ML20248G313

Forwards Response to Generic Ltr 89-04, Guidance on Developing Acceptable Inservice Testing Programs. Revised Topical Rept PGE-1048 Will Be Submitted by 891117

ML20248G313
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/03/1989
From:	Walt T PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-89-04, GL-89-4, NUDOCS 8910100188
Download: ML20248G313 (5)

Text

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!!!!!E UbflPNW David W. Cockfield Vice President, Nuclear October 3, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1

-U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sirs:

Response to Generic Letter 89-04, Guidance on

. Developing Acceptable Inservice Testing Promersms, Nuclear Regulatory Commission (NRC) Generic Letter 89-04 approves the currently submitted Inservice Testing (IST) Program relief requests for the Trojan Nuclear Plant provided Portland General Electric Company (PCE) reviews our program and implementation procedures against the positions delineated in the Letter and confirms in writing our conformance with the stated positions by October 3, 1989. The Letter also requests that changes to the IST Program as a result of the Letter be submitted.to the NRC along with the written confirmation.

6910100168 DR 891003 ADOCK 0500 4 i

' I 121 S.W Salmon Street, Port!and. Oregon 97204

Portlarri General Electric Cuiruziy Document Control Desk October 3, 1989 Page 2 We have reviewed the IST Program and implement ation procedures against the positions delineated in the Generic Letter. The attachment provides our response to each of the positions, with which we are either in conformance or will be in conformance with the completion of the noted actions. Since our review identified changes to our IST Program Topical Report PCE-1048,

" Trojan Nuclear Plant Inservice Testing Progrum for Pumps and Valves Second Ten-Year Interval" is being revised. The revised program will be submitted to the NRC by November 17, 1989.

Sincerely,

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Attachment c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant l

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4 Trojan Nuclear Plant Document Control Desk Docket 50-344 October 3, 1989 License NPF-1 Attachment Page 1 of 3 PORTLAND GENERAL ELECTRIC COMPANY (PCE)

RESPONSES TO CENERIC LETTER 89-04 POSITIONS

1. Full Flow Testing of Check Valves.

The Nuclear Regulatory Commission's (NRC's) position on full-flow testing of check valves is that each tested check valve shall be verified to pass the maximum required accident flow rate. To substs.ntiate the acceptability of any alternative technique for meeting American Society of Mechanical Engineers (ASHE) Code requirements, licensees must document a thorough analysis of the particular situation for the valve of concern, as outlined in the position statement.

Inservice testing (IST) at Trojan had taken credit for full-flow stroking of check valves by passing substantial free flow through the valves. This does not meet the requirements specified in the Generic Letter; therefore, several changes will be made to 1 incorporate the desired testing. Where possible, pump IST procedures will be revised to ensure cach pump is operated at maximum accident flowrate for a portion of the test in order to allow verification of the proper flow rate through the associated check valves. The procedures will be revised by March 21, 1990. A review is in progress to determine the most appropriate actions with regards to testing the boric acid transfer pumps discharge line check valves, the centrifugal charging pumps recirculation line check valves and the emergency core cooling system injection line check valves, except for those noted below. The results of the review will be incorporated into the revised IST Program.

PGE has determined that it is not practical to test the safety i injection accumulator discharge check valves or the first off reactor coolant system cold leg injection check valves to accident flowrates. Therefore, relief requests are included in the revised IST Program in accordance with the guidance provided in the position i statement. f i

2. Alternative to Full Flow Testing of Check Valves. f 1

l l The NRC's position that valve disassembly and inspection is an j acceptable alternative to full-flow testing and that the disassembly j

and inspection may be done on a sample basis for groups of identical j l valves has been incorporated into the revised IST Program. A relief request for the containment spray header check valves adopts this alternative to full-flow testing. One of the two valves will be disassembled and inspected at each refueling outage on a rotating basis.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 October 3, 1989 License NPF-1 Attachment Page 2 of 3

3. Back Flow Testing of Check Valves.

The scope and criteria of check valve back flow testing were reviewed against the NRC's position. As a result, necessary changes are being made to IST Program implementing procedures. The procedure revisions will be completed by March 21, 1990.

4. Pressure Isolation Valves.

PGE has verified that all pressure isolation valves are correctly categorized in the IST Program and are Icak rate tested in accordance with the NRC's position. No changes were necessary.

5. Limiting Values of Full-Stroke Times for Power Operated Valves.

In response to the NRC's position that there are limitations with stroke time as a measure of operational readiness for power operated valves, PGE is incorporating the associated recommendations into a review of the limiting stroke time of all power operated valves in the IST Program. The review will be completed and the appropriate procedures revised by March 21, 1990.

6. Stroke Time Measurements for Rapid-Acting Valves.

Trojan recognizes the problems associated with the stroke time testing and trending of valves with short stroke times. The NRC's position is that measuring. changes in stroke times from a reference value as opposed to measuring changes from the previous test is an acceptable alternative to the rules of ASME Section XI, Subsection IWV. Based on a review of stroke time data at Trojan, a relief request is included in the revised IST Program that requires a reference value to be established for valves which stroke in three seconds or less. The frequency of testing will be increased if a j fixed reference value is exceeded by more than 50 percent.

7. Testing Individual Control Rod i Scram Valves in Boiling Water Reactors (BWRs).

This is not applicable to Trojan which is a pressurized water reactor (PWR).

8. Starting Point for Time Period in Technical Specification (TS) ACTION Statements.

Trojan is in compliance. Trojan's position agrees with the NRC's position that as soon as data is recognized as being within the l

" Required Action Range" for pumps or exceeding the limiting value of

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Trojan' Nuclear Plant DocumentcControl Desk

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I full-stroke time for valves, the associated component must be declared inoperable and the appropriate Technical Specification L action statements entered.

I 9. Pump Testing using Minimum-flow l

Return Line With or Without Flow Measuring Devices.

The auxiliary 'feedwater pumps, centrifugal charging pumps and boric acid transfer pumps are currently tested quarterly on non-instrumented minimum-flow return lines. In accordance with the NRC's position, the auxiliary feedwater pumps will additionally be ..

full-flow tested at cold shutdowns or refueling outages. The d decision on testing of the charging pumps and boric acid transfer pumps is dependent upon the review of- full-flow check valve testing described in Item 1 above; therefore. the final decision has not been made, but will be incorporated into the revised IST Program.

However., PGE is developing an augmented test series for full-flow testing of the emergency core cooling system pumps during refueling outages. l

.10. Containment Isolation Valve Testipg.

All containment isolation valves that are leak tested in accordance with Appendix J are included in the IST Program as Category A or A/C valves. Trojan utilized the NRC's conclusions concerning leakage rate testing by including a relief requestin the revised IST Program stating that containment' isolation valves will be leak rate tested in accordance with 10 CFR 50, Appendix J requirements and the requirements of ASME Section KI, Paragraphs IWV-3426 and  :

IWV-3427(a).

11. IST Program Scope.

The scope of the IST Program was reviewed to ensure that all  !

components, such as pumps a.nd valves, necessary for safe operation l of the Plant were included. Appropriate changes have been made in d the revised IST Program.

LGD/bsh 3566W.0989 l

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