ML20246B594
| ML20246B594 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/03/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-584, NUDOCS 8907100022 | |
| Download: ML20246B594 (19) | |
Text
___
1 4,
B l
Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/53t'r4000 l
July 3, 1989 LIC-89-584 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station PI-137 Washington, DC 20555
References:
1.
Docket No. 50-285 2.
Letter from OPPD (K. J. Morris) to NRC (Document Control Desk) dated March 24, 1989 (LIC-89-202) 3.
Record of Telephone Communication from 0 PPD (J. J. Fisicaro) to NRC (A. Bournia) dated May 24, 1989 (RTC 89-036)
Gentlemen:
SUBJECT:
Inservice Testing Program for Pumps and Valves; Program Clarification and Schedule As requested by the NRC in Reference 3, Omaha Public Power District (0 PPD) submits the enclosed response to questions on the SER for Rev. 3 of the Fort Calhoun Station IST Program. A proposed schedule of activities is also included in the attachment. This response makes clarifications to Reference 2 and proposes a detailed implementation schedule.
The procedures required to be written in order to support testing to establish baseline data will be issued by the 1990 Refueling Outage, with actual testing and incorporation of the baseline reference data into the procedures to be completed by 2 months after the end of the 1990 Refueling Outage.
It is expected that OPPD will submit Revisir.n. of the IST Program Plan to the NRC within 2 months after completion of the IC90 Refueling Outage.
The revision 5 submittal will reflect the changes discussed elsewhere in this document.
I t e907100022 890703 PDR ADOCK 050002S5 roc p
as u n inipu,wnen r
oppononau
1 U. S. Nuclear Regulatory Commission LIC-89-584 Page 2 OPPD believes that implementation of the activities discussed in this transmittal and Reference 2 will result in a significant improvement to the Fort Salhoun Station IST Program.
If you have additional questions or require additicpl information, please contact me or members of my staff.
Sincerely, orris Division Manager Nuclear Operations KJM/pjc Attachment c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector 4
l l
1. :.
Page 1 of 17 ATTACHMENT Program Clarification and Schedule of Implementation'for OPPD's Response to Items in Appendix C of the December 22, 1988 SER for Revision 3 to Fort Calhoun's'IST Pump and Valve Program SER ITEM N0.
1 The licensee should develop a method to measure flow rate for the Low-Pressure Safety Injection Pumps, SI-1A and -1B.
OPPD RESPONSE OPPD agrees to measure flow rates for the Low Pressure Safety Injection Pumps during cold st;atdowns (when Decay Heat Removal is in progress) and Refueling Outages, using installed instrumentation.
o Procedural implementation for establishing baseline reference data is expected by December 15, 1989.
o Implementation of the baseline reference date into the Surveillance Test, and submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
2 The licensee should develop a method to measure flow rate for the Containment Spray Pumps SI-3A, -3B and -3C.
OPPD RESPONSE OPPD agrees to measure flow rates for the Containment Spray Pumps during Cold Shutdowns (when system lineup can be realigned), and Refueling Outages using installed instrumentation.
l o
Procedural implementation for establishirq baseline reference data is expected by December 15, 1989.
o Implementation of the baseline' reference data into the Surveillance Test, and submittal of the revised IST Program Plan is expected within 2 months after the completion of the 199t' Refueling Outage.
1 I
h 6 m..
l v
l' Page 2 of 17 j
Program Clarification and Schedule (cont'd) i SER ITEM N0__.
3 The licensee should develop a method to measure flow rate for the High Pressure Safety Injection Pumps SI-2A, -28, and -2C.
OPPD RESPONSE OPPD agrees to measure flow rates for the High Pressure Safety l
Injection Pumps during Refueling Outages, using installed instrumentation.
3 l
I 0
Procedural implementation for establishing baseline reference data is expected by December 15, 1989.
o Implementation of the baseline reference data into the Surveillance _ Test and submittal of the revised IST Program Plan is expected within 2 Inonths after the completion of the 1990 Refueling Outage.
l l
4 The licensee should calculate pump inlet pressure for the Component Cooling Pumps, AC-3A, -3B, and -3C.
OPPD RESROSSE r rocedures have been revised to allow for calculation of the Ccmponent Cooling W&ter Pumps inlet pressure.
The calculated inlet pressure along with the measured discharge pressure is then used to determine pump differential pressure.
o Submittal of the revised IST Program Plan is emected within 2 months after the. completion of the 1990 Refue'. Ag Outage.
5 The licensee should develop a flow monitoring program for the Component Cooling Pumps, AC-3A, -38, and -3C.
OPPD RESPONSE OPPD agrees to measure flow rates for the Component Cooling Water Pumps quarterly, using installed instrumentation.
o Procedural implementation for establishing baseline reference data is expected by December 15, 1989.
o Implementation of the baseline reference data into the Surveillance Test, and submittal of the revised IST Program Plan l
is expected within 2 months after the completion of the 1990 Refueling Outage.
f3
?
Page 3 of 17 Program Clarification and Schedule (cont'd)
SER ITEM NO.
i 6
1he NRC staff position concerning the licensee's request for relief fr om observing lubricant level or pressure on the Componcnt Cooling Pumps AC-3A, -3B and -3C is that relief is unnecessary because the bearing design is such that the bearings are tot:,".y enclosed and permanently lubricated.
{
JI OPPD RESPONSE OPPD concurs with response and will delete the relief request from the IST Program Plan.
l o
The submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
7 The licensee should develop a method to measure flow rate for the a
Boric Acid Pumps, CH-4A and -48.
OPPD RESPONSE OPPD agrees to measure flow rates for the Boric Acid Transfer Pumps during Refueling Outages, using installed instrumentation.
o Procedural implementation for establishing baseline reference data is expected by December 15, 1989.
o Implementation of the baseline reference data into the Surveillance Test, and submittal of the revised IST Program Plan is expected within 2 months after the completion of the M90 Refueling Outage.
8 The licensee's request for relief from measuring bearing temperature on the Raw Water Pumps, AC-10A, -108, -10C and -100 is unnecessary because the pump bearings are located in the main flow path.Section XI, Paragraph IWP-4310 requires bearing temperature measurements on bearings located outside the main flow path.
OPPD RESPONSE OPPD concurs with the response and will delete the relief request from the IST Program Plan.
']
i ;1:
. w.
I, Page 4 of.37 Program Clarification and Schedule (cont'd)
' SIR ITEM NO.
8 0 PPD RESPONSE (cont'd) ll o
The submittal of the revised IST Program Plan is. expected within 2.
months after the completion of the 1990 Refueling Outage.
l I
9 The licensee should measure flow rate and calculate inlet and differential pressure on the Raw Water Pumps, AC-10A, -108, -10C and -100.
OPPD RESPONSE j
OPPD agrees to measure flow rates.for the Raw Water Pumps quarterly, using installed instrumentation. -Inlet Pressure will j.
also be calculated and the differential pressure will be L
determined by calculation.
1 o
Procedural implementation for establishing baseline reference data is expected by December 15, 1989.
L o
Implementation of the baseline reference data into the L
Surveillance Test, and submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
10 The licensee has failed to include rotative speed measurement of the turbine driven auxiliary feedwater pump, FW-10 in the IST program as required by Secthn XI, Paragraphs IWP-3100 and -4400.
l OPPD RESPONSE The rotative speed measurement of the turbine driven Auxiliary feedwater Pump FW-10 is included in the Surveillance Test and is taken in accordance with Section XI.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
11 The licensee should include the emergency diesel generator fuel oil transfer pumps and appropriate valves in the IST Program.
I i
i
,.. a Page 5 of 17 Program Clarification and Schedule (cont'd)
SER ITEM NO.
f 11 (cont'd)
~
l OPPD RESPONSE OPPD agrees to test the Diesel Generator Fuel Oil Transfer Pumps quarterly, in accordance with Section XI. There are no power operated valves in line with the transfer pumps.
Instrumentation for flow and suction pressure will be required to be installed.
o Procedural implementation for establishing baseline reference data is expected by December 15, 1989.
o Flow and pressure instrumentation is expected to be installed during the 1990 Refueling Outage, o
Procedural Implementation for testing check valves in the Diesel Generator Fuel Oil Transfer line is expected within 2 months after the completion of the 1990 Refueling Outage.
o Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program Plan is expected within 2 months after completion of the 1990 Refueling Outage.
12 The licensee should comply with Section XI, Paragraphs IWV-3426 and -3427 when Leak Testing Containment Isolation.
OPPD RESPONSE Upon further investigation of item 12 above, and based on discussion with NRC inspection team members during the Maintenance Team Inspection, it is OPPD's understanding that trending is required for the Containment Isolation Valves. OPPD will comply with Section XI, Paragraphs IWV-3426 and -3427.
o Procedural implementation for establishing trending for Containment Isolation Valves leakage rates is expected by January 1, 1990.
o Surveillance Tests will be revised to record leakage rates for trending information.
Procedural implementation is expected by February 15, 1990.
l I
- , a Page 6 of 17 Program Clarification and Schedule (cont'd)
SER ITEM N0.
12 OPPD RESPONSE (cont'd)
~
o Submittal of the revised IST Program Plan is expected within 2 months after completion of the 1990 Refueling Outage.
13 The licensee has provided a cold shutdown justification for full-stroke exercising valves HCV-438A, -4388, -438C and -438D, Reactor Coolant Pump Seal and Oil Cooler Component cooling water supply and return, during those cold shutdowns when all Reactor Coolant Pumps are stopped and the reactor coolant system temperature is less that 130' F.
A relief request should have
=
been provided because these valves will not be exercised each cold shutdown since both of those conditions may not be satisfied each cold shutdown, and the exercising interval could exceed that permitted by the Code. However, to avoid confusion, this justification has been evaluated as a relief request in Item 4.3.1.1.
The licensee should correct this error.
OPPD RESPONSE OPPD concurs with the response and will change the Cold Shutdown justification to a Relief Request.
o The submittal of the Relief Request and the revised IST Program
~
Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
14 The licensee should full-stroke exercise valve PCV-1849, containment instrument air supply isolation, quarterly in accordance with Section XI or provide a relief request that demonstrates why that test interval is impractical. To avoid confusion, this cold shutdown justification has been evaluated as a relief request in Item 4.6.1.1.
The licensee should correct this error.
OPPD RESPONSE Valve PCV-1849 has been replaced with two (2) containment instrument air supply isolation valves, PCV-1849A and PCV-18498, which are presently tested during Refueling Outages.
OPPD will submit a relief request _ with additional technical justification for not stroking the valves quarterly, due to the potential erratic behavior of the Pressurizer Level System which could cause severe system depressurization.
-__._.__m_
___---_m____.--_
a *..
Page 7 of 17 l
Program Clarification and Schedule (cont'd)
SER ITEM ?{02 14 OPPD RESPONSE (cent'd) o Procedural implementation to add valves PCV-1849A and PCV-1849B to the Surveillance Test is completed, o
The submittal of the Relief Request and the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
i 15 The licensee has provided a cold shutdown justification for full-stroke exercising valves HCV-206 and -241, reactor coolant pumps saal leak-off isolations, during those cold shutdowns when i
all Reactor Coolant Pumps are stopped and the Reactor Coolant System is depressurized. A relief request should have been provided because these valves will not be exercised each cold shutdown since both of those conditions may not be satisfied each cold shutdown and the exercising interval could exceed that permitted by the Code. However, to avoid confusion, this justification has been evaluated as a relief request in Item 4.7.1.1.
The licensee should correct this error.
OPPD RESPONSE OPPD concurs with the response and will change the Cold Shutdown Justification to a Relief Request.
o The submittal of the Relief Request and the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
16 The following check valves should be categorized A/C instead of A:
SI-194 - shutdown cooling injection check SI-197 - shutdown cooling injection check SI-200 - shutdown cooling injection check i
SI-203 - shutdown cooling injection check i
SI-195 - high pressure safety injection header check
{
SI-198 - high pressure safety injection header check SI-201 - high pressure safety injection header check SI-204 - high pressure safety injection header check SI-208 - combined safety injection tank discharge /
safety injection check l
l l
l
L-Page 8 of 17 Program Clarification and Schedule (cont'd)
SER ITEM N0.
16 (cont'd)
SI-212 - combined safety injection tank discharge /
safety injection check i
SI-216 - combined safety injection tank discharge /
safety injection check SI-220 - combined safety injection tank discharge /
safety injection check l
The licensee should correct this categorization.
(See Appendix A-4.1,
)
Items 4.8.1.1 and 4.8.1.2).
OPPD RESPONSE OPPD concurs with the response and will correct the categorization of the above (SER ITEM #16) listed check valves.
o The submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
17 The licensee should develop a sample disassembly / inspection program that verifies the full-stroke capability of valves SI-208,
-212, -216 and -220 combined safety injection tank discharge / safety injection checks during Refueling Outages.
QEED RESPONSE OPPD proposes to verify the full-stroke capability of check valves SI-208, -212, -216 and -220 (also SI-207, -211, -215 and -219) during Refueling Outages using a Full Flow Verification method; the SI tank will be pressurized (using nitrogen) to approximately 35 psig and then the SI Tank will be " dumped" to the Reactor Vessel.
Parametars as required (such as SI Tank level decrease vs. time, SI tank pressure and valve differential pressure) will be measured in order to establish a baseline of reference data.
One check valve (with the most service) from the SI Tank that has just been emptied will then be disassembled and inspected.
If the check valve is in an acceptable condition, a " signature" will then be developed by Engineering to evaluate the acceptability of the other 3 SI tank check valves, as well as for future tests.
I i
y f w.
ab Page 9 of 17 Program Clarification and Schedule (cont'd) l l
SER TTEM NO2 17 o Procedural implementation for establishing baseline reference data is expected by January 15, 1990.
o Initial testing and evaluation of this method of testing is I
expected to be completed within 2 months after the completion of the 1990 Refueling Outage.
o Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage. NOTE: This item is to be performed in conjunction with SER ITEM #23 below.
18 The licensee should full-stroke exercise valves SI-100 and -113 high-pressure safety injection pump suction checks.
OPPD RESPONSE i
OPPD proposes to partial stroke test the HPSI check valves quarterly, using the mini-recirculation flow path. The full stroke capability of the HPSI check valves will be verified during each Refueling Outage. Minimum design flow based on safety analyses will be verified thru the check valves using installed instrumentation.
o Procedural implementation for establishing bateline reference data is expected by January 15, 1990.
o Initial testing and evaluation of this method is expected to be completed within 2 months after the completion of the 1990 Refueling Outage.
o Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program plan is expected within 2 months after the completion of the 1990 Refueling Outage.
19 The licensee should full stroke exercise valves SI-135, -143 and
-149 containment spray pump discharge checks during Cold Shutdowns.
b Page 10 of 17 i
Program Clarification and Schedule (cont'd) l SER ITEM NQ.
l l
19 QPPD RESPONSE OPPD proposes to verify the full-stroke capability of the containment spray check valves during Cold Shutdowns (when system lineup is able to be realigned) and Refueling Outages. Minimum design flow based on safety analyses will be verified thru the l
check valves by using installed instrumentation.
o Procedural implementation for establishing baseline reference data is expected by January 15, 1990.
o Initial testing and evaluation of this method is expected to be completed within 2 months after the completion of the 1990 Refueling Outage.
o Implementation of the baselinc reference data into the Surveillance Test and submittal of the revised IST Program Plan is 1
expected within 2 months after the completion of the 1990 j
Refueling Outage.
q 20 The licensee should verify that valves SI-139 and -140, safety injection and refueling water tank outlet checks, are being full-stroke exercised during refueling outages.
OPPD RESPONSE OPPD proposes to verify the full-stroke capability of the SIRWT check valves during Refueling Outages by running the Safety Injection and Containment Spray pumps as required in each header j
The minimum design flow thru the check valves based on safety analyses shall also be verified, using installed instrumentation.
o Procedural implementation for establishing baseline reference data is expected by January 15, 1990.
1 o
Initial testing and evaluation of this method is expected to be completed within 2 months after the completion of the 1990 Refueling Outage.
o Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 i
Refueling Outage.
1 l
i
~~
l
/
Page 11 of 17 Program Clarification and Schedule (cont'd)
SER ITEM NO.
21 The licensee should conduct a Sample Disassembly / Inspection Program on valves SI-159 and -160, Containment Sump Outlet Checks, each Refueling Outage.
OPPD RESPONSE OPPD agrees to conduct a Sample Disassembly / Inspection Program on Containment Sump Outlet Check Valves during each Refueling Outage.
o Procedural implementation is expected'by November 1, 1989.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
22 The licensee should partial-stroke exercise valves SI-196, -199, l
-202 and -205, Safety Injection Header Checks, during Cold Shutdowns.
OPPD RESPONSE OPPD agrees to partial-stroke exercise check valves SI-196, -199,
-202 and -205 during Cold Shutdowns using the charging pumps, and l
full stroke exercise these check valves during Refueling Outages.
o Procedural implementation is expected by November 1, 1989.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
23 The licensee should develop a Sample Disassembly / Inspection Program that verifies the full-stroke capability of valves SI-207,
-211, -215 and -219, Safety Injection Tank Discharge Checks, during Refueling Outages.
OPPD RESPONSE OPPD proposes to verify the full-stroke capability of check valves SI-207, -211, -215 and -219 (also SI-208, -212, -216 and -220 during Refueling Outages) using.a Full Flow Verification method; the SI tank will be pressurized (using nitrogen) to approximately 35 psig and then the SI Tank will be " dumped" to the Reactor Vessel.
l m__._____..
.___m
c.-,,
Page 12 of 17 l
Program Clarification and Schedule (cont'd)
SER ITEM N0.
23 OPPD RESPONSE (cont'd) l Parameters as required (such as SI Tank level decrease vs. time, I
l SI tank pressure and valve differential pressure) will be measured in order to establish a baseline of reference data. One check valve (with the most service) from the SI Tank that has just been 3
emptied will then be disassembled and inspected.
If the check i
valve is in an acceptable condition, a " signature" will then be developed by Engineering to evaluate the acceptability of the l
other 3 SI tank check valves, as well as for future tests.
o Procedural implementation for establishing baseline reference data is expected by January 15, 1990.
o Initial testing and evaluation of this method of testing is expected to be completed within 2 months after the completion of the 1990 Refueling Outage.
o Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program Plan is 4
expected within 2 months after the completion of the 1990 Refueling Outage. NOTE: This item is to be performed in conjunction with SER ITEM #17 above.
{
24 The licensee should verify the closure capability of valves MS-351 l
and -352, turbine driven auxiliary Feedwater Pump Steam Supply Checks, because if either were to stick open and a Main Steam line break occurred upstream of the Main Steam Isolation Valve, both l
steam generators would depressurize through the steam line break.
OPPD RESPONSE l
OPPD agrees to verify closure capability and full-stroke capability of MS-351 and -352 during each Refueling Outage by conducting a sample disassembly / inspection of the check valves.
o Procedural implementation is expected by November :,1989.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
l
Page 13 of 17 Program Clarification and Schedule (cont'd)
SER ITEM NO.
25 The licensee has proposed to full-stroke exercise and stroke time valves HCV-150 and -151, PORV block valves, during cold shutdowns with the justification that failure would require entering a Limiting Condition for Operation, but has failed to explain the requirements of the LCO. Additionally, the licensee was provided with the NRC staff's position concerning these valves in a letter from A. Bournia, PD4/ PPM, to R. L. Andrews, OPPD, which stated the following:
The PORV block valves would be included in the IST Program and tested quarterly to provide protection against a small break LOCA should a PORY fail open.
The licensee should comply with this staff position.
OPPD RESPONSE OPPD agrees to exercise the PORV Block Valves, HCV-150 and HCV-151, quarterly, o
Procedural implementation is expected by November 1,1989.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
26 The licensee's justification to verify closure (their safety position) of valves SA-137, -138, -187 and -188, Diesel Generator Starting Air Compressor Discharge Checks, is unnecessary because the verification is being performed quarterly and that frequency is in accordance with Section XI requirements.
OPPD RESPONSE i
OPPD concurs with the response and will delete the justification j
to verify closure of valves SA-137, -138, -187 and -188.
l o
The submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
I
I Page 14 of 17 Program Clarification and Schedule (cont'd)
SER ITEM NO.
27 The licensee has provided a Cold Shutdown justification for not measuring the stroke time of valves SA-147, -148, -197 and -198, Diesel Generator Air Start. A relief request should have been provided because Section XI, Paragraph IW-3413(b) requires that stroke time of a power operated valve be measured each time that valve is full-stroke exercised. The licensee's technical
, justification for measuring stroke time of these valves is i
unacceptable, therefore, the licensee should stroke time these valves in accordance with Section XI.
3 OPPD RESPONSE The Diesel Generator Air Start Valves SA-147, -148, -197 and -198 are Grove "Flexflo" type 1 1/2 inch, screwed end (in line). This type of valve does not have an external operator (actuator) and is totally enclosed. The open/close positioning of this type of valve is a function of the pressure differential on a flexible tube against a slotted cylindrical core, and is almost instantaneous. OPPD will change the justification to a relief request to test the Diesel Generator Air Start Valves quarterly, by measuring the Diesel Generator starting time to ensure that it is started within the required time limit. Measuring the Diesel l
Generator start time gives an indication of possible valve degradation since any significant change in valve stroke time would result in longer Diesel Generator start times.
o Procedural implementation to add valves SA-147, -148, -197 and
-198 to the Surveillance Test in order to test the valves and time them by Diesel Engine start time is completed.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
4 l
l 28 The licensee should identify the applicable paragraph of Section XI from which relief is being requested for all Category B and C valves in the IST Program.
OPPD RESPONSE OPPD agrees to identify the applicable paragraph of Section XI i
from which relief is being requested for all Category B and C valves in the IST Program.
<o Page 15 of 17 Program Clarification and Schedule (cont'd)
SER ITEM NO.
28 OPPD RESPONSE (cont'd) o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
29 The licensee should identify the applicable paragraph of Section XI from which relief is being requested for the following Category A/C valves SI-208 SI-195 SI-212 SI-198 i
SI-216 SI-201 SI-220 SI-204 OPPD RESPONSE OPPD agrees to identify the applicable paragraph of Section XI from which relief is being requested for the above (SER ITEM No.
- 29) listed Category A/C valves.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
30 The licensee should uniquely identify all relief requests and cold shutdown justifications in the IST Program.
OPPD RESPONSE It is OPPD's understanding that this request is to ensure that the correct terminology be used (e.g., relief request or cold shutdown) in the IST Program Plan Submittal. OPPD agrees to uniquely identify Relief Requests and Cold Shutdown justifications in the IST Program, o
Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
31 The licensee should provide sufficient technical information to justify not exercising the Containment Air Coolers Component Cooling water supply and return valves quarterly during power operation, other than valve failure while testing would require entering a seven-day Limiting Condition for Operations. Seven days should allow sufficient time for valve repair should a failure occur while testing; therefore, the licensee should test these valves quarterly.
[
l l
l l
.1 i
1 Page 16 of 17 Program Clarification and Schedule (cont'd)
SER ITEM NO.
1 31 OPPD RESPONSE OPPD agrees-to exercise the Containment Air Coolers Component Cooling water supply and return valves, HCV-400A, -400B, -400C,
-4000, -401A, -401B, -401C, -4010, -402A, -402B, -402C, -402D,
-403A, -403B, -403C and -403D quarterly as required by Section XI.
o Procedural implementation is expected by November 1, 1989.
j o
Submittal of the revised IST Program Plan is. expected within 2
]
months after the completion of the 1990 Refueling Outage.
32 The licensee has stated that exercising the Safety Injection Tanks
. Fill and Drain Valves, HCV-2916, -2936, -2956 and -2976, would cause level fluctuations in the Safety Injection Tanks which may require entering a Limiting Condition for Operation. However, the licensee has failed to explain the requirements and limitations of the LCO. On this basis, these valves should be exercised quarterly because entering a Limiting Condition for Operation is not an adequate technical justification for not performing valve testing ia accordance with Section XI.
OPPD RESPONSE OPPD agrees to exercise the Safety injection Tanks Fill and Drain Valves, HCV-2916, -2936, -2956 and -2976 quarterly in accordance with Section XI.
o Procedural implementation is expected by November 1,1989.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
33 The licensee has provided a Cold Shutdown justification that states that the Reactor Vessel Head Vents, HCV-176, ~ -177 and -178, I
cannot be exercised during power operation because that would vent high-pressure and high-temperature reactor coolant to the pressurizer quench tank. The quench tank is sized to accommodate
. the discharge from the pressurizer Code safety valves and/or the PORYS and it appears that the flow from the vessel head vents would be very small by comparison and, therefore, readily contained and cooled by the quench tank water volume. The i
licensee should full-stroke exercise these valves quarterly in l
accordance with Section XI.
l l
\\
i l
Page 17 of 17 l
Program Clarification and Schedule (cont'd)
SER ITEM NO.
33 OPPD RESPONSE (cont'd)
Reactor Vessel Head Vent Valves HCV-176, HCV-177 and HCV-180 are Target Rock Solenoid Valves.
These valves have shown a high probability of sticking open when exercised during Refueling Outages which could result in a sma'll break LOCA if exercised at l
power.
It is proposed that the Reactor Vessel Head Vent valves be exercised during cold shutdowns and Refueling Outages.
o Procedural implementation to add the Reactor Vessel Head Vent Valves HCV-176, -177 and -180 to the Surveillance Test in order to stroke time them during Cold Shutdowns and Refueling Outages is expected by November 15, 1989.
o Submittal of the revised IST Program Plan is expected within 2 months after the completion of the 1990 Refueling Outage.
l j
i