ML20248E992

Discusses Evaluation Completed Re Inservice Testing Program for Pumps & Valves.Based on Evaluation Some Components Not Capable of Being Tested Per Code Requirements.Justification for Alternate Test Methods Included in Attachment 1

ML20248E992
Person / Time
Site:	Fort Calhoun
Issue date:	10/02/1989
From:	Morris K OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-89-793, NUDOCS 8910060157
Download: ML20248E992 (11)

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Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/536-4000 October 2, 1989 LIC-89-793 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 NRC (P. D. Milano) to OPPD (K. J. Morris), dated December 22, 1988

3. Letter from OPPD (K. J. Morris) to NRC (Document Control Desk), dated March 24, 1989 (LIC-89-202)

4. Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," dated April 3, 1989

5. Record of Telephone Communication, OPPD (J. J. Fisicaro) to NRC (A. Bournia) dated May 24, 1989 (RTC-89-035)

6. Letter from OPPD (K. J. Morris) to NRC (Document Control Desk), dated July 3,1989 (LIC-89-584)

Gentlemen:

SUBJECT:

Inservice Testing Program for Pumps and Valves Omaha Public Power District (0 PPD) has completed the evaluation of certain components and their surveillance testing methodologies in accordance with the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI 1980 Edition, Winter 1980 Addenda. This evaluation was requested by the NRC in Reference 2, and committed to by 0 PPD in Reference 3. Additionally, this updated information replaces those similar SER items and their due dates addressed in Reference 6.

Based on this evaluation, some components are not capable of being tested in accordance with Code requirements. Justification for alternate test methods is i

included in Attachment 1. The alternate test methods described in the i attachment will adequately determine the condition of the component (s) thus

! ensuring that the component (s) will mitigate the consequences of a Design Basis l Accident.

l l The technical justifications in Attachment I contain different procedure l implementation dates than thoso submitted in Reference 6. This is due to a l change made in the Procedure Upgrade Program schedule. Specifically, dates were changed because of a methodology which emphasizes that safety related procedures that are required prior to the Refueling Outage are revised first.

Because this effort is a Safety Enhancement Program item, and due to the commitments made at the Regional level of the NRC, OPPD has altered the PJ0060137 ,m oo; hDk ADOCK 05000;p if ro t mpmwnen opponunau

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U.*S. Nuclear Regulatory Commission i LIC-89-793 Page 2 l present allocation of resources which in turn affected the procedural iniplementation dates as follows:

NOTE: Original dates committed to in Reference 6 are shown in boldface type.

SER Item No.

l From Reference 2 OPPD Response From Reference 6 Revised Dates 1,2,3,5,7, " Implementation of the baseline 10/01/90 9, 11, 17-20, reference data into the Surveillance 23 Test, and submittal of the revised IST Program Plan is expected within 2 months after completion of the 1990 Refueling Outage."

4, 6, 8, 10, " Submittal of the revised IST Program 10/01/90 12, 13-16, 21, Plan is expected within 2 months 22, 24-33 after the completion of the 1990 Refueling Outage."

11 " Procedural Implementation for 10/01/90 testing check valves in the Diesel Generator Fuel Oil Transfer Line is expected within 2 months after completion of the 1990 Refueling Outage."

12 " Surveillance Tests will be revised 06/30/90 to record leakage rates... Procedural implementation is expected by February 15, 1990."

17, 23 " Initial testing and evaluation of 10/01/90 this method of testing is expected to be completed within two months after the completion of the 1990 Refueling Outage."

21, 24, 31, 32 " Procedural Implementation is 02/15/90 expected by November 1, 1989."

22* " Procedural implementation is 08/15/90 expected by November 1, 1989."

33 " Procedural implementation to add the 02/15/90 Reactor Vessel Head Vent Valves to Surveillance Test... expected by November 15, 1989."

• Note: In keeping with the SEP commitment to the NRC on the Procedure Upgrade Project, the Safety Related Procedures that are required for use during the 1990 Refueling Outage will be revised first.

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U. S. Nuclear Regulatory Commission

LIC-89-793 L Page 3 If you should have any questions, please do not hesitate to contact us.

Sincerely.

U Owb K. J.' Morris Division Manager Nuclear Operations KJM/pje Attachment c: LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator A. Bournia, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector

Page 1 of 8 ATTACHMENT 1 ITEMS REQUIRING FURTHER TECHNICAL JUSTIFICATION-SER ITEM NO.

12 The licensee should comply with Section XI, Paragraphs IWV-3426 and  :

-3427, when leak testing containment isolation valves. 1 OPPD RESPONSE OPPD's understanding, based on discussions with the NRC, is that trending is required for the Containment Isolation Valves (CIVs). As stated. in Reference 4, under the " Containment Isolation Valve Testing" paragraph, it is not necessary to comply with Subsection IWV-3427(b) .

of the Code. The section pertaining to increased test frequencies for .j valve sizes of- six inches and larger and repairs or replacements over '

the requirements of Subsection IWV-3427(a) of the Code has not been  !

proven useful as stated by the NRC. l e OPPD will comply with Section XI, Paragraphs IWV-3426 and

-3427(a).

a Procedural implementation for establishing trending for the CIV leakage rates is expected by January 1, 1990.

m Surveillance Tests will be revised to record leakage rates for l trending information. Procedural implementation is expected by  ;

June 30, 1990. l l

e The submittal of the revised IST Progran Plan is expected by j October 1, 1990.

SER ITEM NO.

13 The licensee has provided a cold shutdown justification for full-stroke exercising' valves HCV-438A, -438B, -438C, and -438D, Reactor Coolant' Pump Seal and Oil Cooler Component cooling water supply and return, during those cold shutdowns when all Reactor 3 Coo 7 ant Pumps are stopped and the reactor coolant system temperature i is less than 130 0 F. A relief request should have been provided because these valves will not be exercised each cold shutdown since i both of those conditions may not be satisfied each cold shutdowa, and L therefore the exercising interval could exceed that permitted by the Code. However, to avoid confusion, this justification bs been evaluated as a relief request in Item 4.3.1.1. The licensec should correct this error.

1 OPPD RESPONSE l

OPPD concurs with this item and will change the cold shutdown j justification to a Relief Request.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______ l

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Page 2 of 8 a The~ submittal of the revised IST Program Plan, which will include the Relief Request, is expected by October 1,-1990.

SER ITEM NO.

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 RESPONSC Valve PCV-1849 has been replaced with two (2) instrument air supply isolation valves, PCV-1849A (Inboard) and PCV-1849B (Outboard), which are presently tested during Refueling Outages. PCV-1849A and PCV-1849B were added during the refueling and maintenance outage (fuel cycle 12) in 1988 by modification MR-FC-88-11.

These valves serve to isolate instrument air pressure, via penetration M-73, to containment systems. Stroke testing cannot be performed quarterly during operations or cold shutdown with RCS temperature greater than 1300F and RCS not depressurized. These valves cannot be partial-stroked, because they are either fully opened or fully closed.

The closing of these valves could cause a loss of instrument air in containment which could result in the following:

(1) cause fluctuations in the level and pressure control for the pressurizer (PCV-103-1, PCV-103-2),

(2) result in damage to RCP seals, (HCV-241),

(3) disrupt RCS letdown to Chemical and Volume Control System (CVCS)

(TCV-202,LCV-101-1,LCV-101-2),

(4) cause damage to nuclear detector instrumentation (HCV-467A/C),

(5) damage the CVCS ion exchange resins (HCV-425A/C),

(6) cause level fluctuation in the SI tanks' level (HCV-2916, -2936,

-2956 -2976),and 3

(7) cause the loss of the steam generator blowdown valves (HCV-1387A and -1388A).

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Page 3 of 8 The ripple effect caused by the exercise stroking of PCV-1849A/B would be detrimental during power operation or when in cold shutdown with RCS temperature greater than 1300 F and RCS not depressurized.

These valves shall be exercise tested during cold shutdown when RCS temperature is less than 130*F and RCS is deDressurized 'and during each refueling outage.

OPPD concurs with the comments and will change the Cold Shutdown justification to a Relief Request.

s Procedural implementation to add valves PCV-1849A and PCV-1849B to the Surveillance Test is completed.

e The submittal of the revised IST Program Plan, which will include the Relief Request, is expected by October 1, 1990.

SER ITEM NO.

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 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 this item and will change the Cold Shutdown justification to a Relief Request.

e The submittal of the revised IST Program Plan, which will include the Relief Request, is expected by October 1, 1990.

SER ITEM NO.

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.

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Page 4 of 8 OPPD RESPONSE OPPD proposes to verify the full-stroke capability of check valves SI-208,.-212, -216 and -220 during Refueling Outages using a Flow Verification method. The SI tank will be pressurized using nitrogen.

The SI Tank will then be " dumped" to the Reactor Vessel.

Parameters as required, such as SI Tank leve1' decrease versus time, SI tank pressure, and valve differential pressure,- will be measured in order to establish a baseline of reference data. Both check valves from the SI Tank that has'just been emptied will then be disassembled and inspected. If the rl+tk valves are in an acceptable condition, a

" signature" will then be developed by OPPD on which to evaluate the acceptability of the disenarge check valves. If the flow test Procedure is not effective, OPPD will continue to perform periodic sample disassembles.

m Procedural implementation for establishing baseline reference data is expected by January 15, 1990.

m Initial testing and evaluation of this method of testing is expected to be completed by October 1,1990, s Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program Plan is expected by October 1, 1990.

HQIE: This item is to be performed in conjunction with SER ITEM

1. 23 below.

SER ITEM NO, 18 The licensee should full-stroke exercise valves SI-100 and -113 high-pressure safety injection pump suction checks.

OPPD RESFDNSE 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.

Maximum required design flow based on the Safety Analysis will be verified through the check valves using installed instrumentation.

s Procedural implementation for establishing baseline reference data is expected by January 15, 1990.

m Initial testing and evaluation of this method is expected to be completed within two months after the completion of the 1990 Refueling Outage.

Page 5 of 8 m Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program plan is expected by October 1, 1990.

SER ITEM NO.

19 The licensee should full stroke exercise valves SI-135, -143 and -149 containment spray pump discharge. checks during Cold Shutdowns.

OPPD RESPONSI OPPD proposes to verify the full-stroke capability of the CS check valves during Cold Shutdowns that occur more than three months after the valves were last tested (per Code) when system lineup is able to

.be realigned. and during Refueling Outages. Maximum required design flow based on Safety Analysis will be ver.fied through the check valves by using installed instrumentation.

m Procedural implementation for establishing baseline reference data is expected by January 15, 1990.

s Initial testing and evaluation of this methodology is expected to be completed within two months after the completion of the 1990 Refueling Outage.

m Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program Plan is expected by October 1, 1990.

SER ITEM NO.

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 1

l OPPD proposes to verify the full-stroke capability of the SIRWT check valves during Refueling Optages by running the Safety Injection and Containment Spray pumps at required in each header and verifying that the maximum required design flow through the check valves based on Safety Analysis is observed using installed instrumentation.

l s Procedural implementation for establishing baseline raference data is expected by January 15, i990.

m Initial testing and evaluation of this method is expected to be  !

completed within two months after the completion of the 1990 Refueling Outage.

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5 Page 6 of 8 m Implementation of the baseline reference data into the Surveillance Test and submittal of the revised IST Program Plan is expected by October 1, 1990.

SER ITEM NO.

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 using a Full Flow Verification method; the SI tank will be pressurized using nitrogen. The SI Tank will then be " dumped" to the Reactor Vessel.

Parameters as required (such as SI Tank level decrease versus time, SI tank pressure and valve differential pressure) will be measured in order to establish a baseline of reference data. Both check valves 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 0 PPD, to evaluate the acceptability of the other three SI tanks' discharge check valves. If the ficw test procedure is not effective, OPPD wi!1 continue to perform periodic sample disassembles.

m Procedural implementation for establishing baseline reference data is expected by January 15, 1990.

m Initial testing and evaluation of this method of testing is expected to be completed by October 1,1990.

• Implementat'on of the baseline refererec data Sto the Surveillance Tut and submittal of the revised IST Program Plan is expected by October 1. 1990.

fiQTl: This item is to be performed in c'enjunction with SER Item

1. 17 above.

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 IWV-3413(b) requires that stroke time of a power operated valve be measured each time that l

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Page 7 of 8 valve is full-stroke exercised. The licensee's technical justification for measuring stroke time of these valves is unacceptable, therefore, the licensee should stroke time these valves in accordance with Section XI.

OPPD RESPONSE These are the air start valves on the diesel generators. These valves will be alternately tested by Surveillance Test ST-ESF-6 at least quarterly during the diesel generator start test. The stroke times for these valves are considered acceptable if the diesel generator is .

ready for load within the time prescribed in the surveillance test.

These diesel air start valves are 1 1/2 inch screwed end, in line, Grove "Flexflo" valves, Model 870NK. This type valve does not have an external operator (actuator) and is totally enclosed. The open/close position of this type valve is a function of the pressure differential on a flexible tube against a slotted cylindrical' core. An air relay valve in the pneumatic start circuit provides the pressure source subsequent to the air motor pinion gears engaging the engine gear.

Thus, the start valve provides the motor force through the upper and lower air motors to crank the engine.

Due to the unique construction of the Grove "Flexflo" valve, it does not lend itself to the traditional stroke time testing concept (valve stem movement).

Measuring the opening / closing time of the air start valves would be impractical because of the following:

(1) internal accommodations for the flexible tube movement is not  ;

provided (2) totally enclosed, visual novement is not observable (3) opening / closing is almost instantaneous depending on the differential pressure (4) devising a scheme to measure air pressure changes indirectly is  !

impractical due to the almost instantaneous operation of the l valves Use of the Surveillance Test ST-ESF-6 to indirectly verify that the air start valves are functional is an acceptable alternative to a  :

direct stroke timing test. The monitoring and trending of diesel j generators start times will provide indication of valve degradation  ;

and changes in valve opening / closing time since any change in the opening / closing time is a factor that could result in longer D/G start times, a 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 complete.

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Page 8 of 8 m Submittal of the revised IST Program Plan is expected by October 1, 1990.

SER ITEM NO.

33 The licensee has provided a Cold Shutdown justification stating that the Reactor Vessel Head Vents, HCV-176, -177 and -178, cannot be exercised during power operation because this 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 I

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 accordance with Section XI.

OPpD RESP 0NSE Reactor Vessel Head Vent Valves HCV-176, HCV-177 and HCV-180 are Target Rock Solenoid Valves. Inadvertent failure of these valves to '

close during testing at power could result in a small break LOCA condition. Testing to date shows the valves open reliably. It is proposed that the Reactor Vessel Head Vent valves will be exercised during cold shutdowns and Refueling Outages.  ;

e 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 February 15, 1990.

m Submittal of the revised IST Program Plan is expected by October 1, 1990.

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