ML20082J546

Forwards Response to NRC Draft Position on Open Inservice Testing Program Items Dtd 831114,per 831118 Telcon.Program Includes Fifth Refueling Outage Requirements & Pressure Isolation Valve Evaluation Review

ML20082J546
Person / Time
Site:	Farley
Issue date:	11/28/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
NUDOCS 8312020216
Download: ML20082J546 (6)

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Malling Address Alabama Power Company 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6081 F. L. Clayton, Jr.

Senior Vice President Fhntridge Building /\labaniaPOWCf Dochet Nos. 50-348 ,7,g scy ,yyyy,,,c 3,,

50-364 November 28, 1983 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant -Units 1 and 2 Response to NRC Draft Position on Open IST Items Gentlemen:

By letter dated October 11, 1983, Alabams Power Company provided a list of Inservice Testing (IST) Program requirements for the Unit I fifth refueling outage. This list included a review of the pressure isolation valve evaluation submitted for Units 1 and 2 by letter dated September 27, 1983. In response, NRC has developed a " Draft Staff Position Regarding Farley Units I and 2 Pressure Isolation Valves and Other IST Open Items" dated November 14, 1983.

Each of these items was discussed with Messrs. E. A. Reeves and G. Hammer of NRC in a conference call held November 18, 1983. As requested by Mr. Reeves, Alabama Power Company herewith submits the attached response to these items as discussed in the referenced call.

If you have any questions or if additional information is needed in support of the NRC evaluation, please advise.

Yours truly, N

F. L. Clayton Jr.

FLCjr/ STB:kc/D-302 cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford 6 i i 8312020216 831128 k PDR ADDCK 05000348 P PDR i

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ATTACRMENT APCO RESPONSE TO NRC DEAFT STAFF POSITION ON OPEN IST ITEMS

1. Encapsulated Valve Position Verification (Unit 1)

NRC Position: The staff agrees that the relief given for Unit 2 on position verification of the encapsulated valves should be extended to Unit 1, provided the same redundant position indication features exist on both units.

APC0 Response: Alabama Power Company's letter of September 13, 1983 was docketed for both Units 1 and 2. This letter verified that the same redundant position indication features existed for both units. Alabama Power Company requests that Pages 2 and 3 of the Unit 1 Safety Evaluation Report (SER), Item C be revised to incorporate the relief granted for Unit 2.

2. RWST Check Valve Full Stroke Test (Units 1 and 2)

NRC Position: The staff requests the licensee to submit a proposal for stroke testing the RWST check valve by April 1, 1984.

APC0 Response: Alabama Power Company is presently evaluating the feasibility of various design change alternatives that could permit a full stroke test of the RWST check valve.

This evaluation is scheduled for completion by the end of the first quarter of 1984. Based on this schedule, it is requested that NRC allow Alabama Power Company to submit this revised plan by May 1, 1984.

3. Accumulatot Check Valve Full Stroke Test (Units 1 and 2)

NRC Position: The staff's position is that one accumulator check valve shall be disassembled and full stroke tested each refueling outage beginning with the upcoming outage. If the one tested valve fails to stroke or is found in unacceptable condition for service, the other valves shall also be disassembled and full stroke tested.

APCO Response: The disassembly and inspection of one accumulator check valve, solely for the purpose of completing a full stroke test, will involve exposure of up to.3 man Rem, which is inconsistent with ALARA commitments. Therefore, Alabama Power Company is evaluating other methods to verify valve operability, such as stroke testing the valves to their fully open position or to the position required to achieve design flow during each refueling outage or during the ten year ISI outage. This evaluation is scheduled for completion by the end of the first quarter of 1984.

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Based on this schedule, it is requested that NRC allow Alabama Power Company to submit a revised plan for testing these valves by May 1, 1984. NRC has grented Alabama Power Ccmpany limited relief for performance of the partial stroke test. It is the judgement of Alabama Power Company that the partial stroke test, as granted, is sufficient to verify valve operability until a revised test plan can be implemented.

4. Accumulator Check Valve Test Deferral (Unit 1)

NRC Position: The staff agrees that the accumulator check valves should not have been included in the Unit 1 oummary list referenced.

APC0 Response: Alabama Power Company concurs with the NRC position and requests that Page 5 of the Unit 1 Safety Evaluation Report, Item E, be revised to delete valve numbers Q1E21V037A, B & C.

5. Pressure Isolation Valves (Units 1 & 2)

a. RHR Suction from RCS (Motor Operated Valves)

NRC Position: Four of the pressure isolation valves (PIVs) are RHR suction motor operated gate valves (MOVs). It is the staff position that these valves must be leak tested to assure RCS pressure isolation from directly interconnecting RHR piping. During licensing reviews in the past, the staff has allowed an increased leakage criteria (up to five CPM) in some cases for two MOVs in series which have the appropriate system pressure interlocks so that they cannot be opened when RCS pressure is above the design pressure of the low pressure interfacing system. Also, the MOVs must have positive position indication in the control room. The staff will accept the five CPM criterion for these four Farley 1 MOVs if APC0 can show that the valves have these features.

APCO Response: Alabama Power Company will leak rate test the four RHR suction motor operated gate valves as pressure isolation valves. All four valves are interlocked as required by Technical Specification 3/4.5.2.d.1 and have positive position indication in the control room. Based on these features, Alabama Power Company requests that the leak rate criteria for these valves as specified in Unit 1 Technical Specification 3/4.4.7.3 and Unit 2 Technical Specification 3/4.4.7.2 be changed to less than or equal to five (5) GPM.

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b.

Fifteen Non-Pressure Isolation Valves (PIVs)

NRC Pesition: The remaining 15 valves are in the flow path of charging pump /IIHSI supply. It is argued by APC0 that the pressure being continually supplied by the charging pumps is higher than RCS pressure; therefore, RCS pressure cannot reach the charging pump low pressure suction piping.

The staff agrees that except during brief periods of time during some shutdown modes, the charging pumps do provide adequate pressure isolation and, therefore, will provide assurance that low pressure piping will not be overpressurized and cause an intersystem LOCA.

Therefore, the staff has concluded that leak testing per se is not required for these 15 valves.

APCO Response: The 15 valves and their functions are identified below.

These valves are also listed in Table 2, Items 2 and 3 of APCO's letter of September 27, 1983 to the NRC which provides location information.

Valve ID Number Valve Function 01/2E11V051 A,B,C RRR Pump Discharge to RCS hot leg loops 1, 2, & 3 Q1/2E21V062 A,B,C HHSI (BIT) to RCS cold leg loope 1, 2, & 3 Q1/2E21V066 A,B,C HHSI (BIT Bypass) to RCS cold leg loops 1, 2, & 3 01/2E21V078 A,B,C HHSI to RCS hot leg loops 1, 2, & 3 Q1/2E21V079 A,B,C HHSI to RCS hot leg loops 1, 2, & 3 Alabama Power Company concurs with the NRC position that these valves are not primary pressure isolation valves and that these valves should not require leak rate tests. It is requested that Pages 6 and 7 of the Unit 1 SER, Item H, and Pages 111-114 of the Unit 2 SER, Appendix B, be revised to delete these fifteen valves.

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Reverse Flow Test for Fifteen Non-PIVs NRC Position: Another function of these 15 valves which the staff has concern about is that of preventing reverse flow for certain accident scenarios, such as postulated pipe breaks in the Class 2 piping. Therefore, the staff asks the licensee to propose alternative methods to leak testing in order to verify the reverse flow function.

For example, this may be accomplished by using both a forward flow and a back flow test or by valve disassembly or inspection.

APCO Response: The Farley Nuclear Plant design basis pipe break criteria for Class 2 piping systems is provided in FSAR Section 3.6.1. This criteria states " Design basis piping breaks and piping cracks are postulated to occur in the reactor loops and in all lines outside the reactor coolant piping system that have a normal operating temperature above 200* F and a normal operating pressure above 275 psig."

In accordance with this criteria, pipe breaks are not required to oe postulated in the portions of the safety injection system which include these 15 valves. In addition, in all cases there is a motor operated gate valve between each of the 15 valves and the nearest postulated Class 2 pipe break location. The motor operated gate valves have position indications in the control room. No other accident scenarios have been identified which require reverse flow functioning of these 15 valves. Inasmuch as these valves are not primary pressure isolation valves, and no postulated accident scenarios, including pipe breaks in Class 2 piping, will require reverse flow functioning of these valves, it is the judgement of Alabama Power Company that reverse flow testing of these valves is not technically justified. These valves are currently tested in accordance with ASME Code requirements (with schedular relief where applicable as grcnted by NRC). This testing involves verification of the safety function of the valves (i.e., that they open) which is sufficient to assure continued safe operation of these valves.

6. Instrument Air Check Valve Position Verification (Unit 1)

NRC Position: The staff is continuing to review the safety related function of the Instrument Air Check Valve and the need to verify its position quarterly.

APC0 Response: The Instrument Air Check Valve (01P19V004) provides the back-up air supply to the pressurizer PORVs. This 1/2 inch check valve has no external means of position verification; therefore, its position can be verified neither quarter'y nor each time the valve is cycled. The valve is verified to be in the closed position during the Local Leak Rate Tests performed during each refueling outage. Since this valve is in the normally closed position in a system where no corrosive environment or severe operating condition exists, this valve should not be subject to the type of degradation sufficient to justify test frequencies greater than each refueling outage. Alabama Power Company, therefore, requests that Page 5 of the Unit 1 SER, Item I, be revised to delete the required position verification of valve 01P19V004 other than during each refueling outage. It is noted that the current SER provision to quarterly test this valve cannot be accomplished at power with loss of the back-up air supply to the PORV which was installed in response to NUREG 0737.

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7. IE Bulletin 83-03.(Unit 1)

NRC Position: None received.

APCO Response: Alabama Power Company has responded as required to the NRC IE Bulletin (IEB) 83-03 by letters dated June 10 and November 17, 1983. These letters outlined the planned course of action to be implemented for Unit I during the fifth refueling outage. The Unit 1 SER, Item K, Pages 8 and 9, requires implementation of IEB 83-03 and denies the requested relief. This same relief was granted for Unit 2 and no requirements regarding IEB 83-03 were stated. Since Alabama Power Company has already responded to the NRC on IEB 83-03, it is respectfully requested that the requirement to implement IEB 83-03 be removed from the SER and that the relief previously requested for Unit 1 be granted. Alabaxx Power Company proposes to complete the commitments made to the NRC in the referenced letter of June 10, 1983 during the Unit 1 fifth refueling outage. Following completion of the planned inspections, a report as required by IEB 83-03 stating findings and evaluation of proposed IST program revisions, based on findings, will be submitted to the NRC.

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