ML20246D954

Forwards Rev 3 to Inservice Testing Program Plan for Pumps & Valves. Rev 3 Provides Clarification & Revs in Response to 890531 Request for Addl Info.Rev Complete W/Exception of Any Addl Relief Requests Discovered During Testing

ML20246D954
Person / Time
Site:	Comanche Peak
Issue date:	08/21/1989
From:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20246D956	List: ML20246D954 ML20246D959
References
TXX-89565, NUDOCS 8908280351
Download: ML20246D954 (10)

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EE 2 Log # TXX-89565 File # 10010 905.4 Ref. # 10CFR50.55a(g) tilELECTRIC ;

August 21, 1989 Executive Vice President

g U. S. Nuclear Regulatory Commission

.; Attn:' Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCFE PEAK STEAM ELECTRIC STATION (CPSES)

-DOCKET NO. 50-445'

~ UNIT 1, INSERVICE TESTING PROGRAM PLAN,

" INSERVICE TESTING OF THE PUMPS AND VALVES" REF: " Request for Additional Information Pertaining to the Comanche Peak'

- Steam Electric Station Unit 1 Inservice Testing Program," from C. I.

. Grimes to W. J. Cahill, Jr.,- dated May 31, 1989 Gentlemen:

In accordance with the-requirements of 10CFR50.55a(g), enclosed are two (2)1.

copies of the CPSES, Unit 1. Inservice Testing (IST) Program Plan, Revision 3.

A copy of the IST Program Plan has also been sent to the Region IV office, the NRC Rt:sident Inspector, the Texas Department of Labor and Standards,' and the Hartford Steam Boiler.

.This Unitol, IST Program Plan, Revision 3, supersedes Revision 2 in its entirety. -Please destroy and discard. previous revisions or drafts currently in your possession. . Revision 3 provides clarifications and' revisions in.- ,

response to the.NRC Staff request for additional information referenced' above. i This revision also' reflects plant changes occurring since the last submittal, various editorial changes, valve additions and deletions, and new or revised relief requests.- Due to the extent of these changes, TU Electric decided to publish Revision 3 of the plan without revision bars. However, in order to q aid.the NRC in-performing its review, revision bars have been added in the _j right-hand margin of the enclosed copies. 1 J

The Unit 1. IST Program Plan, Revision 3 is complete with the exceptions of j any additional relief requests discovered during the performance of the j testing activities.

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MS2Ess BE$yf /Wt1 A 1 I \

400 North Olive Street LB 81 Dallas, Texas 73201

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- TXX-89565

August 21, 1989 Page 2 of.2 TU; Electric has completed she review and evaluation of the Open Items which

- resulted from the meeting held among the NRC, CASE, and TU Electric on July 19'and 20, 1989. A. summary of the meeting discussion and the responses to these Open Items, with applicable. comments / justification to support conclusions, are oelineated in the attachment. The attachment format includes the original NRC question and comment, a summary of the discussion as provided by the NRC during the working meeting, and TV Electric's Response provided to close the issue.

Sincerely, E .

t William J. Cahill, Jr.

DAR/vid

Attachment:

Responses to the Open Items

Enclosure:

CPSES Unit 1 Inservice Testing Program Plan, Revision 3 c Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

Texas Department of Labor and Standards Boiler Division E.' O. Thompson State Office Building-P. 0. Box 12157, Capitol Station l Austin, Texas 78701 Attn. George Bynog Hartford Steam Boiler 15415 Katy Freeway Houston, Texas 77094 Attn. Tom Barbara I

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Attachn nt to TXX-89565-August 21. 1989

'Page l'of 8' TU ELEi;TRIC'S RESPONSE.TO THE

< REQUEST FOR ADllITIONAL INFORMATION PERTAINING TO THE COMANCHE PEAK STEAM ELECTRIC STATION-UNIT 1 INSERVICE TESTING PROGRAM OPEN ITEMS FOR THE LICENSEE q

1. VALVE TESTING PROGRAM A. General Questions and Comments

7. The NRC staff positions regarding limiting values of_ full-stroke times for power operated valves are explained in detail in Generic Letter 89-04. " Guidance on Developing Acceptable Inservice Testing Programs."

Are the Comanche Peak Methods;for the determination of limiting values of full-stroke time in compliance with these NRC staff positions?

Discussion:

The CPSES IST ' Pl an utilizes reference . values in lieu of stroke time trending- as described in Relief Request V-2. ' Deviations from

, the fixed reference values are evaluated to determine a valve's acceptability for continued operation. The evaluation criteria will be contained in the applicable procedures and the results will be documented with the data.

CPSES utilizes reference values of full-stroke time, alert values based on these reference values, and limiting values of full-stroke time. However, the limiting values of full-stroke time are currently based on system operability requirements.

The Code requires the owner to specify the limiting value of full-stroke time for each power operated valve. The NRC staff position is that the limiting value of full-stroke time should be based on the valve reference or' average stroke time of a valve when it is known to be in good condition and operating properly. The limiting value should be a reasonable deviation from this reference stroke time based on the valve size, valve type, and actuator type. The deviation should not be so restrictive that it results in ~ a valve being declared inoperable due to reasonable stroke time variations. When the Technical Specification or safety analysis limit for a valve is less than the value l

established using the above guidelines, the Technical

Specification or safety analysis limit should be used as the l limiting value of full-stroke time. When the Technical L

Specification or safety analysis limit for a valve is greater than l

the value established using the above guidelines, the limiting value of full-stroke time should be based on the above guidelines l instead of the Technical Specification or safety analysis limit.

This is an OPEN ITEM for the licensee.

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'Attachrnt to:TX'X-89565 August 21, 1989-Page.2 of 8 TU ELECTRIC'S Response:

-The stroke times have been removed from the valve tables in the CPSES IST Plan. The TV Electric procedure for inservice. pump and-valve testing will be revised to add a table that lists' valves-to be exercised, the Technical Specification' stroke time limit ' for each valve listed, and the limiting value of full stroke ~ time which will be determined in accordance with Generic Letter 89-04 (i.e., based on the valve reference value).

D. Main Steam. Reheat. and Steam Dump System

3. How is a full-stroke to the open position verified quarterly for valves 1-MS-142 and -143? What testing is performed. to verify the closure capability of these valves during cold shutdowns?

Discussion:

The full-stroke of valves 1-MS-142 and 1-MS-143 to' the open position during quarterly testing performed by the passage of main steam through one check valve to operate the turbine driven auxiliary feedwater pump.

One check valve will be disassembled during refueling outages in lieu of a cold shutdown closure test. A suitable relief request '

will be provided in the CPSES IST Plan to address this activity.

The licensee will evaluate whether the steam flow through this valve is equal to or greater than the accident- required steam flow.

The NRC staff position is that valve disassembly and inspection can be used as a positive means of determining that the valve's disk will full-stroke exercise open or of verifying closure capability, as permitted by IWV-3522. However, to grant relief which allows this testing to be performed at a refueling outage frequency, the licensee must demonstrate that it is impractical to perform the Code required testing quarterly, and at a cold shutdown frequency. In order to grant relief which allows this testing to be done on a sampling basis, the licensee must also demonstrate that all other means of testing are impractical, and that it is burdensome to disassemble all valves each refueling' outage.

TV ELECTRIC'S Response:

These valves have been added to the CPSES IST Plan to be full-stroke tested to the open position quarterly by passing steam flow, which is equal to or greater than the accident required flow, through the valve and tested to closure during cold shutdown as defined in the CPSES IST Plan. .

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Attachtent to TXX-89565'

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LAugust- 21, 1989 Page'3 of 8 E. Auxiliary Feedwater System

.3. Do the following check valves perform safety functions in the closed position'to prevent back flow of high temperature feedwater and/or to prevent diversion of flow if an auxiliary feedwater pump is not operating?

1-AF-075 1-AF-078 1-AF-083 1-AF-086 1-AF-093 1-AF-098 1-AF-101 1-AF-106 Discussion:

In addition to providing an auxiliary feedwater flow path to the steam -generators, these check valves also perform a safety function in the closed position. Therefore, a requirement to test these valves in a manner that proves the disk travels to the seat promptly on the cessations or reversal of flow will be added to the CPSES IST Plan. Verification' that 'the valve is in the closed position will be by positive means (such as pressure, temperature, or radiography) on a ccid shutdown frequency. No additional testing needs to be performed unless there is._ an indication that the closure capability of a valve is questionable, than the valve-must be declared inoperable and either be disassembled and visually- inspected, or be repaired, or replaced prior to . being returned to service.

The licensee should determine the maximum back leakage through these valves that the auxiliary feedwater system could tolerate.

This maximum quantity of back leakage should be incorporated into back leakage testing on these valves. Further, the licensee should incorporate a surveillance monitoring system. This is an OPEN ITEM for the licensee' .

TU ELECTRIC'S Response:

It is the owner's responsibility to define the ASME Section XI valve category for each valve to be tested. Check valves, for which seat leakage is not limited to a specific maximum amount by Technical Specifications or the FSAR, are categorized as "C" only in the CPSES IST Plan. Verification of closure will be by positive means.

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. Attachnnt'to TXX-89565 August 21,.1989 Page.4 of 8..

F. Component Cooling t'cter. System

1. Do vaives 1-LV.-4500,.-4501, and -4501-1 perform a safety function? 'Do these valves have a required fail-safe' position?

Discussion:

The safety function of'these valves is to provide.make up water to the. component cooling water surge. tank. They are located within seismic category I. classified piping lines. ; The design basis allows operator -action to manually open these valves ~ if they are-unable to open automatically. Therefore, they are not subject to ASME Section XI inservice testing. These valves will receive non-ASME Section - XI fail safe position and exercise surveillance testing.

If a valve- performs an ' active safety function then. Code requirements do apply. The. licensee.will evaluate' whether these valves perform a safety function. This is an OPEN ITEM for the licensee.

.TU ELECTRIC *S Response:

These - valves perform a safety function and testing. requirements have been added to the CPSES IST Plan.

2. What is the safety function of the following valves?

PC/-H116A PCV-H116B XPV-3583 XPV-3584 XPV-3585 XPV-3586 Discussion:

These valves function as control valves for air conditioning units as described in the notes section of the CPSES IST Plan. The licensee will verify that valves PCV-H116A and PCV-H116B do not have a required fail-safe position. The licensee will note the results of this review in the IST plan.

TU ELECTRIC'S Response:

Valves PCV-H116A and PCV-H116B do have a required fail-safe position and fail-safe test requirements have been added to the CPSES IST Plan.

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Attachrent'to TXX-89565 August _21, 1989-Page 5,of 8

'M. Containment Soray System 2 .- Review the safety function oof check valves ICT-047 -048, -063,_and

-064- to determine:if they should be included in the IST program and tested to_the Code requirements.-

Discussion:

l Check - valves . l 1CT-047, -048, -063, and -064 ' provide' mini-flow protection for the containment spray pumps. The piping in the mini-flow line was recently ' upgraded to Class 2 by DMRC No.

'87-1-088. These valves will be added to the CPSES IST Plan 'and tested to'the Code requirements.

The licensee will evaluate methods to verify a full-stroke' test of these valves (there is no flow instrument in the mini-flow line).

TU Electric's Response:

Portable, ultrasonic flow meters or system instrumentation will be used during testing to verify a full-stroke test for these valves.

O. Safety In.iection System-

7. How are valves 1-8818A, -8818B, -8818C, and -8818D verified to individually. full-stroke open during cold shutdowns? Also, provide a -

technical justification for not part-stroke exercising these valves quarterly.

Discussion:

Compliance with Reactor Coolant System technical specifications for' pressure isolation valves requires a leak test each time these valves are disturbed. Therefore, deferral of any testing to cold shutdown conditions was specified to collect meaningful data and to verify operability when the valves could be leak tested using the SI system test header.

The full stroke of valves 1-8818A, B, C. and D can be verified by monitoring flow and pump operating parameters to baseline condition. The failure of one check valve in each parallel branch to open would alter system resistance character # ctics and result in a change in pump operational parameters.

The NRC staff position is that a full-stroke of each valve must be individually verified. The licensee will evaluate the methods of individually verifying the full-stroke of each valve. This is an OPEN-ITEM for the licensee.

TU Electric's Response:

1 These valves have been added to the CPSES IST Plan to be partial-stroke tested during cold shutdowns (as defined in CPSES IST Plan)

! and full-stroke tested during refueling outages utilizing test equipment to quantify flow in the parallel branch injection lines, b

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Attach = nt to'TXX-89565 August 21, 1989 Page.6 of 8 P. Chemical and Volume Control System

1. Provide a detailed technical justification for not testing valves 1-8153 and -8154 quarterly to the Code requirements.

Discussion:

The Chemical and Volume Control System valves 1-8153 and -8154 are

not required to be tested to ASME Section XI requirements. These normally closed, fail closed valves- constitute the pressure boundary between the Class 1 RCS and Class 2 excess letdown line, per ANSI N18.2a-1975. These valves - are ' not high/ low pressure system _ interfaces and are not listed as RCS pressure isolation valves in Technical Specification Table 3.4-1, Note that the penetration valves 1-8112 and 1-8100 are tested to ASME Section XI requirements.

The licensee will. either identify these valves as non-safety-related in the IST program or will delete them from the program.

TV ELECTRIC'S Response.

These valves' have been added to the CPSES IST Plan to be full-stroke tested quarterly.

2. Table'16 of the Comanche Peak IST program identifies the following check valves as pressure boundary isolation valves. Pressure boundary isolation valves have a safety function in the closed position.

Valves which are normally open, or may be required to open, during plant operation which have a safety function in the closed position are not passive valves. Provide a detailed technical justification for not testing these valves to the Code ~ requirements.

1-8378A 1-8378B 1-8378C 1-8378D 1-CS-8350A 1-CS-8350B 1-CS-8350C 1-CS-8350D 1-CS-8367A 1-CS-8367B 1-CS-8367C 1-CS-8367D Discussion:

The response for these valves is similar to the response provided in 1.0.1 above [the response to Question 1 of Item 1.0 in the ,

reference, " Chemical and Volume Control System"]. These valves i are at the Class 1 RCS to Class 2 CVCS interface per ANSI N18.2a- 1 1975. and unlike the valves listed in Technical Specification Table 3.4-1.. are not in high/ low pressure system interfaces.

The licensee will either identify these valves as non-safety-related in the IST program or will delete them from the program.

TU ELECTRIC'S Response:

l L These check valves have been added to the CPSES IST Plan to be tested in accordance with relief request nos. 16.6 and 16.7.

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X' 'Attachrnt'.to TXX-89565-August 21,l1989

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3; . Evaluate whether check valve 1-8381 has a safety function in the open -

l position and should be exercised to the~open position. Also, Table 16 1

should indicate that this valve'is~ exercised to the closed position at-a refueling outage frequency.

Discussion:

.. , The primary function of 1-8381 'is to p'tvide containmentLisolation for the normal charging header. As such, the' valve is Appendix.J

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• tested. The auxiliary spray - valve 1-8145 and check valve ~ 1-CS-

'8377 were added to the CPSES . IST Plan. . therefore, auxiliary spray does require' the operation of '1-8381. This valve will be exercised to the open position.

The licensee will verify that . normal charging flow will full--

stroke exercise this valve.

TV ELECTRIC *S Response:

Full-stroke exercising, in. accordance with Generic Letter 89-04..

of Valve 1-8381 will be accoinplished by normal charging flow.

Q. Safety Chilled Water System

1. Whatisthe~safetyfunctionofvalves1-CH-300,1-CH-301,'andl 1-HV-8720..

Discussion:

The safety function of these valves is to provide make up water to the' component cooling water surge tank. They are located within seismic ~ category I classified piping lines. The design basis allows operator action to manually open these valves if they are unable to open automatically. Therefore, they are not subject to ASME Section XI inservice testing. These valves will receive non-ASME Section XI fail safe position and exercise surveillance testing.

Per NRC staff position, if a valve performs an active safety function then Code requirements do apply. The licensee will.

evaluate whether these valves perform a safety function. This is an OPEN ITEM for the licensee.

TV ELECTRIC'S Response:

These valves perform a safety function and testing requirements have been added to the CPSES IST Plan.

,d* 'Attachwnt to.TXX-89565 m  : August;21, 1989 Page 8 of 8 S. SDent Fuel Pool Coolino System

1. Provide: P&ID - no. 2323-M1-0235 - for our review. Do . valves XSF-003,

-004 -160, . and -180 . perform . a ' safety function? If so, provide a:

technical ' justification for not testing .these valves in . accordcnce with the Code requirements.

Discussion:

1 The NRC staff position is that the Spent Fuel Pool Cooling System pumps and valves should'be included in the IST program, unisss the-licensee . has. safety grade makeup- _ and . building L

ventilation / filtration systems. The licensee will include this system in their IST program. 'The licensee will evaluate the testing currently performed and the testing required by the.. Code.

Relief' request may be submitted for the Code instrument accuracy requirements TU ELECTRIC *S Response:

The. Spent Fuel Pool Cooling System has been reviewed and a determination has been made that these check valves perform a safety function and have been added to the CPSES IST Plan to be full-stroke tested quarterly, i

2. Loss of cooling ' and/or makeap water to the spend fuel pool could result in over heating of spent fuel and the release of fission =

products and radioactive contamination. Therefore, the NRC requires (refer to NUREG-0800,- Section 9.1.3) that safety related cooling be available for the spent fuel pool and that all active pumps and valves in this cooling water supply be included in the IST program' and. be tested to the Code requirements except where specific relief is requested and approved. What safety related cooling is provided to the spent fuel pool? List the components (if any) that will be added to the IST program and identify the testing that will be performed.

Discussion:

The NRC staff position is that the Spent Fuel Pool Cooling System pumps and valves should be included in the IST program, unless the licensee has safety grade makeup and building ventilation / filtration system. The licensee will include this system in their IST program. The licensee will evaluate the testing currently performed and the testing required by the Code.

Relief request may be submitted for the Code instrument accuracy requi rements .

TU Electric's Response:

The spent fuel pool cooling pumps (active valves as described in the response to Question 1 of Item 1.S above) have been added to the CPSES IST Plan to be tested in accordance with the code.

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