ML20207F911

Forwards Request for Addl Info Re Proposed Inservice Testing Program for Pumps & Valves Submitted w/841127 Ltr,Including Discussion of safety-related Functions of HPCI Pumps.Meeting Recommended

ML20207F911
Person / Time
Site:	Vermont Yankee
Issue date:	01/05/1987
From:	Rooney V Office of Nuclear Reactor Regulation
To:	Capstick R VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8701060254
Download: ML20207F911 (23)

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• Jcnu:ry 5, 1987 Docket No. 50-271 Mr. R. W. Capstick Licensing Engineer Vermont Yankee Nuclear Power Corporation 1671 Worcester Road Framingham, Massachusetts 01701

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION - IST PROGRAM Re: Vermont Yankee Nuclear Power Station We are reviewing your proposed Inservice Testing (IST) program for pumps and valve testing which you submitted by letter dated November 27, 1984. We find that we need additional information as described in the enclosed questions, to complete our review. We believe that this information could most efficiently be communicated in a meeting between your representatives and our reviewers in -

Region I. I request that you contact me and propose a date for such a meeting.

The reporting and/or record keeping requirements contained in this letter

, affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

l Sincerely, Qr'-S-f C9+1 by Vernon L. Rooney, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

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Kr. R. W. Capstick Vermont Yankee Nuclear Power Vermont u nkee Nuclear Power Corporation Station cc:

Mr. J. G. Weigand Mr. W. P. Murphy, Vice President &

President & Chief Executive Officer Manager of Operations Vermont Yankee Nuclear Power Corp. Vermont Yankee Nuclear Power Corp.

R, 9. 5, Box 169 R. D. 5, Box 169 Ferry Road Ferry Road Brattleboro, Vermont 05301 Brattleboro, Vermont 05301 Mr. Dcnald Hunter, Vice President Mr. Gerald Tarrant, Comissioner Vernor t Yankee Nuclear Power Corp. Vermont Department of Public Service 1671 Worcester Road 120 State Street Framingham, Massachusetts 01701 Montpelier, Vermont 05602 New England Coalition on Public Service Board Nuclear Pollution State of Vermont Hill and Dale Farm 120 State Street R. D. 2, Box 223 Montpelier, Vermont 05602 Putney, Vermont 05346 Vermont Yankee Decomissioning Mr. Walter Zaluzny Alliance Chairman, Board of Selectman Box 53 Post Office Box 116 Montpelier, Vermont 05602-0053 Vernon, Vermont 05345 Resident Inspector Mr. J. P. Pelletier, Plant Manager U. S. Nuclear Regulatory Comission Vermont Yankee Nuclear Power Corp. Post Office Box 176 Post Office Box 157 Vernon, Vermont 05354 Vernon, Vermont 05354 Vermont Public Interest Mr. Raymond N. McCandless Research Group, Inc.

Vermont Division of Occupational 43 State Street

& Radiological Health Montpelier, Vermont 05602 Administration Building 10 Baldwin Street Regional Aoministrator, Region I Montpelier, Vermont 05602 U. S. Nuclear Regulatory Comission 631 Park Avenue i Honorable John J. Easton King of Prussia, Pennsylvania 19406 Attorney General r State of Vermont Mr. D. Caphton, Region I 109 State Street U.S. Nuclear Regulatory Commission Montpelier, Vermont 05602 631 Park Avenue John A. Ritscher, Esquire Ropes & Gray 225 Franklin Street Ellyn R. Weiss 4 Boston, Massachusetts 02110 Ij" " 8' [s fe , N.W.

. Suite 430 '

f . Washington, DC 20009-1125 i

Request for Additional Information Concerning the Vermont Yankee Inservice Testing (IST) Program for Pumps and Valves

(

Reference:

letter Warren Murphy to NRR dated November 27,1984.)

The following questions have evolved from the initial staff review of the Vermont Yankee IST Program for pumps and valves, i

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Pumps

1. Service Water Pumps P7-1A-D G191159 Sh-1 The WP appears to be measurable, however, the program's pump testing does not indicate this. The listing should be revised.

2. High Pressure Coolent Injection Pumps G-191169 Sh 2

, HPCI Gland Seal Exhauster HPCI Hot Well Condensate Pump Discuss the safety related functions (shutting down the reactor or in mitigating the consequences of an accident) of these pumps. Provide a detailed technical justification for not incibding the pumps in the program.

3. Standby Liquid Control Pumps Is lubricant temperature measured in the pump crankcase or another location?

4. Core Spray Pumps P46-1A/B During outage testing, is the length of time of the pump run adequate to reasonably assure that no problems are being experienced as a result of bearing heating? Note-this comment is applicable to the other pumps in the program that similarly have bearing temperatures that can not be directly measured.

5. RCIC Condensate and Vacuum Pumps G191174 Sh. 2 Discuss the safety related functions of these pumps. Provide a detailed technical justification for not including these mps in your program.

6. RBCCW Pumps G191159 Sh. 3 The program listing for the reference drawing shows sheet 1, the pumps are on sheet 3.

7. Emergency Diesel Generator Auxiliaries G191162

a. The diesel engine's fuel pump and clean oil return pumps are missing from the program.

b. In relief Request Basis P-12. Fuel Oil Transfer Pump Bearing Temperature measurement per IWP-3300, regarding alternate testing, is it possible to check bearing temperatures by pumping to the 5000 gallon Fuel Oil Day Tank 41-1A for the heating boilers?

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a 8. Pump RRU-18 and G 191175 Sh. 1 Two check valves 16-19-101 (E-15) and 16-19-103 What are the safety related functions of the pump and two check valves?

9. What is the technical justification for not including the Torus to Drywell pumpback system in the IST program? (No drawings provided).

G-191177 Sh. I

10. Describe any functions that the Drywell Floor Drain pumps P-11 A/B and the Drywell Equipment Drain pumps P-15-A/B have in shutting down the reactor or mitigating the consequences of an accident.

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Valves V-4* Service Water System Dwg. G191559 Sh.1&2

1. Valve V 70-1A-D and RRB-V1 (B,H-3)

a. The relief request lacks specificity regarding frequency of exercise testing. The time period should be specified.

Reference IWV-3521. (Note: 24 months is normally the maximum relief that the staff will consider.)

General Note applicable to all relief requests: Relief request should clearly specify what specific relief is being requested including the detailed technical basis for the specific relief being requested. Revise relief requests accordingly,

b. Is there a leakage requirement established for these valves in the closed position? Is prompt closure verified?

2. Relief valves in Service Water System Provide detailed justification for not including the service water system's relief valves in the IST program and testing in accordance with IWV-3510.

3. RHR Motor Cooling What is the technical bases for not including: check valves 181 XC (4 total, one for each motor) and Solenoid valves SE-70-4C (4 Total)?

4. Valve V 70-84A and 84 B Reference G191159 Sh. 2) (B and H-3).

What is the safety related function of these valves?

5. Emergency Diesel Generator Cooling

a. Check Valve 70-1 (B-9)

This check valve is not in the program, however, the position of the valve appears to be of safety related importance to assure a heat sink for the emergency diesels and as such should be tested as a Category C valve.

b. Fill Valves On Expansion Tanks SE-70-2A? (Drawing has no numbers) (F-8)

SE-70-2B (C-5)

• The V-numbers used correspond with the VY program numbers.

2 These valves are not in the program, however, appear to have safety importance to assure cooling of the EDGs. The valves should be included in the program and tested.

6. Line 24" SW IB (Dwg. G191159, Sh.1) appears to connect to 8" SW 18B (Dwg. G151159, Sh. 2) at match line A, however, there is no reducer shown. Is there a missing drawing? Also there is no 24" SW IB in the " Piping Line List".

Also the 18" SW 12 line goes to 20" SW-12? Same question?

V-5 Reactor Building Closed Cooling Water

1. Relief Valves G191159Sh.3(A-4)

RBCCW HX's SR 70-1A/B Provide detailed technical justification for excluding these two relief valves from the program.

2. Air Operated Valve (D-8)

LCV-1 Does this valve operate to make up system losses of inventory? Does the valve fail open upon loss of air?

V-7 Service and Instrument Air, Diesel Generator Starting Air System, Dwg. G-191160 Ref. Sh. 7

1. Pressure Relief Valves (unnumbered) on EDG Air Receiver Tanks, one on each tank, four total. (Ref. Sheet 7 of 7)

Provide your detailed technical justification for not including these valves in the IST program and testing per IWV-3510.

2. Check valve unnumbered in line from air receiver to motor pressure switch, one for each air receiver, (Ref. Sheet 7 of 7).

Provide your detailed technical justification for not including these valves in the IST program and testing per IWV-3510.

3. Pressure Relief Valves (unnumbered) on air compressors, two total.

Provide your detailed technical justification for not including these valves in the IST program and testing per IWV-3510.

4. EDG Air Start Solenoid Valves (ColtIndustriesDwg. 1185383)

Provide your detailed technical justification for not including these valves in the IST program and testing per IWV-3400.

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5. Valve V72-78 A-D and V72-80 A-D Dwg. G191160 Sh. 7 Do these valves have to meet a leakage criteria to protect against the loss of receiver redundancy?

6. Relief Request Basis V5 Revise to show compliance with requirements of IWV-3423 regarding adjusting to functional maximum pressure differential value.

7. Instrument Air System Ref. G191160 Sh. 4 What is the safety function of check valves:

Check valve next to V 72-154 and unnumbered (L-6)

V 72-51A V 72-155 (Check valve is next to and unnumbered)

V 72-86A Y 72-868 Y 72-51B V 72-49A V 72-498 V 72-67A (L-17)

V 72-67B

8. Relief Request Basis V6 For Valves V72-89 B/C Dwg/ G191160 Sh. 3 (K-12 and 15)

Relief request as written does not show compliance with exercise testing frequency under IWV-3522. Revise to meet Section XI.

Note: The leak test requirement Ref. RRB-V5 needs to be revised to comply with IWV-3426 and IWV-3427, Analysis of Leakage Rates and Corrective Action, respectively.

l 9. Check Valve V72-103 Dwg. G191160 Sh. 3 What is the basis for specifying the valve to be passive? The valve is categorized as AC, however, the exercise requirements are not specified.

10. Check Valves I

What is the safety related function of these valves?

V-72-70 A/B G191160 Sh. 3 L-17 V-72-26 A/B G191160 Sh. 3 L-12 V-72-26 G/H G191160 Sh. 3 L-11 i V-72-68 A/B G191160 Sh. 3 J-11 V-72-37 A/B 6191160 Sh. 6 L-7)

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4 V-8 Emergency Diesel Generator Fuel Oil System Dwg. G-191162

1. Is valve LCV-3 (D-5) required to operate at anytime the EDGs are responding to an accident condition?

2. Relief Yalves 3A and 3B (C-4)

Provide detailed technical justification for not including these valves in the program and testing per IWV-3510.

3. Two relief valves and four check valves are shown on the drawing at the EDG. Provide you detail technical justification for not listing the valves in the program.

4. Clean Oil Tank (0-10)

a. How is the tank vented?

b. Are there any check valves installed in the pump discharge piping?

5. EDG Lube Oil System What are the drawing numbers that show this system? (No drawings were provided.)

V-9 & 10 Nuclear Boiler G191167

1. Relief Valves SR2-14E-L and RRB V7 (L-11)

Under " Alternate Testing", RRB V7 should also specify exercise testing during refueling outages.

2. Relief Valves SR2-14 A-D (L-11)

Provide your technical justification for not testing these relief valves.

3. Valves V2-37A check) B7 SIA solenoidoperated) C-8 Provide your detailed technical justification for not including these valves (one set for each relief valve).

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4. RRB V 11 For Safety and Relief Valves The VY testing frequency of testing all valves every two refueling outages is more conservative than the Code frequency of testing all valves every five years. However, the relief request does not adequately address the IWV-3513 additional test aspects regarding corrective action to be taken in the event a failed valve is identified. The relief request states that additional testing is unreasonable per IWV 3513, however, provides no bases for handling the failure issue. Provide your technical bases for handling the valve failure issue and specify alternate requirements.

5. Feedwater Valves V2-27A F-3 V2-96A H-3 and RRB V8 These valves should comply with the analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and i IWV-3427, respectively. The relief request should be revised accordingly.

6. Feedwater Check Valves V2-28 A/B (F-4)(H-4) and RRB V9 Note: Valves have a safety related function to close as an isolation valve and a safety function to open upon HPCI &

RCIC injections. No relief from quarterly exercise testing was included. Do you intend to exercise quarterly?

These valves should comply with the analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and IWV-3427, respectively. The relief request should be revised accordingly.

7. Process Sampling Valves l V2-39 L-4)

! V2-40 L-3)

RRB-V8 These valves should comply with the analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and IWV 3427, respectively. The relief request should be revised accordingly. ,

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8. Steam Drain Valves:

V2-74 D-10 V2-77 D-13

a. -Provide your detailed technical justification for not exercising and stroke time testi..g these Category A valves.

b. The valves must comply with the Analysis of Leakage Rates and. Corrective Action Requirements, Paragraphs IWV-3426 and 3427, respectively.

c. The relief request RRB-V8 needs revising accordingly.

9. MSIVs V2-80 A-D D,F,G,H-10)

V2-86 A-D D. F, G, H-13)

a. The valves must comply with the Analysis of Leakage Rates and Corrective Action Requirements, Paragraphs IWV-3426 and 3427, respectively. Revise the relief request RRV-V8 accordingly.

10. Excess Flow Check Valves G191167 SL-23 -

SL-301F -

SL-3018 -

SL-301A -

SL-301E -

SL-978 M-12)

Describe the safety related function of each of these check valves.

11. MSIV Supply Check Valves IA 87 A-D B-12 CA 87 A-D B-10 i Provide detailed technical justification for not including these valves in the program.

These valves appear to assure that the MSIV accumulators remain at pressure in the event of a loss of header pressure. They appear to be Category C valves.

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7 V-11 Core Spray System Reference Drawing G-191168

!. SR 20 A and B Safety Relief Valves Provide a detailed technical basis for not including these valves in the program and testir.g per IWV 35107

2. M0V 12 A and 12 L (Outsidecontainment)

Check Valves V13A and V138 (Iriside containment)

These valves provide the redundant barrier between high and low pressure piping. Provide detailed technical justification for not designating as Category A and leak testing.

3. MOV-V7Aand78(CSPumpSuction)

What function (s) do the valves serve to mitigate the consequences of an accident. (The valves are not in the IST program).

4. Excess flow check valve SL-25 Why is this valve not tested similarly to SL 31 A&B? (Thevalveis not on relief request RRB-V16).

5. Check Valves 33A and 338 (CS pressurizing lines)

Do these valves close to mitigate an accident? Discuss their function.

V-12-14 High Pressure Coolant Injection System (HPCI) G191169, Sh.1

1. Steam Valves and RRB-V17:

V23-15 E-5 V23-16 E-7 The valves must comply with the Analysis of Leakage Rates and corrective Action Requirements paragraphs IWV-3426 and 3427, respectively. Revise the relief request RRB-V17 accordingly.

2. Excess Flow Check Valves:

SL 23-37 A-D or A-L (F, G-5)

Which is correct? The " Valve No." listing appears to have a i

typo. The drawing reflects A-D.

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3. Check Valves and RRB-V20: (N-7)

V 23-61 The relief request basis wording is unclear regarding assuring that the valve exercise test assures exercising the valves to the full open position.

4. Check Valves (K-5)

V 23-12 and V 23-65 These valves need to open to drain condensate and the exhaust steam drain pot. Provide a technical justification as to why the valves aren't exercise tested?

These valves also appear to perform a containment isolation function; if so, should be Category AC and comply with IWV-3426 and IWV-3427.

5. Check Valves (J-3)

V 23-842 and V 23-843 These valves appear to be needed to open during HPCI operation, if so, they should be exercise tested. These valves also appear to perform a containment isolation function, if so, should be Category AC and comply with IWV-3426 and IWV-3427.

6. Relief Valves G-191169 Sh. 2 V 23-34 D-9)

V 23-66 J-12)

Provide detailed technical justification for not having these valves in the IST program, and testing the valves as required by IWV 3510.

7. Air Operated Valve V 23-54 (K-12)

Provide detailed technical justification for not having the j valve in the IST program and designating Category B.

8. Check Valves '

(L-11)

V 23-130 and V 23-131 Provide detailed technical justification for not having these valves in the IST program and designating as Category C valves.

9. Air Operated Valves G191169 Sh. 2 V 23-39 and 40 (M-11)

What is the safety related function of these valves?

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10. Drain Valves G191169 Sh. 1 (H-17 & J-1)

V 23-53A Air Operated H-17 V 23-42 Air Operated J-16 V 23-43 Air Operated J-16 V 23-149 CheckValve) I-16 Provide detailed technical justification for not having these valves in the IST program.

V-15 Control Rod Drive Hydraulic System G191170

1. Yalve V3-181 and RRB-V22 J-21 The relief request needs to incorporate testing at refueling frequency in addition to cold shutdown.

The program's valve listing drawing coordinates should be J-21, not I-21.

2. Valves V13-115 (B-16)

The charging header check valves are active during reactor scrams to aid in control rod inserting and safe reactor shutdown. Provide detailed technical justification for not including these valves in the program.

V-16 Standby Liquid Control System Drawing No. G-191171

1. Relief Valves SR-39A and 39B (G,K-7)

These valves should be designated Category C and tested per IWV-3510.

2. Check Valves V 11-16 and 17 (GandH-2)

Relief Request Basis V24 refers to TS Table 4.7.2.b applicable to containment isolation valves as opposed to component operational readiness testing under Section XI IWV-3400. Provide detailed technical justify for not testing in accordance with Section XI.

V-17 & 18 Residual Heat Removal System G-191172

1. Motor Operated Valves: V 10-17 and RRB V26 G-8 V 10-18 F-8

a. The relief request needs to clearly state the detailed technical basis for the specific relief requested. The relief request basis states that the valves are presently exempted, per Tech. Spec. Section 4.7.2 from leak testing, however a basis for this statement has not been found.

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b. These valves must comply with-the Analysis of Leakage Rates < ,

and Corrective Action Requirstr.ents of the Code paragraphs IWV-3426 and IWV 3427 '

2. Valves: V 10-26A/B ,

(C-7)(C-11)

Same comment as 1.a. and b. above. * -

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3. Valves V10-27A/B ,

'(D6)(D12)

These valves are the first closed gate valves off of the reactor a coolant loops to protect low pressure piping. Provide detailed ).

technical justification for not designating as category A and leak testing. (Reference GDC-54) .

4. Valves V10-31A/B (C,B)-(C-10)

Same coment as 1.a. & b. above. ,

5. Valve V 10-32 (C-9)

Same comment as 1.b. abase.  ;

6. Valve V 10-33 (A-7)

Same comment as 1.b. above. 1

7. Valves V10-34 A/B (E-4)(E-14)

Valves V10-38 A/B (E-4)(E-13) '

These valves are the first normally closed valves coming,from . .

the suppression chamber (Reference GDC-54). Iame coment as ,

1.a. and 1.b. above. - ' .

8. Valves V10-39 A/B ., (D-4)(D-14) p

a. Same comments as 1.a. and 1.b. above. (Note: this is the second valve from containment.)

b. Provide detailed justification for not quarterly stroke testing these valves.

9. Check Valves V10-46 A/B (E-7)(E-11)

These valves are listed as Category C hemvar, they are.the inside containment isoletion valves and should be categorized as AC and leak tested to assure protection of low pressure .,

piping.

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10. Valves V10-89A/B (M-1)(L-17)

Do the valves have a fail safe position and if so, are they ,

exercised to this position?

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11. Valves V10-16 A/B_ (I-6)(I-12)

These valves are the first isolation valves outside containment and as such appear to be Category A as they serve an isolation .

function (Reference GDC-54). Provide detailed justification for not designating Category A.

12. Check Valves V10-19 A-D K-6 & 12 J-6 & 12

a. These valves are the second isolation valves outside of containment and as such it appears these valves should be ,

Category AC and leak tested. '

b. It is not clear (Reference Note 6) that the exercise-testing verifies full opening of these valves.

13. Relief Valves V10-SR-35 A/B -

(D-15)

V10-SR-40 -

V10-SR-72 A/B/C/D -

(K-11)(J-7)(J-11)

V10-SR-80 A/B -

K-14)

V10-SR-86 A/B -

K-14)

V10-RV-210 A/B D-12) D-5)

Provide detailed justification for not designating these valves Category C and testing per IWV-3510?

14. Motor operated Valve V10-20 (H-4)

This valve has a safety function as described in FSAR 4.8.5 "to supply either loop from the pumps in the other loop". Its operational readiness should be verified and, therefore, ,

included in the program.

15. Valves i

V10-15A/B/C/D (K-7) (K-10) (J-7) (J-10)

Are these valves used to bring the reactor to a cold shutdown condition or in mitigating the consequences of an accident? If so they should be included in the program.

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16. Valves y V10-13A/B/C/D (K-8)(K-9)(J9)(J-8)

N. \ Are these valves used to bring the reactor to a cold shutdown

, condition or in mitigating the consequences of an accident? If so they should be included in the program.

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\y V 19-21 Reactor Core Isolation Cooling System (RCIC) G191174 Sh.' 1 i

1. Motor Operated Valves and RRB-V30 V13-15 D-7 V13-16 D-8 3

i The NRC position is that the Category A valve leak rate y requirements are fulfilled by 10 CFR 50, Appendix J, require-ments for CIVs and that relief from the Section XI leak rate

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testing requirements presents no safety problem. However, the licensee must comply with the Analysis of Leakage Rates s

i and Corrective Action Requirements Paragraphs IWV-3426 and

-3427 unles's specific relief is requested from these paragraphs and subsequently granted by NRC. Revise the Relief Request.

2. Check Valve V13-22 and RRBW31 (G-9) c

, Frequency does not include refueling frequency or (24 month '

' maximum).1 Revise relief request and testing frequency.

3. ' Motor (0peratedValveV13-41 (N-10)

%g If this valve serves a containment isolation function with a specified leak rate, it should comply with IWV 3426 and IWV-3427 (reference 1, tem 1.above).

I V 3 4. Chec'k Valve V13-40 and RRB V-33 (N-11)

Relief request basis does not clearly state words to indicate >

full stroke exercise testing is required.

5. Relief Valves G-191174, Sh. 2 i SR-25 -

B-7)

SR-26 I-7)

SR-27 J-14)

Provide detailed technical justification for not including these valves in the program and testing as Category C valves as required by IWY-3510.

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6. Motor Operated Valve V-1 (13-D)

What is the safety related function of this valve?

7. Check Valves (K13&10)

V13-70 and V13-133 Provide detailed technical justification for not including these valves in the program.

8. Air Operated Valves V13-12 L-l'J V13-13 L-10 Provide detailed technical justification for not including these valves in the program.

9. Air Operated Valves G 191174 Sh.1 V13-32 H-17 V13-34 K-17 V13-35 K-17 Check Valve V13-140 (I-17)

Provide detailed technical justification for not including these valves in the program.

10. Check Valves i V13-SSC-10 K-8) l V13-29 J-10 V13-38 K-11

11. RRB-V33 for valve V13-40 t The alternate testing needs to be revised to clearly assure that the valve is full stroke exercised.

V-22 Primary Containment and Atmospheric Control

1. Drywell to Torus Vacuum Breakers G191175 Sh. 1 (J-8)

The program list Valves V16-19-5A-J, however, the drawing indicates A-F and G&H. Which is correct?

2. Relief Request RRB V-36

F 14 This relief request or another needs to address IWV-3420 regarding pressure differential testing at lower than functional differential pressures, IWV-3426 Analysis of Leakage Rates and IWV-3427 Corrective Action.

3. Valves V16-19-12 A/B and RRB Y-38 G191175 Sh. 1 (K and M-16)

The relief request does not address testing at cold shutdown and refueling frequency. Quarterly exercise testing was not specified as a requirement in the valve table.

4. Check Valves G 191175 Sh. 1 (I-11)

V16-19-51 and V 16-19-52 What is the safety related function of these valves?

V-23 Radwaste Systems G191177 Sh. I

1. Valves V20-82, 83, 94, 95 and RRB-V39 The leak testing does not include requirements of IWV-3426 and IWV 3427 for analysis of leakage and corrective action requirements of the Code.

2. Dry Well Sump Check Valves 80A D-2) 80B D-3 90A I-2 90B I-3 Provide detailed technical justification for not including these valves in the program and categorizing as AC.

V-24 Reactor Water Clean Up System G191178 Sh.

1. Valves V12-15 D-2)

V12-18 D-3)

V12-68 C-11) t j These valves are listed as Category B. The valves serve as primary l

containment isolation valves and have a safety function to protect i the reactor core in case of a pipe break in the clean up system.

l They isolate on a reactor water low level. These valves should be Category A and leak tested.

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2. Relief Valves V12-SR-82 F-10 V12-SR-85 D-10 V12-SR-84 G-12 These valves are not included in the program, however, appear to have a safety function to protect the system against over pressurization.

What is the basis for not designating the valves as Category C and testing in accordance with IWV-3510?

3. Check Valve V12-62 (B-5)

This valve appears to be a Category C valve since it functions to close to assure that RCIC flow goes to the core, however, it is not in the program.

V-26 Nuclear Boiler Vessel Instrumentation

1. RRB-V40 Dwg. G-191267 The Code stipulates exercising the valves every 3 months or if the valves cannot be exercised every 3 months during plant operations, the valves shall be full stroke exercised curing cold shutdowns. The relief request for testing does not address the Code required frequency of cold shutdown nor is technical justification provided for not meeting the cold shutdown frequency.

V-27&28 Containment Atmosphere Dilution Dwg. VY-E-75-002

1. General Comment: Valves which are required to operate or function to bring the reactor to cold shutdown conditions or in mitigating the consequences of an accident should be included in the IST program and tested in accordance with requirements of the Code (Reference IWV-1100). If the valve is required to operate under these conditions, testing is required under the Code and any relief requested from this testing must have a technical basis provided for the specific relief requested.

(Also reference to the staff note under item 2. of Primary ContainmentandAtmosphericControl).

Further, the NRC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds or less.

Relief from the trending requirements of Section XI (Paragraph IWV-3417(a) will be given for these valves since variations in stroke times will be affected by slight variations in the response time of the personnel perfonning the tests. However,

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16 the staff does require that the licensee assign a maximum limiting stroke time of 2 seconds to these valves in order to obtain this Code relief.

The relief request bases in RRB 41, 42 and 43 lack specificity regarding the detailed technical bases for the relief requested.

These relief requests need revision.

2. The following valves are designated as passive, however, they serve an active function with the Primary Containment Isolation System (PCIS), therefore, should be designated " Active" and exercised and stroke time tested:

VG-75A-3, 4 J-14)

VG-9 A/B G-12,I-13)

VG-22 A/B B-16,E-16)

NG-11 A/B G-9)

NG-12 A/B I-8)

NG-13 A/B I-9)

3. The following valves are designated for alternate testing in accordance with Appendix J. These valves need to comply with IWV-3426, Analysis of Leakage Rates and IWV-3427, Corrective Action of the Code.

FS0-109-76A/B L-14 VG-23 J-19 VG-26 J-19)

VG-9 A/B G-12,I-13)

VG-22 A/B B-16,E-16)

NG-11 A/B G-9 NG-12 A/B I-8 NG-13 A/B (I-9

4. Technical Specifications Table 4.7.2.b require the following valves to be operable, however, the program does not operability test (exercise or stroke time) the valves. Provide detailed technical justification for not including this testing in the program.

Valves: VG-24 L-11 VG-25 L-11 VG-33 L-11 VG-34 (L-11 VG-75 A, 1-4 (J-13,J-14)

5. Relief Valves NG-34-A, B (A-2,G-2)

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17 Provide detailed technical justification for not testing these valves per requirements of IWV-3510.

V-29 TIP

1. Ball Valves A-C and RRB V44 The program " Test Requirements" should show " leak test".

RRB-Y44 should show that the valves meet IWV-3426, analysis of Leakage Rates and IWV-3427, Corrective Action.

Quarterly testing of these valves was not stipulated as the test frequency.

2. Shear Valves A-C The program legend stipulates testing 20% of the explosive charges every 2 years. This cumulatively test all 4 valves within eight years. Does the manufacturer's guaranteed operating life for the explosive charges exceed the eight years?

3. Relief Request RRB-V45 The relief request will be acceptable if a maximum stroke time of 2 seconds is assigned. (Reference comment under item 1. of V-27 & 28.)

Relief Request Basis

1. RRB GV-2 This relief request needs better definition.

2. RRB GV-4

As previously discussed under V-27 & 28, the NRC staff has identified rapid-acting power operated valves as those which stroke in 2 seconds or j less. Relief from trending requirements of IWV-3417(a) will be given for

! these valves, however the staff does require that the licensee assign a l maximum limiting stroke time of 2 seconds to these valves in order to obtain this Code relief.

Miscellaneous Items /Coments

1. Provide pump and valve program listing for spent fuel pool cooling.

2. Provide the maximum value of limiting stroke time for all power operated valves in the IST program.

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3. Provide the documentation that er.sures that IWV-3300 is being met.

(Remote position indication verification).

4. Provide latest revisions of drawings for post accideat hydrogen control and the updated IST program listing for the pumps and valves for post accident hydrogen control.

5. Provide a listing of all valves that perform a pressure isolation boundary between the high pressure reactor coolant system and connected lower pressure piping systems.

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