ML20248B442
| ML20248B442 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/31/1989 |
| From: | Charemagne Grimes Office of Nuclear Reactor Regulation |
| To: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| NUDOCS 8906090056 | |
| Download: ML20248B442 (14) | |
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Docket No. 50-445; Mr. William J. Cahill, Jr.
Executive Vice President, Nuclear Texas Utilities Electric Company, L. B. 81 Dallas, Texas 75201
Dear Mr. Cahill:
SUBJECT:
REQUEST FOR ' ADDITIONAL INFORMATION PERTAINING TO THE COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 INSERVICE TESTING PROGRAM The staff and its contractor EG46 Idaho, Inc., have reviewed your pump and valve Inservice Testing-(IST) Program, Revision 2, dated March 3,1989 for Comanche Peak Unit 1.
Based on this review, a list of questions and comments have been-generated that are provided in the enclosure.
It is proposed that-a working meeting be h' eld between the staff EG&G Idaho / Inc.
and TU Electric and that-these questions and comments serve as the agenda for this meeting.-
Formal written responses to our questions need not be provided prior to this meeting.
It is required that this meeting be the staff can complete its review of your IST. held _as_early as possible so program.
If your have any-questions regarding this enclosure or when you have established a date for the proposed meeting, please call J. Wilson, our Assistant Director for Projects (30I) 492-3306.
The reporting and recordkeeping requirements contained in this letter affect fewer than ten respondents, therefore OMB' clearance is not required under P. L.96-511.
Sincerely, Chr stopher 'I. Grimes, Director Comanche Peak Project Division Office of Nuclear Reactor Regulation
Enclosure:
List of questions and comments O
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See next page o
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Mr. William J. Cahill, Jr. I cc:
Asst. Director for Inspec. Programs Joseph F. Fulbright Comanche Peak Project Division Fulbright & Jaworski U.S. Nuclear Regulatory Commission 1301 McKinney Street P. O. Box 1029 Houston, Texas 77010 3
Granbury Texas 76048 1
Roger D. Walker j
Regional Administrator, Region IV Manager, Nuclear Licensing J
U.S. Nuclear Regulatory Connission Texas Utilities Electric Company 611 Ryan Plaza Drive, Suite 1000 Skyway Tower Arlington, Texas 76011 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Lanny A. Sinkin Christic Institute Texas Utilities Electric Company 1324 North Capitol Street c/o Bethesda Licensing Washington, D.C.
20002 3 Metro Center, Suite 610 Ms. Billie Pirner Garde. Esq.
Garde Law Office William A. Burchette. Esq.
104 East Wisconsin Avenue Counsel for Tex-La Electric Cooperative Appleton, Wisconsin 54911 of Texas Heron, Burchette, Ruckert & Rothwell Susan M. Theisen 1025 Thomas Jefferson Street, NW Assistant Attorney General Washington, D.C.
20007 Environmental Protection Division P. O. Box 12548, Capitol Station GDS ASSOCIATES, INC.
Austin, Texas 78711-1548 Suite 720 1850 Parkway Place 1
Mrs. Juanita Ellis, President Marietta, Georgia 30067-8237 Citizens Association for Sound Energy 1426 South Polk Jack R. Newman Dallas, Texas 75224 Newman & Holtzinger 1615 L Street, NW E. F. Ottney Suite 1000 P. O. Box 1777 Washington, DC 20036 Glen Rose, Texas 76043 l
George A. Parker, Chaiman Senior Citizens Alliance of Tarrant County, Inc.
6048 Wonder Drive Fort Worth, Texas 76133
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0FFICIAL RECORD COPY
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IDacionura COMANCHE PEAK STEAM ELECTRIC STATION, UNIT I PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS
..a m 1.
VALVE TESTING PROGRAM A.
General Ouestions and Comments 1.
The licensee's definition of passive valves in section 1.5.2.I of their IST program does not conform to the NRC staff definition. A passive valve is one which never has to change its position to perform its safety-related function.
Identify any valves which are currently classified as passive valves which do not conform to this definition.
2.
The licensee states in section 1.5.5 of their IST program that indirect evidence such as a change in system pressure, temperature, level, flow,-
or lights may be used to verify the position indication of valves.
Explain how indicating lights can be used to verify that position indication accurately reflects the actual position of a valve.
3.
The licensee's intent in the first sentence of section 1.5.6 of their IST program is unclear.
Provide a detailed clarification of this sentence.
4.
The NRC staff positions regarding check valve testing by disassembly are explained in detail in Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs".
Does the Comanche Peak IST program conform to these positions for all valves tested by disassembly?
5.
If valves are exempted from Appendix J, Type C, leak rate testing in the plant Technical Specifications then relief from leak rate testing is not required unless the valves also have another safety function (i.e., pressure boundary isolation valves).
Refer to relief request V-4.
I
_1 6.
The NRC staff position is that, as an alternative to the Code requirements, valve accumulator series check valves may have their closuroff.spabilityverifiedbypositivemeans(suchaspressure indicatten)lthat at least one of the series valves is closed once every three months. No additional testing needs to be performed unless there is an indication that the closure capability of the pair of valves is questionable, then both valves must be declared inoperable and be repaired or replaced before being returned to service.
In cases where the licensee cannot verify that at least one valve of the pair.is shut on a quarterly basis, both valves must be disassembled and inspected or otherwise individually demonstrated operable each refueling outage.
Both series check valves must tie included in the IST program.. Refer to relief requests V-5 and V-6.
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?
8.
The NRC staff position is that pressure boundary isolatior, valves should be categorized A or A/C in the IST program and be leak rate tested to verify their leak tight integrity.
These valves perform a safety function in the closed position and should be listed as such in the valve tables.
9.
The relief request and cold shutdown justification bases should indicate the negative consequences that make testing at the Code required frequency impractical such as endangering personnel, damaging equipment, or resulting in a plant shutdown.
B.
Service Water System 1.
Is position indication verified for valve 1-HV-4286 in accordance with IWV-33007 2
2.
Review the safety function of valves 1-SW-14 and -48 to determine if they should be included in the IST program and tested to Section XI requirements.
3.
Review the safety function of valves 1-SW-84 and -85 to determine if they should be included in the IST program and tested to Section XI requirements.
4.
Provide a more detailed technical justification for not full-stroke exercising valves 1-HV-4395 and -4396 during cold shutdowns.
Refer to relief request 1.2.
5.
Provide the P& ids showing valves CPI-SWVAVB-013, -023, -033, and -043 for our review.
How are these valves verified to full-stroke to the open position?
C.
Feedwater System 1.
Provide a more detailed technical justification for not exercising valves 1-FV-2181, -2182, -2183, and -2184 quarterly during power operation.
2.
Provide a more detailed technical justification for not exercising the following valves quarterly during power operation.
The licensee should include the specific negative consequences of testing these valves quarterly. Also, provide an explanation for not including valve 1-HV-2187 in the cold shutdown justification for these valves.
1-FV-2181 1-FV-2182 1-FV-2183 1-FV-2184 1-HV-2185 1-HV-2186 1-HV-2188 3.
Provide the justification for not including valves 1-HV-2156 and -2157 in the IST program and testing them to Section XI requirements.
3
4
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D.
Main Steam. Reheat. and Steam Dumo System What is f safety function of the following valves?
1.
{
c l-HV-2401A 1-HV-2401B 1-HV-2402A 1-HV-2402B 1-HV-2403A 1-HV-24038 1-HV-2404A 1-HV-2404B i
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2.
What testing method is employed to exercise the following check valves to the closed position quarterly? Refer to relief request V-5.
1-MS-680 1-MS-681 1-MS-682 1-MS-683 1-MS-684 1-MS-685 1-MS-686 1-MS-687 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?
E.
Auxiliary feedwater System 1.
Provide a more detailed technical justification for not full-stroke exercising valves 1-HV-2480, -2481, and -2482 during cold shutdowns.
Refer to relief request 1.2.
2.
The NRC staff positions.regarding full-stroke testing of check valves are explained in detail in Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs".
How are the following valves verified to full-stroke to the open position quarterly during power operation?
l-AF-014 1-AF-024 1-AF-032 1-AF-038 1-AF-051 1-AF-065 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?
)
j 1-AF-075 1-AF-078
?.-AF-083 1-AF-086 1-AF-093 1-AF-098 1-AF-101 1-AF-106 4
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e F.
Connonent coolina Water System 1.
Do valves 1-LV-4500, -4501, and 4501-1 perform a safety function? Do these valves have a required fail-safe position?
2.
What is the safety function of the following valves?
PCV-Hil6A PCV-H116B XPV-3583 XPV-3584 XPV-3585 XPV-3586 3.
Review the safety function of vacuum breaker CPI-CCVBST-01 (P&lD 2323-MI-0229 coordinates C-1) to determine if it should be included in the IST program and tested to the Code requirements.
4.
What are the negative consequences of testing valves 1-FV-4650A and
-4650B quarterly during power operation?
5.
Review the functions of valve 1-CC-1067 to determine if it should be
~
categorized A/C.
Provide a justification for not testing this valve in accordance with the requirements of IWV-3510. Also, provide the P&ID showing-this valve.
6.
Valves 1-CC-1075, -1076, -1077, and -1078 cannot be located with the P&ID number and coordinates given.
Provide a P&ID showing these valves.
7.
Provide a more detailed technical justification for not testing the following valves to the Code requirements quarterly and during cold shutdowns.
1-CC-646 1-CC-657 1-CC-687 1-CC-694 1-CC-1075 1-CC-1076 1-CC-1077 1-CC-1078 G.
Review the functions of valve 1-RC-036 to determine if it should be categorized A/C.
5
H[ Demineralized and Reactor Water System 1.
ReviewIthe functions of valve'l-DD-430 to determine if it'should be categorized A/C.
2.
Provide P&ID number INE-M1-0241-01 for our review.
I.
Vents and Drains System - Containment Buildina.
1.
Review the functions of valve 1-VD-907 to determine if it should be categorized A/C.
2.
Provide a technical justification for not fail-safe testing valve 1-HV-5157 quarterly.
J.
Process Samalina System 1.
Review the functions of valves 1-PS-193, -194, -195, and -196 to determine if they should be categorized A/C.
K.
Liauid Waste Processina System 1.
Review the functions of valves IWP-7176 and -7177 to determine if they should be categorized A/C.
L.
Ventilation Chilled Water System 1.
. Review the functions of valves ICH-271 and -272 to determine if they should be categorized A/C.
2.
What are the negative consequences of testing valves 1-HV-6082, -6083, and --6084 quarterly during power operation?
M.
Containment Soray System 1.
How are valves CPI-CTVBCA-01 and -02 verified to full-stroke open quarterly?
6 a________--_-___
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2.
Review the' safety function of check valves ICT-047, -048, -063, and -064 to determine if they should be included in the IST program and tested to m:..
the Code; requirements.
e[
3.
Would full-stroke exercising of valves 1-8716A and -87168 quarterly during power operation result in a violation of the Comanche Peak licensing basis, as discussed in IE Information Notice No. 87-0l?
N.
Safety Iniection System 1.
Provide a more detailed technical justification for not exercising valve 1-8924 quarterly during power operation.
2.
Provide a more detailed technical justification for not exercising check valve 1-8969A quarterly during power operation.
Refer to relief request 15.3.
Y 3.
Branch Technical Position RSB 5-1 establishes requirements for taking reactor plants from powe_r_ operation to cold shutdown using only safety-grade equipment. To comply with this position, credit is normally taken for the safety injection accumulator vent paths and/or the accumulator motor operated isolation valves.
Provide a technical justification for not testing valves 1-8808A, -88088, -8808C, -88080, and 1-HCV-943 to the Code requirements.
4.
Provide a more detailed technical justification for not exercising check valves ISI-166, -167, -168, and -169 during cold shutdowns.
Refer to i
relief request 15.8.
5.
Would check valve 1-SI-8968 ever be opened during normal operation?
If so, it is not a passive valve and must be exercised according to the requirements of IWV-3522.
I l
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6.-
Review the safety function of the following valves to determine if they j
should be. included in the IST program and tested to the Code i
requirements.
1-8875A 1-8875B l-88750 1-88750 1-8878A 1-88788 1-8876C 1-88780 7.
How are valves 1-8818A, -8818B, -8818C, and -88180 verified to individually full-stroke open during cold shutdowns? Also, provide a technical justification for not part-stroke exercising these valves quarterly.
t 8.
Provide a detailed technical justification for not part-stroke exercising the following check valves quarterly using the SIS test header.
Refer to relief requests 15.1, 15.7, and 15.8.
1-8922A 1-89228 1-SI-8819A I
l-SI-8819B l-SI-8819C 1-SI-8819D 1
1-SI-8905A 1-SI-8905B l-SI-8905C 1-SI-8905D 9.
Reduction in redundancy is not an adequate justification for not testing in accordance with the Code.
Provide a detailed technical justification for 'not testing valves 1-8923A and -89238 quarterly during power operation.
10.
Provide a more detailed technical justification for not exercising check valves 1-8958A and -89588 quarterly during power operation.
Refer to relief request 15.17.
O.
Chemical and Volume Control System 1.
Provide a detailed technical justification for not testing valves.1-8153 and -8154 quarterly to the Code requirements.
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 8
1
.e
~
which are normally open, or may be required to open, during plant l
operation which have a safety function in the closed position are not passiveNalves. Provide a detailed technical justification for not
. testing;}hesevalvestotheCoderequirements.
1-8378A 1-8378B l-8378C 1-83780 1-CS-8350A 1-CS-83508 1-CS-8350C 1-CS-83500 l
1-CS-8367A 1-CS-83678 1-CS-8367C 1-CS-83670 3.
Evaluate whether check valve 1-8381 has a safety function in the open position and should be exercised to the open position. Also, Table 16 should indicate that this valve is exercised to the closed position at a refueling outage frequency.
4.
Evaluate whether check valves 1-8481A and -84818 have a safety function in the closed position to prevent diversion of safety injection flow through an idle pump.
5.
Does valve 1-FCV-1118 have a required fail-safe position? If so, it should be included in the IST program and tested to Section XI requirements.
6.
Review the safety function of valves XCS-037 and -041 (check valves in the boric acid pump recirculation lines) to determine if they should be included in the IST program and tested to the Code requirements.
P.
Safety Chilled Water System 1.
What is the safety function of valves 1-CH-300,1-CH-301, and 1-HV-6720?
Q.
Containment Ventilation System i
1.
Do valves XHV-5526, -5529, -5579, and -5580 perform a safety function in the open position?
If so, provide a technical justification for not testing these valves in accordance with the Code requirements.
2.
Provide a more detailed technical justification for not testing the valves listed in relief request 18.1 during cold shutdowns.
9 I
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R.
Sonnt Fuel Pool Coolina 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 accordance with the Code requirements.
2.
Loss of cooling and/or makeup water to the spent 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 7
identify the testing that will be performed.
2 S.
Emeroency Diesel Generator System 1.
How is a full-stroke of the following valves verified? '
l 1D0-004 100-005 100-016 1D0-017 100-049 100-050 2.
How is a full-stroke of vacuum breakers 100-299 and -300 verified quarterly.
1 1
10
y-a 2.
PUMP TESTING PROGRAM d
1.
The NH(staff agrees that measurement of pump vibration velocity is a superiedulethodofdetectingpumpdegradation,therefore, vibration measureNmts may be made in velocity units in lieu of displacement units. However, to utilize a vibration velocity program for pumps requires the approval of a relief request that describes in detail all aspects of the proposed program (e.g., instrument accuracies, measurement locations, limits). The NRC has determined that a pump testing program incorporating all the pump vibration criteria of ANSI /ASME OM-6, Inservice Testing of Pumps, provides an acceptable alternative to the Section XI requirements. The Comanche Peak IST program has not adopted all of the acceptance criteria of OM-6.
Further, the vibration measurement program has not been described in sufficient detail.
2.
Does the testing method proposed in relief request P-1 for the service %
water pumps meet the accuracy requirements of IWP-4110?
3.
How is flow rate measured for the boric acid transfer pumps during quarterly pump testing?
4.
How is flow rate measured for the diesel fuel oil transfer pumps during quarterly pump testing? How are pump flowrate and discharge pressure evaluated to determine pump degradation?
5.
Review the safety function of the service water screen wash pumps to determine if they should be included in the IST program and be tested to the Code requirements.
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