ML20246P508
| ML20246P508 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/24/1989 |
| From: | Morris K OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LIC-89-202, NUDOCS 8903280236 | |
| Download: ML20246P508 (7) | |
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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102-2247 402/536-4000 March 24, 1989 1
LIC-89-202 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 0 PPD (R. L. Andrews) to NRC (Document Control Desk) dated December 15, 1987 (LIC-87-806) 3 3.
Letter from NRC (P. D. Milano) to OPPD (K. J. Morris) dated December 22, 1988 4.
Letter from NRC (G. M. Holahan) to OPPD (K. J. Morris) dated February 9, 1989 5.
Letter from NRC (D. G. Eisenhut) to OPPD (R. L. Andrews) dated November 8, 1985 Gentlemen:
SUBJECT:
Inservice Testing Program for Pumps and Valves, Rev. 3, Fort Calhoun Station As mentioned in OPPD's discussion with P.D. Milano (week of February 20, 1989),
several activities are underway at Fort Calhoun Station which are designed to upgrade the Inservice Inspection Program.
The Fort Calhoun Station Inservice Inspection Program Plan is being upgraded to ensure that it provides a complete, consistent and accurate program by which departments can work.
In addition to the revision of the Inservice Inspection Program Plan, the following activities, which are more specific to the Pump and Valve Test Program, have been completed or are currently in progress.
These activities are essential to the final quality of the Pump and Valve Surveillance Tests, but are time consuming in nature and preclude meeting the 90 day implementation schedule requested by the NRC in Ref. 3.
An Operability Analysis Verification is included as Attachment 2.
OPPD proposes to continue the ISI Program requirements as previously approved (Interim Approval) by the NRC (Ref. 5), until the ISI Program Evaluation and Upgrade has been completed and accepted by the NRC.
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l The following is a summary of activities that impact the implementation of revisions to the pump and valve program at the Fort Calhoun Station.
[QMPLETED ACTIVITIES
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I 1.
Seventy-two valves have either been added to existing surveillance test procedures or had criteria modified as committed to by Rev. 3 of the ISI Program for Pump and Valve Testing (Ref. 2).
2.
CQE instrument air accumulator check valves which have been identified by system walkdowns and design documentation reviews have been added to existing surveillance tests.
Some of these check valves were not committed to be added to the program in Rev. 3.
ONG0ING ACTIVITIES l
1.
Existing surveillance test procedures are being reviewed and revised j
by the Procedure Upgrades Project for format consistency, verbatim i
compliance, technical quality and conformance to NUREG 1369.
2.
The pump and valve surveillance test procedures are being reviewed to ensure compliance to ASME Section XI and proper acceptance criteria per Subsections IWP and IWV.
3.
Verification that the pump and valve procedures can be performed as written is being done.
4.
A review of existing pump and valve surveillance test procedures is being done to ensure that a complete list of pumps and valves exists and complies with requirements of ASME Section XI. This review is approximately 90% complete.
l 5.
New procedures are being developed for position indication verification to ensure that the requirements of IWV-3300 are met.
6.
Design Engineering is presently reevaluating ISI pump and valve acceptance criteria based on the safety analysis and revising documents referencing this acceptance criteria in order to ensure consistency (USAR, Surveillance Tests, ISI Program Plan, Design Basis Documents).
1 7.
A " Checklist" was developed and is being approved to be attached to surveillance test procedures which addresses concerns identified in the OSTI Report 88-201 such as timely performance of retests, establishing adequate communications during test performance, l
necessity of pre-job briefings and clear understanding of the use of N/As.
Part of the procedure rewrite activity is to incorporate the elements of the checklist into the ST procedures.
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U. S.' Nuclear Regulatory Commission i
LIC-89-202 Page 3 8.
Existing procedures are being revised to incorporate changes resulting l
from Rev. 3 of the ISI Program and the associated Safety Evaluation i
Report, except as mentioned in Item 9 below. The following status applies to the approximately 409 components listed in Rev. 3 of the ISI Pump and Valve Program:
79% complete 14% in progress 7% pending clarification of OPPD's position with NRC
- 9. identifies items requiring additional information and l
documentation as well as items requiring further evaluation.
- 10. Special Procedures will be issued to establish pump reference data for use in determining acceptance criteria for revised ISI pump surveillance tests.
Reference 2 identifies the revised ISI Program for Pump and Valve Testing (Rev. 3) which OPPD submitted on December 15, 1987.
Ref. 3 is the Safety Evaluation Report which corresponds to the Fort Calhoun Station Inservice Testing Program for Pumps and Valves through the revisions submitted in Ref. 2.
The Safety Evaluation Report states that " required program changes should be made within 90 days of receipt of this SE" (Safety Evaluation).
OPPD is concerned that complying with the request of the Safety Evaluation Report alone, without completion of the other ongoing activities, would result in a pump and valve test program requiring additional revisions in the future. This would cause confusion and delays in completing the surveillance test upgrade effort.
OPPD would prefer to implement ongoing activities as well as address the concerns associated with the Safety Evaluation Report in parallel.
This would be an approach that would encompass all program attributes at once, rather than an approach which deals with some attributes now and others later.
The approach that we propose would be more efficient and expeditious in finalizing the Pump and Valve Test Program.
Action Plan j
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It is not feasible to accomplish the planned activities within the time frame requested in the Safety Evaluation Report.
Therefore, OPPD requests i
that the following milestone schedule which encompasses all related upgrade activities be accepted for the implementation of the ISI Pump and Valve Test Program.
1.
Design Engineering complete review of valve stroke times by July 15, 1989.
2.
Procedure Upgrades Project complete draft revision of existing ISI program pump and valve procedures by August 1, 1989.
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U..S. Nuclear Regulatory Commission LIC-89-202 Page 4 3.
Issue new procedures for position indication _ verification by August 1, j
1989.
4.
Items requiring further technical justification will be submitted by l
September 1, 1989 (See Section 2 of Attachment 1).
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5.
Complete review of procedures for acceptance criteria and compliance to ASME Section XI by November 1, 1989.
6.
Implement ISI' pump and valve ST changes resulting from Rev. 3 of ISI Program (except items requiring validation during refueling outage and items under pending relief request in Section 2'of Attachment 1) by November 15, 1989.
7.
Completely implement Rev. 3 of the ISI Pump and Valve Program and l
associated SER within 2 months of the completion of the 1990 refueling l
outage (with exception of items pending NRC Clarification).
l 8.
Issue special procedures for establishing pump acceptance criteria by December 15, 1989.
9.
Open items from Section 2 of Attachment I will be implemented within
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90 days of resolution of the item by NRC.
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l OPPD is confident that implementation of the activities as discussed in this transmittal will result in a significant improvement to the Fort Calhoun Station ISI Pump and Valve Program and resolve the comments transmitted in the SER. The schedule presented in this submittal represents an effort to accomplish this work as expeditiously as possible.
Please let us know if you concur with the proposed schedule.
If you have questions, please contact us.
Sincerely, a
/- 7Xyo
. d. M rris Division Manager Nuclear Operations KJM/jak Attachment c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator P. D. Milano, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector
l ATTACHMENT 1 i
This attachment addresses the ISI Program anomalies identified in Appendix C of the Technical Evaluation Report (TER) which was incorporated in the NRC's Safety Evaluation Report dated December 22, 1988.
The attachment is made up of j
two sections.
Section 1 is a list of anomalies where OPPD concurs with the i
staff's position. These positions will be incorporated into the Pump and Valve 1
Test Program. Section 2 identifies anomalies where additional information/docu-
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mentation may be needed to clarify OPPD's position. Other items in Section 2 I
may require further evaluation to define resolution to satisfy NRC concerns.
These evaluations may be due to hardware changes, the need for further clarification, results of investigating the methodology used by other plants or INP0 recommendations. OPPD intends to submit proposals for all the items in Section 2 by July 1,1989. Note: The numbers listed in Sections 1 and 2 will match the anomalies as listed in Appendix C of the TER.
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SECTION 1 1,2,3,5,7,9 OPPD agrees that methods should be developed to measure flow on 1
these pumps. The methodology to be used is currently being i
explored.
Implementation of the results of methodology reviews into applicable Surveillance Tests is expected within 2 months of the completion of the 1990 Refueling Outage.
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4, 10 The request associated with these two items are currently j
included in the Program.
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6,8,26 The NRC staff position was that the requests for relief 3
associated with these items were unnecessary. OPPD concurs and will delete these relief requests.
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11 OPPD agrees to add the emergency diesel generator fuel oil
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transfer pumps and appropriate valves to the Pump and Valve Test-l l
Program.
Procedural implementation is expected by November, 1
1 1989.
Submittal of revised Program Plan is expected within 2
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l months of the completion of the 1990 Refueling Outage.
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16,28,29 OPPD agrees to correct the categorization associated with item
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16 and to identify the applicable paragraph of Section XI from I
i which relief is being requested for Items 28 and 29.
Submittal l
of revised program plan is expected within 2 months of the completion of the 1990 Refueling Outage.
21 OPPD agrees to conduct a sample disassembly / inspection program on valves SI-159 and -160 each refueling outage.
Procedural implementation is expected by November 1,1989.
Submittal of revised program plan is expected within 2 months of the completion of the 1990 Refueling Outage.
I 22 OPPD agrees to partial-stroke exercise valves SI-196, -199,
-202, and -205 during cold shutdowns and full-stroke exercise these valves during refueling outage Procedural implementation is expected by November 1, 1989.
Submittal of revised Program Plan is expected within 2 months of the completion of the 1990 Refueling Outage 24 OPPD agrees to verify closure capability of valves MS-351 and
-352.
OPPD also agrees to describe the test method utilized to demonstrate the full-stroke capability of these check valves.
The proposed test method will be a sample disassembly / inspection program.
Procedural implementation is expected by November 1, 1989. Submittal of revised Program Plan is expected within 2 months of the completion of the 1990 Refueling Outage.
25,31,32 OPPD had proposed to exercise the valves associated with these items during the cold shutdown and refueling outages. The NRC staff's position is that the valves associated with these items be exercised quarterly. OPPD agrees to exercise these valves quarterly.
Procedural implementation is expected by November 1, 1989.
Submittal of revised Program Plan is expected within 2 months of the completion of the 1990 Refueling Outage.
30 OPPD agrees to uniquely identify relief requests and cold shutdown justifications in the ISI Pump and Valve Program.
Submittal of revised Program Plan is expected within 2 months of the completion of the 1990 Refueling Outage.
SECTION 2 10 Clarification is requested by OPPD regarding compliance with Section XI, Paragraphs IWV-3426 and -3427, when leak testing containment isolation valves.
13,15 OPPD intends to submit additional technical justification and a relief request proposing alternate testings of full-stroke exercising the valves associated with these two items during those cold shutdowns when the reactor coolant system temperature is less than 130*F and when all reactor coolant pumps are secured and during each refueling outage.
14 There are now two containment instrument air supply isolation valves (PCV-1849A and B). 0FPD is evaluating the practicality of quarterly full-stroke exercising these valves. A relief request with additional technical justification may be submitted.
i
a 17,23 OPPD is pursuing an alternate method of testing the valves associated with these two items. This alternate method would involve dumping the safety injection tanks to the reactor vessel in. order to demonstrate the full-stroke capability of these valves.
If the alternate method-proves not-to be feasible, a sainple disassembly / inspection program will be implemented.
18,19,20 OPPD is evaluating alternate methods to verify the full-stroke -
capability of the check valves associated with these-.three items.
If the alternate method proves not to be feasible, a sample disassembly / inspection program'will be implemented.-
l OPPD is evaluating an alternate method of testing the stroke 27 time of valves SA-147, -148, -197 and -198. OPPD will provide i
additional technical justification and will submit a relief request as necessary.
33 OPPD is evaluating an alternate method of testing the valves associated with this item since the valves have shown a high probability of sticking open which could result in a small break LOCA condition.
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UNITED STATES
[ b,, 3 NUCLEAR REGULATORY COMMISSION g
jJ evA5HINGTON. D. C. 20555
~,g%..y j Decemoer 22. 1988
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Docket No. 50-285 Mr. Kenneth J. Morris i
j Division Manager - Nuclear Operations i
Omaha Public Power District 1623 Harney Street.
Omaha, Nebraska 68102 1
Dear Mr. Morris:
SUBJECT:
INSERVICE TESTING PROGRAM FOR PUMP 5 AND VALVES, REVISION 3, FORT CALHOUN STATION, UNIT I (TAC 54804)
The Connission, with the technical assistance of EG&G I'daho, Inc., has completed its review of the Fort Calhoun Station Inservice Testing Program (IST) Report for Pumps and Valves through the revisions identified. in your.
I submittal dated December 16, 1987. This report covers the second ten-year interval from September 26, 1983 to September 26, 1993.
Omaha Public Power District (OPPD) is required to comply with the IST program-defined in the referenced letters and in accordance with the relief granted in -
the enciesed Safety Evaluation..The Safety Evaluation incorporates the findings in the enclosed Technical Evaluation Report, dated August 1988, prepared for the Commission by EG8G Idaho, Inc. The stated relief being granted is from the-testing requirements which would be impractica.1 to perform. Certain relief reouests were denied where the proposed ai?arnative testing was considered unacceptabic er where an acequate basis for the relief request had not been includs.c. The IST pregram is acceptable for implementation provided that the i
omissions and inconsistencies identified in Appendix C of the Technical Evaluation Report are addressed within three months of the receipt of this letter.
We have determined that the testing requirements are impractical for the items for which relief is being granted and, pursuant to 10 CFR 50.55a(g)(6)(1),
that the granting of relief is authorized by law, will not endanger life or property or the commen defense and security, and is otherwise in the public intarest. In making this-determination, we have given due consideration to tta burden that could result if those requirements are imposed on your facility.
This letter grants the reliefs identified as granted in the enclosed Safety Evaluation.
f j ow y
, _ _ _ _ _ _ _ ~ _ _ _ _ _ _. - - - - - - - - - -
ATTACHMENT 1 Kenneth J. Morris Program changes, such as aeditional relief reauests or changes to previous relief reouests, snoulo be sucmitted for NRC review but may not be implemented prior to approval by the NRC.
Program changes that 1nvolve additions or celetions of components from the IST program will be provided to the NRC.
Sincerely, 3 A'~b.%
Patrick D. Milano, Project Manager Project Directorate - IV Division of Reactor Profects - III, IV, Y anc Special Projects Office of Nuclear Reactor Regulatien
Enclosures:
As stated cc w/ enclosure:
See next page 1
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2 ATTACHMENT 1 Mr. Kennetn J. Morris Fort Calhoun Station Omana Public Power District Unit No. I cc:
Harry H. Voigt, Esc.
LeBoeuf, Lama, Leiby & MacRae 1333 New Hamosnire Avenue, NW Washington, D.C.
20036 Mr. Jack Jensen, Chairman Washington County Boaro i
of Supervisors i
Blair, nebraska 68008 Mr. Phillip Harrell, Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 309 Fort Calhoun, Nebraska 65023 Mr. Charles B. Erinkman. ": nager Wasnington Nuclear Operat1ons C-E Power Systems 7910 Woodmont Avenue Bethesca, Marylana 20814 I
Regional Administrator, Region IV U.S. Nuclear Regulatory Ccamisi:on Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Harold Borchert, Director Oivision of Radiological Health Oeoartment of Health 301 Centennial Mall, Scutn P.O. Box 95007 Lincoln, Nebraska 68509 W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023 l
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NUCLEAR REGULATORY COMMISSION
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I SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REOUEST FOR RELIEF OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION-DOCKET NOS.: 50-285 INTRODUCTION The Code of Federal Regulaticos,10 CFR 50.55a(g), reouires that inservice testing (IST) of ASME Ccce C ass 1, 2, and 2 pumps and valves be performee in -
accorcance with Section XI of the ASitE Boiler and Pressure Vessel Ccde and applicab~1e addenca, except unere specific written relief has been requested by the licensee and crantec by the Comissicn pursuant tc 10'CFR 55.55a(a)(3)(i),
(a)(3)(ii), or (g}(E)(i).
In recuesting relief, the licensee must demonstrate-that (1) the proposed alternht1ves provide an accepthble level of ouality at.c safety, (2) ccmpliance would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety, or (3) conformance 1
with certain requirements of the applicable Code edition und addenda is impractical for its facility.
TheRegulation,10CFR50.55a(a)(3)(1),(a)(3)(ii),and(g)(6)(1),authcrizes the Ccmission to grant relief from these requiresmnts upon making the necessary findines.
The NRC staff's findings with respect to granting or not granting the relief reouested as part of the licensee's Inservice Testing (IST)
Program are contained in the Safety Evaluation (SE) issued on the licensee's program.
The IST program addressed in this report covers the second ten-year inspection interval frem September 26, 1983 to September 26, 1993. The licensee's program is described in a submittal dated March 19, 1984.
This report is basen on review of the licensee's IST program through :evisions identified in a letter to NRC dated December 16, 1987. The program was reviewed against the require-ments of Section XI of the ASME Code,1980 Edition through the Winter of 1980 Addanca.
EVALUATION The IST program and the request fer relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, EG1G, Idaho, Inc. (EGAG).
In addition, EG8G 'and staff members met with licensee representatives on October 14 and 15, '1987 in a working session to discuss cuestions resulting frem the review. The Technical Evaluation Report (TER),
provided as Attachment '1, is EG&G's evaluation of the ' licensee's inservice
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ATTACHMENT 1
.2-testing program and relief reouests. The staff has reviewec the TER ano concurs with, ano acoots, the evaluations and conclusions contained in the TER. A sunnary of the pump anc valve relief request determinations is presented in Table 1.
The granting of relief. is based upon the fulfillment of the connitments i
made by the licensee in its basis for each relief request and the alternative proposed testing.
Six relief request were denied (TER sections 3.5.2.1, 3.7.1.1,. 4.6.1.1, 4.8.2.1, 4.8.2.3, and 4.10.1.1) and ten reifef requests were granted with certain conditions (TER sections 3.1.2.1, 3.2.2.1, 3.3.2.1, 3.5.1.1, 3.6.2.1, 4.8.1.2, 4.8.2.3,4.8.2.5,4.8.2.7,4.8.2.8).
The licensee should refer to the specific TER sectiun fer a detailed discussion.
The ten conditions are listed in TER t
Appencix C and in addition, Appenoix C lists other IST program anomalies which were identified curing our review.
The licensee should resolve all the items listed in Appendix C in accordance with the staff positions.
Required program changes should be mace within 90 days of receipts of this SE.
CONCLUSION Based on the review of the licensee's IST program and relief reouests, the staff concludes that the IST program, as evaluated and sodified by this SE, will provide reasonable assurance of the operational readiness of the-pumps and valves covered by the IST program to perform their safety related functions.
The staff has determined that granting relief pursuant to 10 CFR 50.55a(g)(6)(1) is authorized by law and will not endanger life or property, or the cosmon defense and security and is otherwise in the public interest.
In making this determination the staff has considered the impracticality of performing the required testing while considering the burden if the requirements were imposed.
The last column of Table 1 identifies the regulation under which the requested relief is granted.
-1 During the review of the ifcensee's inservice testing program, the staff has identified curtain misinterpretations or omissions of Code requirements. These items are summarized in the TER Appendix C.
The IST program for Fort Calhoun Station through revisions identifiec in a letter to the staff dated December 16, 1987 is acceptable for implementation provide that the items noted above are corrected promptly.
Relief requests contained in any subsequent revisions may not be implemented without prior approval by NRC.
Dated: December 22. 1988 Principal Contributor:
K. Dempsey i
ATTACHMENT 1 1
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1 APPENDIX C I
IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW l
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APPENDIX C
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IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW
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Inconsistencies and omissions in the licensee's program noteo during j
the course of this review are summarized below. The licensee should resolve these items in accorcance with the evaluations, conclusions, and guidelines presented in this report.
1.
The licensee should develop a method to measure flow rate for'the -
low pressure safety injection pumps, SI-1A and -18.
(See Item 3.1.2.1.)
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2.
The licensee snould develop a method to measure flow rate for.the containment spray pumos, SI-3A, -39, and -3C.
(See Item 3.2.2.1.)
i 3.
The licensee snould develop a method to measure flow rate for the high pressure safety injection pumps, SI-2A, -29, and.-2C.
(See Item 3.3.2.1.)
'k 4.
The licensee should calculate pump inlet pressure for the component cooling pumps, AC-3A, -38, and -3C.
(See Item 3.5.1.1.)
j 5.
The licensee should develop a flow monitoring program for the i
component cooling pumos, AC-3A, -3B, and -3C.
(See Item 3.5.2.1.)-
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The NRC staff position concerning the licensee's request for relief-l from observing lubricant level or pressur :a D maponent cooling pumps, AC-3A, -38, and *-3C, is that relief is unnecessary because the bearing design is such that the bearings are totally enclosed and permanently lubricated.
t 7.
The licensee should develop a method to measure flow rate for the boric acid pumps, CH-4A and -48.
(See Item 3.6.2.1.)
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' 3.
The licenseo's reouest for relief from measuring cearing temperature on the raw water pumps, AC-10A, -108, -10C, and -100, is unnecessary because.the pumo bearings are locatec in the mair. flow path.
Section XI, Paragrapn IWP-4310, requires bearing tecoarature measurements on bearings located outside the main flow path.
9.
The licensee should measure flow rate and calculate inlet and differential pressure on the raw water pumps, AC-10A, -108, -10C, and
-100.
(See Item 3.7.1.1.)
10.
The licensee has failed to include rotative speed measurement of the turbine driven auxiitary feedwater pump, FW-10, in the IST program as required by Section XI, Paragraphs IWp-3100 and -4400.
11.
The licensee should include the emergency diesel gei trator fuel oil transfer pumps and appropriate valves in the IST pecqram.
12.
The licensee should comply with Section XI, Paragraphs IWV-3426 and
-3427, when leak testing containment isolation valves.
- 13. The licensee has provided a cold shutdown justification for full-stroke exercising valves HCV-438A, -4388, -438C, and -4380, 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 than 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.
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' ATTACHMENT 1 14.
The licensee should full strone exercise valve PCV-1849, containment instrument air supply iso 3ation, quarterly'in accorcance with Sc: tion 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 Jin Item 4.6.1.1.
The licensee should correct this error.
- 15. The licensee has provided a cold shutdown justification for full stroke exercising valves HCV-206 and -241, reactor coolant pumps seal leak-off isolations, during those cold shutdowns when all reactor coolant pumps are stoppec 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 b6th 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 Ites 4.7.1.1.
The licensee should correct this error.
16.
The following check valves should be categorized A/C instead of A:
SI-194 shutdown cooling injection check SI-197 shutdown cooling injection eneck 51-200 shutdown cooling injection check SI-203 shutdown cooling injection check 51-195 - high pressure safety injection header check SI-198.- high pressure safety injection header check 51-201 - high pressure safety injection header check SI-204 - high pressure safety injection header check SI-208 combined safety injection tank discharge / safety injection check SI-212 combined safety injection tank discharge / safety injection check SI-216 connined safety injection tank discharge / safety injection check SI-220 combined safety injection tank discharge / safety injection check 4
The licensee should correct this categorization.
(See Appencix A-4.1, Items 4.8.1.1, and 4.8.1.2. )
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ATTACH!iENT 1 17.
The licensee snouic cevelop a sample disassembly / inspection program that verifies the full-strate cacao 111ty of valves SI-208, -212, -216, and
-220, comoinen safety injaction tank disenarge/ safety injection enacts, during refueling outages.
(See Item 4.8.1.2.)
18.
The licensee snould full stroke exercise valves SI-100 and -113, l
high pressure safety injection pump suction checks.
(See Item 4.8.2.1.)
19.
The licensee should full-stroke exercise valves SI-135, -143, and -149, containment spray pump discharge checks, during cold shutdowns.
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(See Item 4.8.2.3.)
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20.
The itcensee should verify that valves SI-139 and -la9, safety injection l
and refueling water tank outlet checks, are being full stroke exeretsed curing refueling cutages. (See Item 4.8.2.4.)
21.
The licensee should concuct a sample disassembly / inspection program on valves SI-159 anc -160, containment sump outlet checks, each refueling outage.
(See Item 4.8.2.5.)
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22.
The licensee should partial stroke exercise valves Sl-196, -10
-202, 3
.nd -205, safety injection header checks, during cold shutdowns.
(See Item 4.8.2.7.)
23.
The licensee should develop a sample disassembly / inspection program that verifies the full-stroke capab111ty of valves SI-207, -211. -215, and l
-219, safety injection tank discharge checks, during refueling outages.
(See Item 4.8.2.8.)
24.
The licensee should verify the closure capability of valves Mi-351 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 steam generators would depressurize through the steam line break.
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ATTACHMENT 1
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Additionally, the licensee snould be requirec to describe the test method utilizee to comonstrate the full-stroke capability of these check valves.
- 25. The licensee has proposed to full-stroke exercise and stroke time valves HCV-150 and -151, FORY block valves, during cold shutdowns with the justification that failure would require entering a Limiting Concition 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, FD4/PM, to R. L. Andrews, CPPO,.wnich stated:
The PORV block valves snould be included in the IST program and tested ouarterly to provide protection against a small break LOCA should a PORV fail open.
The licensee should comply with this staff position.
- 26. The licensee's justification to verify closure (their safety position) i of valves SA-137, -138, -187, and -188, diesel generator starting air compressor discharge checks, ts unnecessary because the verification is being performed quarterly and that frequency is in accordance with Section XI requirements.
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- 27. The licensee has provided a cold shutdown justification for not I
measuring the stroke time of valves SA-147, -148, -197, and -198, diesel generator air start. A relief request should have been provided becaust Section XI, Paragraph IWV-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 not measuring 8
stroke time of these valves is unacceptable, therefore, the licensee should stroke time these valves in accordance with Section XI. (See Item 4.10.1.1.)
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ATTACHMENT 1 O
28.
The licensee snould identify the applicable paragraph of Section XI from which relief is being reouestec for all Category B anc C valves in the IST program.
29.
The licensee should identify the applicable paragraph of Section.XI from which relief is being reouested for the following Category A/C valves:
51-208 51-195 51-212 SI-198 SI-216 51-201 SI-220 SI-204 30.
The licensee should uniquely identify all relief requests and cold shutdown justifications in the IST. program.
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 Operation.
Seven days should allow sufficient time for valve repair should a failure occur while testing; therefore, the licensee should test these valves quarterly. (See Appendix A-2.2.)
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 entaring 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 j
Condition for Operation is not an adequate technical justification for not performing valve testing in accordance with Section XI.
(See Appendix A-4.1.)
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ATTACitMENT 1 33.
The licensee has provided a cold snutcown justification that states that the reactor vessel heaa vents, HCV-176, -177, and -178, cannot be exercisea during power operation because that would vent hign pressure and high-temperature reactor coolant to the pressurizer quencn tank.
The quench tank is sized to accommodate the discharge from the pressurizer Code safety valves and/or the PORVs 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 licensee should full-stroke exercise these valves quarterly in accorcance with Section XI.
(See Appendix A-7.1.)
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ATTACHMENT 2 Operability Analysis Verification 9
OPPD has determined that due to recent industry. changes and developments such as those listed below, the FCS ISI Program requires evaluation and upgrading:
1.
Recent technological advances which allow testing and data to be performed / evaluated that was not previously available during the
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initial ISI Program submittal.
2.
Industry experiences have shown the need for'more complete and-useable component and system test methodologies. The effects of these new developments as well as the ability to improve plant safetyLand. reliability has been a driving force.behind OPPD's:
commitment to upgrade and improve the ISI Program.
3.
Relief requests denied by the NRC in the1ISI program' submittal and delineated in the Safety Evaluation Report dated December 22, 1988, have shown the need for further evaluation / upgrading of the ISI Program.
i Thesecond10-yearintervalISIProgram(1983-1993) was given interim 1
approval pending completion of the NRC's detailed review. A detailed review of the ISI Program (submitted December 15,1937) was completed as documented by the issuance of the Safety Evaluation Report-dated.
December 22, 1988. The Safety Evaluation Report granted some relief requests and denied others.
The Safety Evaluation Report also identified additional concerns and recommendations. Components specified in the ISI Program have been monitored and trended using surveillance procedures and methods previously agreed to by.the Commission (Ref. letter dated November 8,1985).
Those components for which relief was requested, but i
denied have been routinely operated in accordance with Fort Calhoun Station approved procedures.
These components generally are exercised without data / documentation being required.
Therefore, based on the above, it is OPPD's position that components currently in the ISI Program and those to be included have been demonstrated to be functionally operable.
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