public Service of New Hampshire, NRC, and EG&G Idaho, Inc. representatives to discuss the questions resulting from the review of the Seabrook Station pump and valve inservice testing (IST) program. Enclosed is a list of the 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 i followed by detailed discussions concerning specific pumps and valves in the [
Seabrook IST program.
Of the 113 questions and comments discussed at this working meeting, 19 remain as 'open items to be resolved at a later date. These open items are identified in the enclosure. There are several additional items where the utility has agreed to make corrections or changes to their IST program as indicated in the responses to the questions.
Victor Nerses, Project Manager PWR Pro. ject Directorate #5 Division of PWR I.icensing-A
Enclosure:
As stated cc: See next page ers 6/p/86 0606270068 DR 860621 a ADOCK 05000443 PDR Q *iy
/ 'o,, UNITED STATES
[" g NUCLEAR REGULATORY COMMISSION g j WASHINGTON, D. C. 20$55
\....*/ JUN 211986 Docket Nos.: 50-443 and 50-444 APPLICANT: Public Service Company of New Hampshire FACII.ITY: Seabrook Station, Unit I and 2
SUBJECT:
MEETING
SUMMARY
On May 13 and 14, 1986, a working meeting was held in Bethesda, Maryland with Public Service of New Hampshire, NRC, and EG8G Idaho, Inc. representatives to discuss the questions resulting from the review of the Seabrook Station pump and valve inservice testing (IST) program. Enclosed is a list of the 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 Seabrook IST program.
Of the 113 questions and comments discussed at this working meeting,19 remain as open items to be resolved at a later date. These open items are identified in the enclosure. There are several additional items where the utility has agreed to make corrections or changes to their IST program as indicated in the responses to the questions.
Victor Nerses, Project Manager PWR Project Directorate #5 Division of PWR licensing-A
Enclosure:
As stated cc: See next page
Mr. Robert J. Harrison Public Service Company of New Hampshire Seabrook Nuclear Power Station cc:
Thomas Dignan, Esq. E. Tupper Kinder, Esq.
John A. Ritscher, Esq. G. Dana Bisbee, Esq.
Ropes and Gray Assistant Attorney General 225 Franklin Street Office of Attorney General Boston, Massachusetts 02110 208 State Posue Annex Concord, New Hampshire 03301 Mr. Bruce B. Beckley, Project Manager Public Service Company of New Hampshire Resident Inspector i Post Office Box 330 Seabrook Nuclear Power Station !
Manchester, New Pampshire 03105 c/o US Nuclear Regulatory Comission i Post Office Box 700 !
Dr. Mauray Tye, President Seabrook, New Hampshire 03874 )
Sun Valley Association 209 Sumer Street Mr. John DeVincentis, Director Haverhill, Massachusetts 01839 Engineering and licensing Yankee Atomic Electric Company l Robert A. Backus, Esq. 1671 Worchester Road O'Neil, Backus and Spielman Framingham, Massachusetts 01701 116 lowell Street l Manchester, New Hampshire 03105 Mr. A. M. Ebner, Project Manager i United Engineers & Constructors William S. Jordan, III 30 South 17th Street Diane Curran Post Office Box 8223 Famon, Weiss & Jordan Philadelphia, Pennsylvania 19101 l 20001 S Street, NW Suite 430 ,
Washington, D.C. 20009 l l
Mr. Philip Ahrens, Esq.
Assistant Attorney General State House, Station #6 Augusta, Maine 04333 Jo Ann Shotwell, Esq.
Office of the Assistant Attorney General Environmental Protection Division '
Mr. Warren Hall One Ashburton Place Public Service Company of Boston, Massachusetts 02108 New Hampshire Post Office Box 330 D. Pierre G. Cameron, Jr., Esq.
Seabrook, New Hampshire 03874 General Counsel Public Service Company of New Hampshire Seacoast Anti-Pollution league Post Office Box 330 Ms. Jane Doughty Manchester, New Pampshire 03105 5 Market Street Portsmouth, New Hampshire 03801 Regional Administrator, Region !
U.S. Nuclear Regulatory Comission Mr. Diana P. Randall 631 Park Avenue 70 Collins Street King of Prussia, Pennsylvania 19406 Seabrook, New Hampshire 03874 Richard Hampe, Esq.
New Fampshire Civil Defense Agency 107 Pleasant Street Concord, New Fampshire 03301 F
L____.__..._ . . . . . . . ..
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l Public Service Company .. Seabrook Nt... ear Power Station New Hampshire cc:
Mr. Calvin A. Canney, City Manager Mr. Alfred V. Sargent, City Hall Chairman 126 Daniel Street Board of Selectmen Portsmouth, New Hampshire 03801 Town of Salisbury, MA 01950 Ms. Letty Hett Senator Gordon J. Humphrey Town of Brentwood ATTN: Tom Burack RFD Dalton Road U.S. Senate Brentwood, New Hampshire 03833 Washington, D.C. 20510 Ms. Roberta C. Pevear Mr. Owen B. Durgin. Chairman Town of Hampton Falls, New Hampshire Durham Board of Selectmen Drinkwater Road Town of Durham Fampton Falls, New Fampshire 03844 Durham, New Pampshire 03824 Ms. Sandra Gavutis Charles Cross, Esq.
Town of Kensington, New Hampshire Shaines, Mardrigan and RDF 1 McEaschern East Kingston, New Hampshire 03827 25 Maplewood Avenue Post Office Box 366
, Portsmouth, New Hampshire 03801 I Chairman, Board of Selectmen RFD 2 South Fampton, New Hampshire 03827 Mr. Guy Chichester, Chaiman Rye Nuclear Intervention Mr. Angie Machiros, Chairman Committee Board of Selectmen c/o Rye Town Fall for the Town of Newbury 10 Central Road Newbury, Massachusetts 01950 Rye, New Fampshire 03870 Ms. Cashman, Chairman Jane Spector Board of Selectmen Federal Energy Regulatory Town of Amesbury Commission Town Fall 825 North Capital Street, NE Arnesbury, Massachusetts 01913 Room 8105 Washington, D. C. 20426 Honorable Peter J. Matthews Mayor, City of Newburyport Mr. R. Sweeney Office of the Mayor New Hampshire Yankee Division City Hall Public Service of New Fampshire Newburyport, Massachusetts 01950 Company 7910 Woodmont Avenue Mr. Donald E. Chick, Town Manager Bethesda, Maryland 20814 Town of Exeter 10 Front Street Mr. William B. Derrickson Exeter, New Fampshire 03823 Senior Vice President Public Service Company of New Hampshire Post Office Box 700, Route 1 Seabrook, New F.impshire 03874 l l
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Meeting Sumary Distribution Docket or Central File NRC Participants NRC PDR G. Bagcht .l 1.ocal PDR D. Caphton PD#5 Reading File G. Fammer l J. Partlow S. Fou Y. Noonan R. Lipinski Project Manager VNerses N. Romney OELD '
E. Jordan B. Grimes ACRS (10)
M. Rushbrook 1 cc: Licensee and Plant Service 1.ist l i i
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ATTENDANCE LIST INSERVICE TESTING PROGRAM WORKING MEETING PLANT: Seabrook Station DATES: May 13 and 14, 1986 Name Representing Goutam Bagchi NRR/PWR-A/EB Donald Caphton NRC/Rgn. I/DRS.
James Connolly NHY Gary Hanmer NRR/PWR-B/EB Shou-nein Hou NRR/PWR-A/EB Rom Lipinski NRR/PWR- B/EB Robert Martel III NHY Clair Ransom EG8G/INEL Herb Rockhold -
EG8G/INEL Norman Romney NRR/PWR-A/EB Robert Sweeney NHY-Bethesda l
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MEETING MINUTES SEABROOK STATION May 13 and 14, 1986 1
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SEABROOK STATION PUMP AND VALVE INSERVICE TESTING PROGRAM i WORKING MEETING MINUTES May 13 and 14, 1986 A. _ General Ouestions and Conrnents
- 1. Are all valves that are Appendix J, Type C, leak tested included in the IST program and categorized /> or A/C as '
appropriate?
Response: Yes.
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- 2. Relief Requests that reference the FSAR, Technical Specifications, and other documents should be expanded to provide a brief discussion of the technical information contained in the applicable document.
Response: The utility will include additional information in their relief requests to identify the specific operational problems that make pump or valve testing undesirable or impractical.
- 3. The NRC staff position concerning stroke time measurements ;
. of power operated valves is that those measurements must be trended in accordance with Section XI so the information can be utilized to monitor valve degradation and predict valve !
failure. The exception to this position is explained as ]
follows.
Rapid-acting valves are defined as those power operated valves that stroke in 2 seconds or less. Relief from the trending requirements of Section XI (Paragraph IWV-3417(a),1980 Edition through Winter 1981 Addenda) presents no safety concerns for these valves since variations in 1
a
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- 6. A description of the plant operating modes should be added to the IST program legend.
Response: The utility will include this information in their IST program.
Additional Comment: The utility is working on determining limiting values of full-stroke time for power operated valves in the Seabrook IST program, but has not yet determined the values for all of these valves. The utility will provide a listing of these limiting values of full-stroke times in their program resubmittal.
B. Main Steam P&ID 202074
- 1. How are valves MS-PV3001, -PV3002, -PV3003, and -PV3004 fail-safe tested quarterly? Can these valves be stroke timed during fail-safe testing?
Response: The utility will fail-safe test these steam generator atmospheric dump valves during the cuarterly valve exercising tests by using the remote valve positioning switches. The manual block valves may be closed prior to valve testing; this does not pose a problem for the utility.
Additional Comment: The utility will reference in their general discussion section of the IST program the administrative procedures for performance of pump and valve inservice testing used to meet 1
ASME Section XI requirements.
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i C. Emeroency feedrater P&ID 202076
- 1. Should valves FW-V64 and -V70 be Category A/C in Figure 5.37 Relief Request 5 does not apply to these valves as stated in Note 4. Provide a detailed technical justification for not full-stroke exercising.these two valves during each cold shutdown.
Response: These are Category C valves that are not leak rate tested.
Tnese valves will be exercised during cold shutdowns, however, this may not be a full-stroke exercise for FW-V64 since the turbine driven emergency feedwater pump may not be able to establish full flow at this time. This remains an OPEN ITEM for the utility to determine if the testing at cold shutdowns is a full-stroke exercise of FW-V64; and if it is not, it is open for them to determine a sethod and frequency to full-stroke exercise this valve. The utility is monitoring the pipe temperature upstream of these valves to verify that there is no major back leakage through the valves.
- 2. The system and P&ID identification at the top of page 3 of I l
47, figure 5.3, is incorrect. i Response: This is a typographical error that will be corrected. I
- 3. Why are valves FW-V30, -V39 -V48, and -V57 fail-safe tested when the P&ID indicates that they fail *as-is*7 Relief Request 1 does not apply to these valves as stated in Note 2.
Response: The identified fail-safe test will be deleted for these valves. Relief Request #4 applies to these valves.
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- f. Diesel Generator Cooling Water
- 1. Provide P&ID 202103 for our review.
I Response: The P&ID was provided.
i Additional Comment: The emergency diesel generators are tested at 100C load monthly for 60 minutes which should verify that the check l valves in this system full-stroke open. The air operated valves and the 3-way control valves in the diesel cooling water system should be evaluated to determine if they should be included in the IST program. This remains an OPEN ITEM for the utility. If these valves have a required fail-safe position, they must be included in the IST program.
G. Leak Detection P&ID 500037-2
- 1. Review the safety-related function of valves LD-V4 and -V5 (Location D-3) to determine if they should be included in the IST program and categorized A.
Response: These valves have been removed from the piping and the pipe has been capped and seal welded closed.
H. Containment Purce P&ID 604131
- 1. Relief Request 7 does not address valves CAP-V1, -V2, -V3, and V4 as stated in Note 8. Provide a detailed technical j9stification for not full-stroke exercising these valves curing each cold shutdown.
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4 Response: Valve CC-V32 will be stroke timed when it is exercised quarterly and the limiting value of full-stroke time will be identified, j
- 2. Should the valve identified in Figure 5.3 as CC-V226 actually be CC-V2667 Response: Yes, this was a typographical error, i
- 3. Should valve CC-V445 be stroke timed when it is exercised l quarterly?
Response: This valve will be stroke timed quarterly and the limiting i value of full-stroke tine will be provided.
L. Floor Drain P&ID 804994
- 1. What is the P&ID location of valve WLD-V2007 1
Response: There is no valve WLD-V200, it should be identified at WLD-V209. The valve listing table will be corrected and note 25 will be deleted for this relief valve.
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- 2. What is the correct description of valve WLD-FV83317 Is this a rapid-acting valve?
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Response: WLD-FV8331 is a rapid acting valve. The valve listing table will be corrected for this valve.
M. Reactor Coolant P& ids 805002, 805003, and 805006 l
- 1. Provide a detailed technical justification for not full-stroke exercising valves RC-V323 and RC-FV2881 during each cold shutdown. Is valve RC-FV2881 a rapid-acting valve?
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l N. Reactor Coolant Pressurizer P&fD 805007 1
- 1. The NRC staff position concerning PORVs is that the valves )
be exercised each cold shutdown and if the PORVs are l utilized for low-temperature overpressure protection that f they be full-stroke exercised prior to initiation of system I conditions for which vessel protection is needed.
1 Therefore, provide a more detailed technical justification l
for not full-stroke exercising valves RC-PCV456A '
and -PCV4568 during each cold shutdown. Are these valves i rapid-acting valves?
l Response: These pressurizer PORVs will be exercised during each cold q shutdown. These are rapid acting valves and will have a limiting value of full-stroke time of 2 seconds. j Note: These valves do not conform to the staff's positions on cold shutdown testing; they must be tested during each J cold shutdown not necessarily to exceed once every 3 months.
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- 0. Residual Heat Removal P&ID 805008
- 1. How are valves CBS-V55 and -V5F full-stroke exercised during pump tests?
l Response: These valves will not be exercised quarterly because they are not in the pump test flow path. These valves cannot be exercised during cold shutdowns because there is no flow path except into the RCS and flow cannot be established into the RCS since there is no place to put the additional inventory of water: A relief request will be provided for these valves that will provide for testing them during refueling outages.
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- 6. Review the safety-related function of valves RH-V14, -V26,
-v32, and -V70 to determine if they should be categorized A.
Response: These valves are not currently Appendix J 1eakrate tested to verify a containment isolation capability. These valves will not be categorized A.
- 7. Review the safety-related function of valves RH-FCV606,
-FCV607, -FCV618, and -FCV619 to determine if they should be included in the IST program.
Response: This is an OPEN ITEM for the utility to determine if these valves are required to change position to take the RCS to the cold shutdown condition.
P. Safety injection Accumulators P&ID 805009
- 1. The system and PLID identification at the top of page 22 of 47, Figure 5.3, is incorrect.
Response: This is a typographical error that will be corrected.
- 2. Are valves SI-V3, -V17, -V32, and -V47 full-stroke exercised during each cold shutdown? Is power removed from the operators during cold shutdowns?
Response: These valves are closed going into cold shutdowns and are opened when starting up from cold shutdowns. Power is removed from the valve operators during cold shutdowns with the valves closed. The utility will classify these valves as passive valves and need not perform a Section XI exercising test.
- 3. Are valves SI-VS, -V20, -V35, and -V50 leak tested during each cold shutdown? These valves have not been included in Relief Request 10.
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- 5. Category A, passive, valves SI-V62 and -V70 are not required to be exercised according to Paragraph IWV-3700.
Response: The exercise tests will be deleted for these passive valves.
Q. Safety injection-Hiah Head P&ID 805010
- 1. How are valves CBS-V48 and -V52 full-stroke exercised during pump testing?
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Response: These valves can only be partial-stroke exercised quarterly 1 during power operation. These valves cannot be full-stroke i
exercised during cold shutdowns due to low-temperature !
overpressurization considerations. These valves will be full-stroke exercised during refueling outages. A relief request will be provided by the utility.
- 2. Provide a detailed technical justification for not full-stroke exercising valves RH-V50 and -V51 during each cold shutdown. Relief Request 18 does not address these valves as stated in Note 19.
Response: These valves cannot be exercised during cold shutdowns since establishing flow through the valves could result in RHR cooling flow bypassing the reactor core. These valves are addressed in relief request #19. The relief request will be augmented to include a cold shutdown justification.
- 3. Provide a detailed technical justification for not full-stroke exercising valves RH-V52 and -V53 during each
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cold shutdown. Relief Request 19 does not address thrse valves as stated in Note 19.
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- 7. Provide a detailed technical justification for not full-stroke exercising valves SI-V106 and -V110 during each cold shutdown. Relief Request 19 does not address these valves as stated in Note 19.
Response: These valves cannot be exercised during cold shutdowns because it could result in low-temperature overpressurization of the RCS. The utility will augnicnt relief request #18 to include the cold shutdown justification.
- 8. Review the safety-related function of valve SI-V114 to determine if it should be categorized A.
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Response: This valve is not currently leak tested per the Appendix J requirements. This valve need not be categorized A.
- 9. Provide a detailed technical justification for not
! full-stroke exercising valves SI-V118, -V122, -V126, and -V130 during each cold shutdown. Relief Request 19 does l not address these valves as stated in Note 19.
Response: These valves cannot be exercised during cold shutdowns l because it could result in low-temperature overpressurization of the RCS. The utility will augment relief request #18 to include the cold shutdown j justification.
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- 10. Should the stroke time value be the same for valves CBS-V49 I
and -V53 since they appear to be identical?
Response: The stroke times for these stallar valves may be the same.
- 11. Review the safety-related function of valves SI-V138 and -V139 to deterrhine if they should be categorized A. Has )
a maximum stroke time limit been determined for these valves? q l
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_ _ . _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _. _ .__ _ _ _ . . _ _____.)
- 3. Is Category A valve CS-V143 leak rate tested?
Response: This valve is not currently leak rate tested to Appendix J requirements and will be categorized B in the IST program.
- 3. Provide a detailed technical justification for not full-stroke exercising Category A/C valve CS-V144 quarterly or during each cold shutdown. What is the safety position of this valve? Is this valve leak rate tested?
Response: The utility will determine if this valve performs a safety related function in the open position to pass flow for auxiliary pressurizer spray. This valve is not currently leak tested to the Appendix 3 requirements and will be recategorized C. This is an OPEN ITEM for the utility.
- 4. Provide a detailed technical justification for not full-stroke exercising valves CS-V149 and -V150 quarterly.
Response: The utility will full-stroke exercise these valves during cold shutdowns and refueling outages. Relief Request $21 will be modified to expand the technical justification for not exercising these valves quarterly during power operation which will include loss of pressurizer level control and a possible plant trip.
- 5. In reference to Relief Request 22, are the reactor coolant pumps ever secured at any time other than refueling outages?
Response: The reactor coolant pumps can be secured during cold shutdowns, therefore, valves CS-V167 and V168 will be exercised during cold shutdowns when the reactor coolant pumps are secured. Relief request #22 will be revised to conform to this position.
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Response: The utility feels that these valves are passive and need not be included in the IST program. This remains an OPEN ITEM for the NRC to determine if these valves perform an active safety function.
- 10. Provide a detailed technical justification for not full-stroke exercising valves CBS-V58 and -v60 quarterly and during cold shutdowns.
Response: The utility will provide a relief request for these valves and will include in their justification for not exercising quarterly the basis that testing would inject higher concentrations of boric acid into the RCS which could result in a plant shutdown. The basis for-not exercising during cold shutdowns will be the low-temperature overpressurization concerns. The correct valve listing table entries will be made for these valves.
- 11. How is valve CS-V192 full-stroke exercised during pump testing? What is the safety-related position of this valve?
Response: This valve does not perform a safety related function and need not be included in the IST program.
- 12. Is the required design basis accident flow rate achieved during pump testing to demonstrate a full-stroke exercise of valves CS-V200 and -V2097 Response: The quarterly testing results in a partial-stroke exercise of these valves. They cannot be full-stroke exercised during cold shutdowns due to low-temperature overpressurization concerns. These valves will be full-stroke exercised during refueling outages. A relief request will be provided for these valves.
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Response: These valves will be exercised during cold shutdowns and refueling outages when the cooling loads are low enough te allow securing one train cf component cooling. A relief request will be provided for these valves.
- 2. Provide a detailed technical justification for not full-stroke exercising valves CC-V447 and -V448 at least at a refueling outage frequency. Are these modulating valves whose stroke time need not tse measured? Relief Request 29' does not address these valves as stated in Note 26.
Response: These valves will be exercised during cold shutdowns and i 1
refueling outages when the cooling water to non-essential '
loads can be isolated. A relief request will be provided for these valves. The limiting value of full-stroke time will be provided for these valves, i
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- 1. Provide a detailed technical justification for not full-stroke exercising valves CC-TV2171-1 and -TV2171-2 at least at a refueling outage frequency. These valves are incorrectly identified on page 29 of 47, figure 5.3. Relief Request 29 does not address these valves as stated in Note 26.
1 Response: These valves will be exercised during cold shutdowns and refueling outages when the cooling loads are low enough to allow securing one train of component cooling. A relief request will be provided for these valves.
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V. Nitrocen Gas P&ID 805020
- 1. Has a minimum value of Itmiting stroke time been assigned to valves NG-V13. -V14, -FV4609, and -FV46107 Are these l passive valves?
Response: These valves will be classified as passive valves that need not be exercised in the IST program. The limiting value of full-stroke time need not be provided for these passive valves.
W. Reactor Makeup Water P&ID 805021 1
- 1. Provide P&ID 805021 for our review.
Response: The P&ID was reviewed and will be provided with the utilities resubmittal.
- 2. Should valve RMW-V29 be identified as passive?
Response: This valve is a passive valve and it need not be exercised by the IST program.
- 3. Has a maximum value of limiting stroke time been assigned to valve RMW-V307 Response: Valve RMW-V30 is a category A-passive valve that need not be exercised by the IST program.
X. Combustible Gas Control P&ID 805022
- 1. Has a maximum value of limiting stroke time been assigned to valves CGC-14 and -287 Response: These are Category A-passive valves. The limiting values of full-stroke time for these passive valves need not be assigned.
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- 2. The valve identified as CBS-V6 on page 34 of 47, figure 5.3, is incorrect and should be CBS-V7. The valve identified as CBS-V7 should be CBS-VB and the valve identified as CBS-V8 should be CBS-V9.
Response: This is a typographical error that will be corrected.
- 3. How is valve CBS-V7 full-stroke exercised?
Response: The utility is establishing flow through this valve during pump testing. The test flow of ~2000 gpm is below the
~3000 gpm design accident flow. This is an OPEN ITEM for the utility to determine a method and frequency for full-stroke exercising these check valves.
- 4. Review the safety-related function of valve CBS-V8 to determine if it should be categorized A.
Response: This valve is not currently leak tested to the Appendix J requirements. This valve need not be categorized A.
- 5. Review the safety-related function of valve CBS-Vil to determine if it should be categorized A.
Response: This valve is not currently leak tested to the Appendix J requirements. This valve need not be categorized A.
- 6. Review the safety-related function of valve CBS-V12 to i
determine if it should be categorized A/C instead of B. How l is this valve full-stroke exercised during refueling outages? Provide a detailed technical justification for not full-stroke exercising this valve each cold shutdown.
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- 10. Should va ives CBS-V31, -V32, and -V33 be uroke timed when i tested? I l
Response: These valves will have their stroke times measured during l valve exercising. i Additional Coment: Valves CBS-V9, V15, V25, and V26 will be disassembled and i inspected during refueling outages. They will be disassembled on a sampling basis with two groups made up of valves CBS-V9 and V15 and valves CBS-V25 and V26. Relief request $28 will be expanded to discuss sample disassembly and inspection for these valves.
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- 2. Sample Service P&ID 805025 ,
- 1. What is the normal position of valve RC-FV28367 Response: The normal position of this valve is closed.
- 2. It is unnecessary to full-stroke exercise relief -
valve RC-V312 quarterly.
Response: This is a typographical error and the valve need not be exercised. The relief valves are passive valves.
AA. Primary Component Coolina P&ID 805028
- 1. Provide a detailed technical justification for not l
full-stroke exercising valves CC-V175. -V176. -V256, and -V257 quarterly in accordance with Section XI. Relief Request 22 does not address these valves as stated in Note 22 and it also appears that Note 22 does not apply.
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- 00. Service Water P&ID 805033 j l
- 1. Review the safety-related function of valves SW-V63 and -V64 to determine if they should be included in the IST program and tested in accordance with the requirements of Section XI. i Response: These valves do not perform a safety related function and I need not be included in the IST program.
EE. Service Air P&ID 202108 and 804989 1
- 1. Review the safety-related function of valves SA-V229 and -V1042 to determine if they should be included in the IST program and categorized A.
Response: These valves are currently leakrate tested per Appendix J and will be included in the IST program as category A-passive valves.
FF. Containment Air Handlino P&ID 604131 1
- 1. Valve CAH-V12 should be Category A/C. Note 1 does not apply to I this check valve.
Response: This valve will be categorized A/C. This is an OPEN ITEM for the utility to determine if valves CAH-FV6572, FV6573, and TV6574 are active or passive valves. Note 1 will be deleted for valve CAH-V12 in the valve listing table. l l
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- 2. PUMP TESTING PROGRAM
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- 1. Provide the documentation that demonstrates that all safety-related pumps are being tested quatterly in accordance with Section XI. This information should be included in the IST program and can be in the form of a 1 table similar to the valve test tables identifying the pump, tests performed, and any applicable relief requests.
Response: A table listing the pump testing performed at Seabrook Station was provided. This table will be included in the !
IST program resubmittal.
- 2. In reference to Relief Request 31, does using the computer readout when measuring pump flow provide repeatable test data?
Response: The utility will provide a listing of the instrument accuracies as an attachment to the IST resubmittal. The l computer readout meets the requirements for repeatable test data.
- 3. Are both flow and differential pressure measured when testing the service water pumps?
Response: Yes, both pump flow and differential pressure will be measured for these pumps. The relief request for not ;
varying pump flow in the ftxed flow system will be deleted.
Additional l Consnent: It is an OPEN ITEM for the utility to determine which type of pump vibration measurements will be taken at Seabrook.
If velocity measurements are used, it is open for the utility to determine the alert and required action ranges.
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