ML20199A806

Requests Addl Info Re Inservice Testing Program Including Auxiliary Feedwater Sys,Reactor Coolant Sys,Chemical & Vol Control Sys,Component Cooling Water Sys & RHR Sys,Per 840731,850222 & 0729 Requests

ML20199A806
Person / Time
Site:	Wolf Creek
Issue date:	06/11/1986
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Koester G KANSAS GAS & ELECTRIC CO.
References
NUDOCS 8606160016
Download: ML20199A806 (9)

Text

C c I i aun 11 as 00M nh Docket No.: 50-482 Mr. Glenn L..Koester Vice President - Nuclear Kansas Gas and Electric Company 201 North Market Street

. Post Office Box 208 Wichita, Kansas 67201

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE WOLF CREEK GENERATING STATION INSERVICE TESTING PROGRAM The staff is continuing its review of your submittals dated July 31, 1984; February 22, 1985; and July 29, 1985. To permit us to continue our review on our current schedule, we require the information requested in Enclosure 1 to this letter be provided.

We have found from past experiences that acceptable responses can best be arrived at through a discussion between our staff, consultants, and your staff. Please notify us when you are ready for us to schedule a meeting to discuss your responses.

Sincerely, B. J. Youngblood, Director PWR Project Directorate #4 Division of PWR Licensing-A

Enclosure:

DISTRIBUTION:

As stated .- N r*

NRC PDR Local PDR PD#4 R/F BJYoungblood OELD EJordan BGrimes JPartlow P0'Connor MDuncan ACRS (10)

/W fWef PWR#4/DPWR-A PWRf4/DPWR-A P0'Connor:lr  % BJYoungblood 6/ // /86 6/// /86 06061gg$$$50 PDR f

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ENCLOSURE 1 WOLF CREEK GENERATING STATION p~ PUMP AND VALVE INSERVICE TESTING PROGRAM RE00EST FOR ADDITIONAL INFORMATION I. VALVE TESTING PROGRAM (REVISION 1)

A. General Questions and Comments

1. The current NRC position for inservice testing of valves identified to be tested during cold shutdown is that testing shall connence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after ree.. .. . .old shutdown condition rather than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> specified in the Wolf Creek IST program.

Are all valves that are leak-rate tested in accordance with 10CFR50, ,'

2.

Appendix J included in the IST Program and categorized "A" or "AC"?

3. The NRC has concluded that the applicable leak test ~ procedures and ,

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e requirements for containment isolation valves are determined by

. 10CFR50, Appendix J'(see relief request VR-5). Relief from paragraphs IWV-3421 through -34'Z5 for containment isolation valves presents no safety problem since the intent of IWV-3421 through -3425 is met by Appendix J requirements, however, the licensee shall comply with ,

paragraphs IWV-3426 and -3427.

4. Are valves (if any) that perform both a containment isolation and a pressure isolation function leak-rate tested to both the Appendix J and the Section XI requirements?

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5. The NRC staff has determined that fast-acting valves are defined as those valves with stroke times of..two seconds or less and that valves with stroke time greater than two seconds should be tested in accordance with IWV-3413 (this position affects relief request VR-2).

6. Provide the current revision of the Wolf Creek P&ID M-02KA01 for our review.

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B. Auxiliary Feedwater System

1. How are the following check valves full-stroke exercised quarterly?

If these valves are exercised open with flow, how is it verified that they open sufficiently to allow passage of design accident flow?

V-001 V-006 V-015 V-002 V-009 V-003 V-012

2. Are the following valves ever closed or throttled during power operation? If so, they would be required to open in order to perform their function important to safety, and should not be classified as control or passive valves in the IST program.

. HV-5 HV-8 HV-11 HV-6 HV-9 HV-12

,' HV-7 HV-10

3. Review the function'important to safety for valve V-033 (P&ID

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M-02AP01 coordinates'F-4) to determine if it should be included in the IST program.

C. Reactor Coolant System

1. How are the following check valves full-stroke exercised during refueling outages? How is it verified that they open sufficiently to allow passage of design accident flow?

8948A,B C,&D V-001 V-040 8949A,B C,8D V-022 , V-059

2. Is credit taken for the operability of valves V-084 and HV-8145 to reduce plant pressure in order to meet Reactor Systems Branch Position 5.17 If so, these valves should be tested in accordance with the Code unless specific relief is requested.

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Provide a more detailed technical justification for not exercising l

- 3.

valves HV-8001A, 8001B, 8002A, and 80028 quarterly during power operation.

I D. Chemical and Volume Control System

1. What is the justification for the 60 second limiting value of stroke time for valve HCV-123, a 1 inch air operated globe valve?

2. What are the limiting values of stroke times for valves LCV-459 and 4607 Are these valves leak tested to verify their ability to perform a pressure boundary isolation function?

3. What is the function important to safety for the following valves?

Are these valves ever required to change position in. order to perform any safety function?

HV-8146 V-019 ,

4 HV-8147 ,} V-154

4. How are check valves 8481 A and B full-stroke exercised quarterly?

How is it verified that these valves open sufficiently to allow passage of design accident flow?

- 5. How are check valves V-589 and 590 verified closed when they are full-stroke exercised quarterly during plant operation?

6. Review any function important to safety for valve V-598 (P&lD M-02BG03 coordinates G-2) to determine if it should be included l in the IST program es a category C valve. .

E. Component Cooling Water System

1. Does valve V-129 perform a safety function in the open position?

! F. Residual Heat Removal System i

i 1. How is the valve position indication verified for HV-8811 A and B which are located inside the valve encapsulation tanks?

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2. Do valves FCV-618 and 619 have a required fail safe position?

If so, are they tested to verify this fail safe actuation per ,

IWV-34157

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G. High Pressure Coolant Injection

1. Is the boron injection tank ever subjected to boric acid concentrations greater than the RWST concentration of 2,000 ppm boron, where re-circulation would be required to prevent boron precipitation?

2. Provide a more detailed technical justification for not full or partial-stroke exercising check valves V-240, V-241, and 8815 quarterly during power operation.  ;

H. Containment Spray System

1. The current NRC position is that an alternate means should be used to full-stroke exerqise any check valves that perform a function important to safety which cannot be full-stroke exercised with flow.

! What alternate means have been considered to full-stroke exercise the following valves?

V-003 V-009

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V-004 V.-010 .

. 2. Provide a more detailed technical justification for not exercising valves HV-15 and 16 quarterly during power operation. Why would it

- be necessary to isolate the spray additive tank to perform the testing of these valves?

3. Provide a more detailed technical justification for not exercising valves HV-1 and 7 quarterly or during cold shutoowns. How is the

! valve position indication verified for these valves which are located inside the valve encapsulation tanks?

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I. Accumulator Safety Injection

1. Should the valve listing table indicate that the relief request (s) for valves 8956A,B,C,8D is (are) VR-4 or both VR-4 and VR-6?

J. Auxiliary Feedwater Pump Turbine -

1. How are the following valver individually verified to open during quarterly testing? Do these valves perform a safety function in the closed position?

, V-001 V-024 V-002 V-025 ,

K. Containment Hydrogen Control System ,

1. Is credit taken for the containment air sample and return flow paths to and from the post accident sample system? If so, review

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I any function import 4[qt to safety for the following valves to determine if they should be exercised in accordance with the .

Code.

HV-30 V-054 HV-35 V-059 L. Standby Diesel Generators .

1. Review any functiora important to safety for the following valves to determine if they should be included in the IST program.

Valve P&ID '

Coordinates V-716A M-02KJ02 C-2 V-717A M-02KJ02 C-4 V-716B M-02KJ05 C-2 l V-717B M-02KJ05 C-4 i

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M. Nuclear Sampling System

1. Review any functions important to safety or any operability requirements for the post accident sampling system to determine if the following valves should be exercised in accordance with the Code.

V-100 HV-3 V-101 HV-4 Y-116 HV-20 N. Service Gas System

1. Is credit taken for the nitrogen supply to the main steam isolation and feedwater isolation valves? Is any credit taken for closure of the, check valve (V-131) in the nitrogen suppiy line io these valve

. actuators?

O. Chilled Water Supply '.

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1. Is any credit taken for the chilled water system in meeting the post accident control room habitability requirements?

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• II. PUMP TESTING P!!0 GRAM (REVISION 1)

1. Provide a more detailed justification for extending the time allowed for analysis of pump test data (see relief request PR-2). The currently allowed 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> appears to be adequate for almost all possible situations, even cases involving three day holiday weekends.

2. Is it possible to detect emergency fuel oil transfer purp degradation by taking vibration measurements at some alternate location such as on the motor upper or lower bearing (see relief request PR-4)?

3. A general relief from the Section XI requirements cannot be granted as ,

requested in PR-7. If specific cases are identified where the IWP-3100 allowable ranges cannot be met, then the licensee should submit a specific j

request for relief providing suffit.ient technical data t'o allow for NRC

- evaluatica.

4. Provideadditionalinfogationthatjustifiestheselectionofthe suction and discharge piping of the boric acid transfer pumps as the best location for measuring pump bearing vibration to provide an indication of bearing degradation (see relief request PR-6).

i -- 5. The current NRC position is that the lack of installed instrumentation

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is not an acceptable long term technical justification for not i measuring the Code required parameters on pumps that perform a I function important to safety. Unless the licensee can demonstrate that a valid alternate method is used to obtain the data required to assess pump condition and determine pump degradation, the licensee should make the necessary system and/or' component modifications to allow measurement of the required parameters. Pump program relief request PR-8 is affected by this positon.

6. P&ID M-02AL01 shows flow elements installed in the test flow path for the motor and turbine driven auxiliary feedwater pumps. Can these flow elements be used to measure pump flow during quarterly pump testing (see relief request PR-8)?

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. . 1 III. ADDITIONAL QUESTIONS BASED ON REVISIONS 2, 3, & 4 l

. 1. Revision 3. Item 2 and relief request PR-11 address changing seme of the Acceptable and Alert Ranges from the values specified in Table IWP-3100-2. It is not typically a problem for plants to meet these Code specified ranges. Provide more detailed information documenting the specific cases where Wolf Creek cannot meet these Section XI requirements.

2. Revision 3. Items 30 and 31 delete the fail-safe testing for valves AB-HV-11, 14, 17, and 20 and valves KJ-PV-1A, IB, 101A, and 1018. The only basis provided for these changes was program enhancement. Provide a technical basis for not testing these valves in accordance with IWV-3415.

3. Revision 4, Item 1 and relief request VR-8 delete from the Wolf Creek IST program the leakage rate corrective action requirements contained in I

. IWV-3427(b) of the ASME Code Section XI. The basis provided in Revision 4 and relief request VR-8 is not considered to be an adequate technical justification for not complying with Section XI requirements. Provide a more detailed technical)ustification for deleting the cortective actions identifiedinIWV-3427(b).

4. Relief request PR-10 states that the emergency fuel oil transfer pumps

- will be operated for 30 seconds before the specified measurements are i recorded. Provide information that demonstrates that a 30 second run is i

adequate to allow conditions to stabilize sufficiently to obtain representative and repeatable pump measurements that allow detemination of pump condition and detection of pump degradation.

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