ML20205D137

Forwards Questions & Comments on Pump & Valve Inservice Testing Program.Working Meeting Should Be Held in Bethesda,Md 30 to 45 Days After Receipt of Ltr to Discuss Util Responses

ML20205D137
Person / Time
Site:	Clinton
Issue date:	08/06/1986
From:	Butler W Office of Nuclear Reactor Regulation
To:	Spangenberg F ILLINOIS POWER CO.
References
NUDOCS 8608150271
Download: ML20205D137 (20)

Text

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AM 6 M86 Docket No. 50-461 .D:STRIBUTMON O B mitet Mle a NThompson

'NRC PDR BSiegel LPDR M0'Brien Mr. Frank A. Spangenberg PD#4 Rdg. ACRS(10)

Manager-Licensing and Safety RBernero HShaw Clinton Power Station Pirfo,0GC RLaGrange P.O. Box 678 EJordan Mail Code V920 BGrimes Clinton, Illinois 61727 JPartlow

SUBJECT:

PUMP AND VALVE INSERVICE TESTING PROGRAM FOR CLINTON POWER STATION, UNIT 1 Enclosed are questions and comments resulting from the staff's and its consultant's (EG8G Idaho) review of your inservice testing (IST) program dated February,1985 for Clinton Power Station, Unit 1. For the staff to proceed with the review of your IST program, it is suggested that a working meeting be held in Bethesda, Maryland 30 to 45 days after your receipt of this letter to discuss your responses to the questions and comments contained in the enclosure. In Supplement 6 to the SER, Section 3.9.6, the staff granted you reifef from the pump and valve testing requirements of the ASME Code Section XI (1980 Edition) through Winter 1981 addenda. This relief was for a period of no longer than two years from the date of issuance of the operating license or until the staff's detailed review was completed, whichever came first.

Therefore, completion of this review prior to issuance of a low power or full power ifcense is not required.

Since your IST program was found to be lacking in many of the details that have typically been included in other facility programs, it may be desirable to have a conference call prior to the date for the working meeting. In addition, you may wish to submit proposed program changes or a revised IST program for consideration by the staff prior to the meeting.

If you have any questions regarding this issue please contact the staff's project manager for your application, Byron Siegel, at (301) 492-9414.

Sincerely,

%IWW Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

See next page 8608150271 060006 PDR ADOCK OD000461 A PDR

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UNITED STATES

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! j NUCLEAR REGULATORY COMMISSION h VW ASHINGTON, D. C. 20555

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% ..... # AUG 6 1986 Docket No. 50-461 Mr. Frank A. Spangenberg Manager-Licensing and Safety Clinton Power Station P.O. Box 678 Mail Code V920 Clinton, Illinois 61727

SUBJECT:

PUMP AND VALVE INSERVICE TESTING PROGRAM FOR CLINTON POWER STATION, UNIT 1 Enclosed are questions and comments resulting from the staff's and its consultant's (EG&G Idaho) review of your inservice testing (IST) program dated February,1985 for Clinton Power Station, Unit 1. For the staff to proceed with the review of your IST program, it is suggested that a working meeting be held in Bethesda, Maryland 30 to 45 days after your receipt of this letter to discuss your responses to the questions and comments contained in the enclosure. In Supplement 6 to the SER, Section 3.9.6, the staff granted you relief from the pump and valve testing requirements of the ASME Code Section XI (1980 Edition) through Winter 1981 addenda. This relief was for a period of no longer than two years from the date of issuance of the operating license or until the staff's detailed review was completed, whichever came first.

Therefore, completion of this review prior to issuance of a low power or full power license is not required.

Since your IST program was found to be lacking in many of the details that have typically been included in other facility programs, it may be desirable to have a conference call prior to the date for the working meeting. In addition, you may wish to submit proposed program changes or a revised IST program for consideration by the staff prior to the meeting.

If you have any questions regarding this issue please contact the staff's project manager for your application, Byron Siegel, at (301) 492-9474.

Sincerely,

. ,$ Y Walter R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

See next page

. Mr. Frank A. Spangenberg Clinton Power Station Illinois Power Company Unit I cc:

Mark Jason Assistant Attorney General Public Utilities Division Office of the Attorney General State of Illinois Center Richard B. Hubbard 100 West Randolph Street - 12th Floor Vice President Chicago, Illinois 60601 Technical Associates 1723 Hamilton Avenue - Suite K Mr. D. P. Hall San Jose, California 95125 Vice President Clinton Power Station Chairman of DeWitt County P. O. Box 678 c/o County Clerk's Office Clinton, Illinois, 61727 DeWitt County Courthouse Clinton, Illinois 61727 Mr. John Greene Manager-Nuclear Station Engineering Dpt. Director, Criteria & Standards (ANR-460)

Clinton Power Station Office of Radiation Programs P. O. Box 678 U. S. Environmer.tal Protection Agency Clinton, Illinois 61727 Washington, DC 20460 Sheldon Zabel, Esquire EIS Review Coordinator Schiff, Hardin & Waite Environmental Protection Agency 7200 Sears Tower Region V 233 Wacker Drive 230 S. Dearborn Street Chicago, Illinois 60606 Chicago, Illinois 60604 Resident Inspector Director, Eastern Environmental U. S. Nuclear Regulatory Commission Radiation Facility RP 3, Box 229 A U. S. Environmental Protection Agency Clinton, Illinois 61727 P. O. Box 3009 Montgomery, Alabama 36193 fir. R. C. Heider Project Manager Illinois Department of Nuclear Safety Sargent & Lundy Engineers Division of Engineering 55 East Monroe Street 1035 Outer Park Drive, 5th Floor Chicago, Illinois 60603 Springfield, Illinois 62704 Mr. l.. Larson ProjectManager General Electric Company 175 Curtner Avenue, N/C 395 San Jose, California 95125 Regional Administrator, Region !!!

799 Roosevelt Road Glen Ellyn, Illinois 60137

8' t' ENCLOSURE CLINTON POWER STATION PUMP AND VALVE INSERVICE TESTING PROGRAM OVESTIONS AND COMMENTS

1. VALVE TESTING PROGRAM A. General Questions and Comments

1. Provide a listing of the limiting values of full-stroke time for all power operated valves in the Clinton IST program for our review.

2. Are all valves that are Appendix J type C leak-rate tested included in the Clinton IST program?

3. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10 CFR 50 Appendix J, however, the licensee must comply with the Analysis of Leakage Rates and Correcti 9 Action Requirements paragraphs of Section XI, IWV-3420 (f) and 3420 (g). Does the current Clinton IST program meet this NRC staff position?

4. Do the following valves receive an Appendix J 1eak rate test to verify their ability to perform a containment isolation function? If so, they should be categorized A or A/C as appropriate and be identified in the IST program as receiving a valve seat leakage test (Method of Testing 3 from Table 3.3-1).

System Valves Component Cooling Water System 1CC049 1CC050 1CC053 1CC054 1CC057 1CC060 1CC071

• 1CC072 1CC073 1CC074 1CC127 1CC128 1

4 ,- .

System Valves Containment Monitoring System 1CM011 1CM012 1CM022 1CM023 1CM025 1CM026 1CM047 1CM048 Cycled Condensate System 1CY016 1CY017 Control Rod Drive System 1C11-F083 1C11-F122 Residual Heat Removal System 1E12-F004A 1E12-F0048 1E12-F011A 1E12-F0118 1E12-F021 1E12-F024A 1E12-F0248 1E12-F027A 1E12-F0278 1E12-F028A 1E12-F0288 1E12-F037A 1E12-F0378 1E12-F046A 1E12-F0468  !

1E12-F046C 1E12-F064A 1E12-F0648 1E12-F064C 1E12-F074A 1E12-F0748 1E12-F105 Low Pressure Core Spray System 1E21-F001 1E21-F012 1E21-F303 1E21-F340 High Pressure Core Spray System 1E22-F012 1E22-F015 1E22-F023 1E22-F304 Leakage Detection System E31-F014 .

E31-F015 E31-F017 E31-F018 2

System Valves Reactor Core Isolation Cooling System 1E51-F019 ,

1E51-F031 1E51-F063 1E51-F064 1E51-F068 1E51-F076 1E51-F078 1E51-F316 Fuel Pool Cooling and Cleanup System 1FC007 1FC008 1FC036 1FC037 Fire Protection System 1FP050 1FP051 1FP052 1FP053 1FP054 1FP092 Reactor Water Cleanup System 1G33-F028 1G33-F034 IG33-F039 ,

IG33-F040 1G33-F053 1G33-F054 Combustible Gas Control System 1HG001 1HG004 1HG005 1HG008 Instrument Air System IIA 005 11A006 11A012A

'11A0128 11A013A IIA 0138 IIA 042A IIA 0428 i Makeup Condensate System OMC009 OMC010 Process Sampling System IPS004 1PS005 IPS009

IPS010 -

i IPS016 1

3 1

. l System Valves O

Process Sampling System (continued) 1PS017 1PS022 1PS023 1PS031 1PS032 1PS034 1PS035 1PS037 1PS038 1PSO47 1PSO48 1PS055 1PS056 1PS069 IPS070 Breathing Air System ORA 026 ORA 027 ORA 028 ORA 029 Equipment Drain System 1RE021 1RE022 Floor Drain System 1RF021 1RF022 Service Air System 1SA029 1SA030 Suppression Pool Cleanup System 1SF001 1SF002 ISF004 Shutdown Service Water System 1SX088A 1SX0808 ISX089A ISXO898 -

ISXO96A ISX0968 1SX097A ISX0978 Drywell Cooling System IVP004A 1VP0048 1VP005A 1VP0058 IVP014A IVP0148 +

1VP015A IVP0158 4

., . 1 System Valves Drywell Purge System IVQ004A )

1VQ004B ,

1VQ006A l 1VQ0068 Containment Ventilation System 1VR001A 1VR001B 1VR002A 1VR0020 1VR035 1VR036 1VR040 1VR041 Chilled Water System 1W0001A 1W00018 1W0002A 1W00028 Solid Radwaste System 1WX019 1WX020

5. Are any valves at Clinton Power Station currently leak-rate tested to verify a pressure boundary isolation function? Those valves that serve both a pressure boundary isolation function and a containment isolation function must be leak tested to both the Appendix J and Section XI requirements.

6. The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise during plant operation and these valves are specifically identified by the licensee and are full-stroke exercised during cold shutdowns. The staff requires that the licensee provide a technical justification for each valve that cannot be exercised quarterly during power operation that clearly explains the difficulties or hazards encountered during that testing. The staff will then verify that it is not practical to exercise those valves and that the testing should be performed during cold shutdowns. Cold shutdown testing of valves identified by the licensee is acceptable -

when the following conditions are met: ,

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a. The licensee is to commence testing as soon as the cold shutdown condition is achieved, but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or the plant is ready to return to power.

b. Completion of all valve testing is not a prerequisite to return to power.

c. Any testing not completed during one cold shutdown should be performed during any subsequent cold shutdowns starting from the last test performed at the previous cold shutdown.

d. For planned cold shutdowns, where ample time is available and testing all the valves identified for the cold shutdown test frequency in the IST program will be accomplished, exceptions to the 48 nours may be taken.

Does the Clinton IST program conform to this staff position for all valves tested on a cold shutdown frequency?

7. The Clinton IST program valve listing table does not identify the testing frequency for each individual valve. Therefore, it was assumed that unless indicated otherwise in a comment or a relief request, the tests are performed at the Code specified frequency of once every 3 months for tests 1, 2, and 7; at refueling outages but not less than once every two years for test 3; and in accordance with Table 3510-1 for test 5. Does the Clinton IST program conform to these Code requirements?

8. Many Clinton IST program relief requests specify that the valves will be exercised "during cold shutdown or refueling outages." The use of the word "or" implies that an option exists for the frequency of perforrhing the testing. For valve testing purposes, the NRC differentiates between the cold shutdown mode and the refueling outage .

mode. That is, for valves identified for testing during cold 6

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shutdowns, it is expected that the tests will be performed both during cold shutdowns (in accordance with the Staff positions in A.6 above) and during each refueling outage. However, when relief is granted to perform tests on a refueling outage frequency, testing is expected only during each refueling outage. In addition, for extended outages, tests being performed are expected to be maintained as closely as practical to the Code-specified frequencies.

For the purposes of this review, when the alternate testing specified

" cold shutdown or refueling outages" it was assumed that the testing was to be performed on the cold shutdown frequency and the word "and" was substituted for "or" in the relief requests. Specifically identify any cases where this assumption is not correct and provide a technical justification for not exercising the involved valves during cold shutdowns.

9. Are remote position indicators being verified in accordance with the requirements of Section XI, IWV-3300 for all applicable valves in the Clinton IST program?

10. When flow through a check valve is used to indicate a full-stroke exercise of the valve disk, the NRC staff position is that verification of the maximum flow rate identified in any of the plant's safety analyses through the valve would be an adequate demonstration l of the full-stroke recuirement. Any flow rate less than this will be considered partial-stroke exercising unless it can be shown (by some means such as measurement of the differential pressure across the valve), that the check valve's disk position at the lower flow rate would permit maximum required flow through the valve. Does the

• Clinton IST program conform to this staff position?

l 11. If a manual operator is used to full-stroke exercise check valves that cannot'be full-stroke exercised with flow, is the force or torque that l is applied to the mechanical exerciser measured to assure compliance ,

with IWV-3520(b)(2)?

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12. The NRC staff position is that the emergency diesel generators perform a safety-related function and that the appropriate valves in the emergency diesel air start, cooling water and fuel oil transfer systems should be included in the IST program and be tested in accordance with the Code. Engtne mounted pumps are considered to be part of the diesel and need not be tested separately.

13. Do the valves identified in Table 200-1 in relief request 200 perform safety related functions? IF they do, they shculd be included in the valve listing table of the IST program and be tested in accordance with the Section XI requirements (stroked, stroke timed, fail-safe tested, position verification tested, etc., as applicable) unless specific relief is requested for individual valves or groups of valves in similar applications.

B. Main Steam System

1. Are valves F022A through D and F028A through D full-stroke exercised quarterly during power operations? If not, describe the testing that is performed and provide either a cold shutdown justification or a relief request for these valves.

2. Do valves F022A through D and F028A through D have a required fail-safe position? If so, their fail-safe operation should be verified quarterly by performing test 7.

3. Define what is meant by " extended cold shutdown" in relief requests 015 and 016. If these valves are not tested on a cold shutdown frequency as described in A.6 and A.8 above, then the detailed technical justifications for not testing these valves during cold shutdowns should be included in the relief requests.

4. The safety relief valves that also perform the ADS function should be categorized B/C in the IST program and be exercised in accordance with ,

Section XI as Category B power operated valves to verify their ability 8

to perform the ADS function as well as the safety relief valve function. Which main steam safety relief valves perform the ADS function?

5. Since the upstream MSIVs are exercised quarterly, provide the justification for not exercising valves F098A, B, C, and D quarterly during power operation.

6. Do valves F021 and F033 (M05-1002/2 coordinates B-4 and C-4, respectively) perform any safety related function?

C. Reactor Recirculation System

1. What is the safety related function of valves F023A, F0238, F067A and F067B? Provide the detailed technical justification for not measuring stroke times for these valves.

2. What is the safety related function of valves F060A and B? Provide the detailed technical justification for not measuring stroke times for these valves.

D. Component Coolina Water System

1. What is the safety related function of check valves 1CC188A and 188B7 If the safety function is to close, how are these valves verified in the closed position quarterly?

2. Do valves 1CC065, 067, 068, and 070 perform any safety related function? If so, they should be included in the IST program as Category B valves.

E. Containment Monitorino System

1. How are excess flow check valves 1CM002A, 0028, 003A, and 0038 tested ,

and at what frequency are they tested?

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2. The purpose of measuring valve stroke times in the IST program is to detect valve degradation to allow for repairs of degraded valves prior to their failure, and not for any functional or accident mitigation reasons as indicated in relief request 032.

Solenoid operated valves are not exempted from the stroke time measurement requirements of Sectien XI; their stroke times must be measured and corrective action taken if these times exceed the limiting value of full-stroke time. The NRC staff will grant relief from the trending requirements of Section XI (Paragraph IWV-3410 (c)(3); for these rapid acting valves, however, in order to obtain this relief the licensee must assign a maximum limiting stroke time of 2 seconds to these valves.

F. Cycled Condensate System

1. Review the safety related function of valves 1CY020 and 021 (P&ID M05-1012/6 coordinates D-3 and D-2, respectively) to determine if they should be included in the IST program and be categorized A.

G. Control Rod Drive System

1. It is the NRC staff position that the hydraulic control unit air operated valves 126 and 127 and check valves 114, 115, and 138 (145 of each valve) perform a safety related function and must be included in the IST program and be tested in accordance with the requirements of Section XI.

2. Provide the P&IO that shows the scram discharge volume piping. Any valve that is required to operate in order to allow insertion of the control rods must be included in the IST program.

3. Provide a detailed technical justification for not measuring the )

stroke times for air operated valves F010 and F011. Also provide the ,

P&ID that shows these valves.

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e. .

4. Define " extended cold shutdown" as used in relief request 008 for valve F083. i H. Standby Liauid Control System

1. Define " extended cold shutdown" as used in relief request 011.

2. Provide P&ID M05-1077 for our review.

3. Are any of the valves in the standby liquid control system leak rate tested in accordance with Appendix J requirements to verify their ability to perform a containment isolation function?

I. Residual Heat Removal System

1. How is check valve F098 full-stroke exercised open quarterly during power operation?

2. What is the safety related function of check valves F103A, F103B, F104A, and F104B? If these valves perform a safety function in the closed position, how is each valve individually verified to closef

3. Is credit taxen for the RCIC steam condensing mode of operation in any of the Clinton accident analyses? Review the safety related function of valves F032A, F032B, F051A, F0518, F065A, and F0658 (P&ID M05-1075/4) to determine if they should be included in the IST program and be categorized B.

4. Review the safety related function of solenoid operated valve F095 to determine if it should be included in the IST program.

5. How is check valve F019 full-stroke exercised quarterly during power operation?

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6. Will the air operators full-stroke exercise testable check valves

- F041A, B, and C7 If not, how are these valves full-stroke exercised quarterly?

7. How are valves F046A, B, and C verified to full-stroke exercise during the quarterly testing?

8. Do check valves F085A, B and C perform a safety related function in either the open or closed position? Do check valves F084A, B, and C perform a safety related function in the closed position? If so, how are these valves individually verified to close?

9. Provide the P& ids that show valves F052A, F0528, F100A, and F1008; they do not appear in the P&ID locations indicated in the Clinton IST program on the drawings provided.

10. Review the safety related functions of valves F301A, 8, and C to determine if they should be included in the IST program.

J. Low Pressure Core Soray System

1. Will the air operator on testable check valve F006 full-stroke exercise the valve quarterly during power operations? If not, how is this valve full-stroke exercised quarterly?

2. Are there any interlocks (i.e. RCS pressure >135 psig) that would prevent a full-stroke exercise of valve F005 quarterly during power operation?

3. How is valve F033 individually tested to verify its safety related function in the closed position? Does valve F034 perform a safety related function in either the open or closed position?

4. Review the safety related function of valve F340, the air operated i

bypass valve around F006 (P&ID M05-1073 coordinates D-2), to determine I i if it should be included in the IST program.

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K. Hiah Pressure Core Soray System

1. Will the air operator on valve F005 full-stroke exercise the valve quarterly during power operations? If not, how is this valve full-stroke ex3rcised quarterly?

2. Does valve F006 perform a safety related function in either the open or closed position? If this valve performs a safety related function the cloted position, how is it individually verified to close?

3. Provide the P&ID that shows excess flow check valves F330 and F332.

How are these valves being tested?

4. Review the safety related function of valve F304, the bypass around valve F005, to determine if it should be included in the IST program and be categorized A.

L. MSIV Leakaae System

1. What is the safety related function of the following valves? If they perform a safety function in the closed position, how are these valves exercised closed?

F010 F315A F315C F011 F3158 F3150 M. Reactor Core Isolation Coolina System

1. Does valve F062 perform a safety related function in either the open or closed position? How is valve F061 tested to individually verify its ability to perform its safety related function in the closed position?

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2. How are check valves F065 and F066 full-stroke exercised quarterly during power operation? Can F065 be exercised with a differential pressure equivalent to operating reactor pressure across the valve disk?

3. How is valve F030 full-stroke exercised quarterly? If this valve is full-stroke exercised using a manual operator, provide a valve drawing that shows how the mechanical exerciser actuates the valve disk.

4. Review the safety related function of valve F316 to determine if this valve should be included in the IST program and be categorized A.

N. Fuel Pool Coolina and Cleanuo System

1. Is credit taken for the RHR system supplying cooling water flow to the fuel pool? If so, all applicable system valves should be included in the IST program (may include check valves 1FC018A, 0188, 020A, 020B, 022A, and 0228).

2. Are the fuel pool cooling and cleanup pumps (1FCO2PA and 1FCO2PB) supplied from an emergency power source? If they perform a safety related function, all applicable system valves should be included in the IST program.

! 3. What are the safety related functions for the following valves?

l l 1FC004A 1FC016A 1FC024A 1FC017 l 1FC0048 1FC016B 1FC024B 1FC023 l

! 0. Instrument Air System

1. Provide a more detailed technical justification for not exercising valves 11A005, 006, 007, and 008 quarterly during power operation.

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2. Define " extended cold shutdowns" as used in relief requests 028 and 029. Explain how a failure of valves lIA012A, 0128, 013A, and 013B to return to original position would cause a loss of operating air to SRVs. .

I

3. Do check valves lIA042A, 042B, 076A, and 076B perform a safety related function in the closed position? If so, how are these valves verified in the closed position during valve testing?

P. Process Samplina System

1. Provide a more detailed technical justification for not measuring stroke times for the solenoid operated valves in this system (refer to relief request 034 and comment E.2).

2. Does this system perform any safety related function? If so, review the function of the following valves to determine if they should be included in the IST program.

lPSO41 1PS013 1PS029 1PS050 1PS019 IPSO 46A 1PS006 1PS025 1PSO468 Q. Breathina Air System

1. Provide a more detailed technical justification for not measuring the stroke times for the solenoid operated valves in this system (refer to relief request 027 and item E.2). Provide P&ID M05-1065/7 for our review.

R. Suppression Pool Makeup System

1. How are excess flow check valves ISM 008, 009, 010, and 011 being tested? ,

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S. Shutdown Serv. ice Water System

1. Provide a more detailed technical. justification for not measuring stroke times for the valves listed in relief request 020 Table 20-1.

Stroke times are measured for IST purposes to detect valve degradation instead of determining if the valve can meet an operational time requirement.

2. Should the valves identified on the valve listing table (Table 3.3-1) as 1SX0120, 012E. and 012F be changed to 1SX0130, 013E, and 013F7

3. What is the basis for the 18 month alternate testing frequency identified in relief requests 017 and 0307 What is the technical justification for not performing this testing on a cold shutdown frequency?

4. How are check valves 1SX0834 and 083B full-stroke exercised quarterly during power operation.

5. The valve listing table indicates that a loss of power test will be performed for valves 1SX025A, 0258, and 025C. Do these motor operated valves have fail-safe actuators?

6. Review the safety related function of the following valves from P&ID M05-1052/5 to determine if they should be included in the IST program.

1SX072A 1SX106A 1SX073A 1SX0728 1SX1068 1SX073B T. Control Room HVAC System

1. Provide the P&ID that snows valves OVC017B, 020B, and 0328 for our review, e

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2. Do valves OVC010A and 022A have a required fail-safe position? If so,

, they should be included in the IST program and be full-stroke exercised.

3. What is the safety related function of check valves OVC020A and 032A7 If these check valves perform a safety related function in the closed position, how are they verified in that position quarterly?

4. What is the function of valves OVC001A and 002A7 Is this a safety related function?

U. Containment Ventilation System

1. Provide the P&ID that shows valves 1VR006A, 006B, 007A, and 0078 for own review.

2. How are excess flow check valves IVR016A, 0168, 018A, and 018B tested?

3. Provide a more detailed technical justification for not measuring stroke times for valves 1VR035, 036, 040, and 041.

V. Chilled Water System

1. Provide the P&ID that shows valves 1W0001A, 0018, 002A, and 0028.

They do not appear on M05-1117/9 as indicated in the valve listing table.

2. Define " extended cold shutdown" as used in relief request 021.

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