ML20207S496

Forwards List of Questions & Comments Re Inservice Insp Program.Questions & Comments Informally Delivered Previously by Hou at Meeting W/Licensee

ML20207S496
Person / Time
Site:	Millstone
Issue date:	03/16/1987
From:	Ballard R Office of Nuclear Reactor Regulation
To:	Doolittle B Office of Nuclear Reactor Regulation
References
NUDOCS 8703190555
Download: ML20207S496 (15)

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MAR 16 wei MEMORANDUM FOR: Beth Doolittle, Project Manager PWR Project Directorate .lo. 5 Division of PWR Licensing.A FROM: Ronald L. Ballard, Chief Engineering Branch Division of PWR Licensing _A

SUBJECT:

RAI ON IST PROGRAM OF MILLSTONE 3 The Mechanical Section of Engineering Branch and its contractor EG&G have reviewed the IST program of Millstone Unit 3. A list of our questions and connents on the IST program was informally delivered to you by Shou Hou recently (copy attached), and a meeting with the licensee for resolving our concerns was requested.

This is to formalize the above actions.

Original signed by Ronald L. Ballard, Chief Engineering Branch Division of PWR Licensing _A

Attachment:

As stated cc: C.E. Rossi V. Nerses G. Bagchi S. Hou

Contact:

S. Hou X_29080 Distribution:

Docket Filef PAEB Reading File PAEB Plant File R. Ballard 0703190555 870316 PDR ADOCK 05000423 g PDR (SEE ATTACHED FOR PREVIOUS C0_NCURRENCES*)

0FC :PAEB * :PAEB * :PAE '  :  :  :  :

..__ :............:.. ___..____: _ _ ,y..:......_____.:_......_____:.......____:-__........

NAME : Shou:lt :GRagchi :PB 1 aM-  :  :  :  :

DATE :3/ 9 /87 :3/ 9 /87 :3//6/87  :  :  :  :

OFFICIAL RECODD COPY

MEMORANDIM FOR: Beth Doolittle, Project Manager PWR Pro.iect Directorate No. 5 Division of PWR Licensing-A FROM: Ronald L. Ballard, Chief Engineering Branch

, Division of PWR Licensing-A

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SUBJECT:

RAI ON IST PROGRAM.0F MILLSTONE 3

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The Mech 9 nical Section of Engineering Branch and its contractor EG4G have reviewedTthe IST program of Millstone Unit 3. For expediting the reviews effort, a\ list of our questions and comments on the IST program was personally delivered 'to you by Shou Hou recently, and a meeting with licensee for resolving our concerns was reouested.

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This is to formalize the above actions.

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\ Ponald L. Ballard, Chief Engineering Branch Division of PWR Licensing-A cc: C.E. Rossi V. Noonan s G. Bagchi i S. Hou \

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Contact:

S. Hou \

X-29080

\ i Distribution:

Docket File

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PAER Reading File PAEB Plant File R. Ballard \ 1 i

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UFC :PAEB r r :FAER :PAEB  :  :  :  :

.....:.... .J p 7.:  :: _ _ _ .. ...:............:...........:............:_......._:...........

,NAME : Shou lt :i.agchi :RBa11ard  : 1  :  :  :

C DATE :3/ /87 :3/ *)/87 :3/ /87  :  :  :  :

i 0FFICIAL DECORD COPY l

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MILLSTONE NUCLEAR POWER STATION, UNIT 3 PUMP AND VALVE INSERVICE TESTING PROGRAM QUESTIONS AND COMMENTS

1. VALVE TESTING PROGRAM A. General Questions and Comments

1. Section 4.3.7 of the Millstone Unit 3 IST program does not agree with Section XI, Paragraph IWV-3416. The Code requires valves to be exercised within 30 days prior to return of the system to operable status; why can't this Code requirement be met?

2. Are all valves that are Appendix J, Type C, leak-rate tested

,- included in the Millstone Unit 3 IST program and categorized "A" or "AC"?

3. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10CFR50, Appendix J. Relief from paragraphs IWV-3421 through 3425 for containment isolation valves presents no safety problem since the intent of IWV-3421 through 3425 is met by Appendix J J -

requirements, however, the licensee shall comply with Paragraphs IWV-3426 and 3427.

4. The Code permits valves to be exercised during cold shutdowns where it is not practical to exercise them during plant operation l and these valves are specifically identified by the licensee and are full-stroke exercised duding cold shutdowns. The NRC staff requiresthatthelicenseephovideatechnicaljustificationfor each valve that cannot be exercised quarterly during power operations that clearly explains the difficulties or hizards encountered during that testing. The NRC staff will th'en verify that it is not practical to exercise those valves and that the testing should be performed during cold shutdowns.

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5. What are the bases used to assign the limiting values of full-stroke time for the power operated valves in the Millstone Unit 3 IST program? Provide the limiting values of full-stroke times for those valves that have NSR(1) in the maximum stroke time column of Table 5.4.

. 6. 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 of the full-stroke requirement. 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 Millstone Unit 3 IST program conform to this staff position?

7. The relief request and cold shutdown justification bases should indicate the negative consequences that make testing at the Code required frequency impractical such as endangering personnel, damaging equipment, or resulting in a plant shutdown.

B. Reactor Coolant System

1. How are valves 3RCS-V31, 32, 71, 107, and 146 verified to full-stroke during cold shutdown testing?

2. What is the safety related function of valves 3RCS-V31, 32, 147, and 1487 If these valves perform a safety-related function in the closed position, how are they individually verified to close? Do these valves perform a pressure isolation function?

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4 C. Reactor Coolant Pump Seals

1. - Provide a more detailed technical justification for not full-stroke exercising valves 3CHS-V393, 433, 466, and 500 during cold shutdowns (Relief Request R-17 does not address the consequences of exercising these valves).

2. Provide a more detailed technical justification for not full-stroke exercising valves 3CHS-V394, 434, 467, and 501 during cold shutdowns (Relief Request R-2 does_not address the consequences of exercising these valves during cold shutdowns).

D. Chemical and Volume Control System

1. Provide a more detailed technical justification for not

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full-stroke exercising valves 3CHS-V5 and 802 quarterly during

. power operations.

2. Provide a more detailed technical justification for not full-stroke exercising valves 3CHS-V40 and 41 quarterly during power operations.

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3. Provide a more detailed technical justificatien for not full-stroke exercising valves 3CHS-V46, 47, and 48 quarterly during power operations and during cold shutdowns.

4. Provide a more detailed technical justification for not full-stroke exercising valves 3CHS-V56 and 57 quarterly during power operations.

5. Provide a more detailed technical justification for not full-stroke exercising valve 3CHS-V58 quarterly during power

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operations and during cold shutdowns.

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6. Provide a more detailed technical justification for not full-stroke exercising valves 3CHS-V333, 710, 711, and 712 quarterly during power operations.

7. Provide the P&ID that shows valves 3CHS-V487, 488, and 489.

8. Provide a more detailed technical justification for not full-stroke exercising valves 3CHS-V532 and 533 quarterly during power operations and during cold shutdowns.

9. Review the safety function of valve 3CHS-V42 (P&ID 25212-26904 Sh. I location J-9) to determine if it should be included in the IST program and tested to the Code requirements.

10. Do valves 3CCE-V9 and 21 (P&ID 25212-26905 locations E-2 and C-2) have a reauired fail-safe position? If so, they are active valves and should be included in the IST program and tested to the Code requirements.

11. Would failure of valve 3CHS-V269 closed during quarterly stroke testing render an entire safety system inoperable?

12. Review the safety related function of valves 3CHS-V294, 296, and 320 (P&ID 25212-26904 Sh. 3 locations J-5, J-6, and F-4) to determine if they should be included in the IST program.

E. Fuel pool Coolino System

1. Review the safety function of valves 3SFC-V3 and 6 (P&ID 25212-26911 locations G-9 and G-10) to determine if they should be included in the IST program and tested to the Code requirements. ,

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F. LowPreso'[eSafetyInjectfonSystem

1. Would failure of valh)e 3SIL-V5 or 11 closed during quarterly stroke testing render the low pressure safety injection system unavailable to perform its safety function?

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2. 'How are valves 3SIL-V6, 7, 12, an/ 13 partial-stroke exercised quarterly during power operations?

4 3. The proposed alternate test frequency for valves 3SIL-V15, 17, 19, and 21 does not adequately demonstrate the operability of these valves. The NRC staff has concluded that a valve sample disassembly / inspection utilizing a manual full-stroke exercise of the valve disk is an acceptable method to verify a check valve's full-stroke capability. This program involves grouping similar

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valves together and testing one valve in each group during each refueling outage. The sampling technique requires that each valve in the group be of the same design (manufacturer, size, model number and materials of construction) and have the same service conditions. Provide a justification for not meeting this NRC staff position.

4. Would failure of valve 3SIL-V25 open during quarterly stroke testing render the low pressure safety injection system

unavailable to perform its safety function?

5. How are valves 3SIL-V26, 27, 28, and 29 partial-stroke exercised quarterly during power operations?

6. Valve disassembly and inspection is an acceptable test method, however, the test frequency proposed in Relief Request R-5 for valves 3SIL-V982 and 983 is not adequate (see question F.3 above). ,

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7. Reviewthesafetyfug$iionofvalves3SIL-V32and33todetermine if they should be ingjuded in the IST program and tested to the Code requirements.

8 Review the safety function of the following valves (located on P&ID 25212-26912 Sh. 2) to determirje if they should be included in the IST program and tested to the code requirements:

3SIL-V41 3SIL-V44 3SIL-V82 3SIL-V885 3SIL-V42 3SIL-V53 3SIL-V83 3SIL-V886 3SIL-V43 3SIL-V64 3SIL-V884 3SIL-V887 G. Residual Heat Removal System

1. Do valves 3RHS-V3, 7, 25, and 42 (P&ID 25212-26912 Sh. 1 locations G-7, G-10, E-7, and E-9) have a reauired fail-safe position? If so, they should be included in the IST program and ,

be tested to the Code requirements.

2. Would failure of valve 3RHS-V4 or 8 in the closed position during quarterly stroke testing render the low pressure safety injection system unavailable to perform its safety function?

3. Provide a more detailed technical justification for not full-stroke exercising valves 3RHS-V998 and 999 quarterly during power operations.

4. Review the safety function of valves 3RHS-V24 and 41 (P&ID 25212-26912 Sh. 1 locations E-6 and E-11) to determine if they should be included in the IST program and tested to the Code requirements. ,

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H. Recirculation Spray System

1. The Code identifies valve disassembly as an acceptable method of verifying valve operability, however, the testing interval identified in relief request R-6 for valves 3RSS-V3, 6, 9, and 12 is not acceptable by the NRC staff.

I. High pressure Safety injection System l 1. Relief request R-4 is inconsistent since it provides a justification for not full- or partial-stroke exercising valve 3SlH-V5 in the basis for relief and then in the alternate testing section proposes to partial-stroke exercise this valve quarterly.

2. How are valves 3SIH-V13 and 17 partial-stroke exercised quarterly during power operations?

3. Would failure of valve 3SIH-V20 closed during quarterly stroke testing render both trains of the high pressure safety injection system unavailable to perform their safety function?

4. Can valves 3SIH-V22, 24, 26, and 28 be partial-stroke exercised during cold shutdowns utilizing residual heat removal recirculation flow?

5. Would failure of valve 351H-V93 or 100 open during quarterly stroke testing render a train of the high pressure safety injection system unavailable to perform its safety function?

6. Could exercising valves 3CHS-V259 and 260 during power operations result in the injection of refueling water storage tank water intothereactorcoolantsyftem?

7. Would failure of valve 35!H-V962 closed during quarterly stroke testing render both trains of the high pressure safety injection system unavailable to perform their safety function?

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8. Provide a more detailed technical justification for not exercising valve 3CHS-V261 during cold shutdowns.

J. Quench Spray System

1. The Code identifies valve disassembly as an acceptable method of verifying valve operability, however, the testing interval identified in relief requests R-7 and R-8 for valves 3QSS-V4, 8, 976, 977, 978, and 979 is not acceptable by the NRC staff.

2. Provide a more detailed technical justification for not verifying closure of valves 3HCS-V7 and 14 quarterly during power operations or during cold shutdowns.

3. Could failure in the open position of valve 3QSS-V30 or 31 during quarterly valve testing result in the flow of caustic chemicals into the refueling water storage tank?

4. Review the safety related function of valve 3QSS-V984 (P&ID 25212-26902 Sh. 1 coordinates E-4) to determine if it should be included in the IST program.

K. Reactor plant Component Coolina System

1. Provide a more detailed technical justification for not full-stroke exercising valves 3CCP-V18 and 60 quarterly during power operations.

2. Do valves 3CCP-V989, 990, and 991 (P&ID 25212-26921 Sh. I coordinates I-7, I-8, and I-6) have recuired fail-safe positions?

L. Main Steam and Blowdown System *

1. Provide a more detailed technical justification for not full-stroke exercising valves 3 MSS-V1, 4, 7, and 10 quarterly during power operations.

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2. What is the safety related function of valves 3 MSS-V2, 5, 8, and 117 Is this an active function?

3. Do valves 3 MSS-V12, 37, and 38 perform a safety function in the closed position? If so, how are these valves verified to close during quarterly testing?

M. Feedwater System

1. Can valves 3FWS-V15, 22, 29, and 36 be partial-stroke exercised quarterly during power operations? What is the safety related function of these valves?

2. Provide a more detailed technical justification for not full- or partial-stroke exercising valves 3FWS-V18, 25, 32, and 39 quarterly during power operations. What is the safety related function of these valves?

3. Provide a more detailed technical justification for not full- or partial-stroke exercising valves 3FWS-V20, 27, 34, and 41 quarterly during power operations.

4. Provide a more detailed technical justification for not exercising valves 3FWS-V898, 899, 920, and 921 quarterly during power operations.

5. Is credit taken for the reverse flow closure of the following auxiliary feedwater check valves? If so, how are these valves individually verified to close?

3FWA-V23 3FWA-V882 3FWA-V884 3FWA-V9 3FWA-V28 3FWA-V883 3FWA-V885 3FWA-V14 9

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6. Which auxiliary feedwater check valves prevent diversion of flow through an idle auxiliary feedwater pump when another pump is operating? How are these valves individually verified to close?

7. Review the safety function of the following valves (located on P&ID 25212-26930 Sh. 2) to determine if they should be included in the IST program and tested to the Code requirements.

Valve Valve Valve 3FWA-V6 3FWA-V27 3FWA-46 3FWA-V8 3FWA-V34 3FWA-48 3FWA-V11 3FWA-V36 3FWA-60 3FWA-V13 3FWA-V38 3FWA-62 3FWA-V20 3FWA-V40 3FWA-854 3FWA-V22 3FWA-V42 3FWA-855 3FWA-V25 3FWA-V44 N. Service Water S_ystem

1. Provide a more detailed technical justification for not full-stroke exercising valves 3SWP-V25, 27, 58, and 60 quarterly during power operations and during cold shutdowns.

2. Could failure of either valve 35WP-V33 or 65 closed during quarterly testing cause equipment damage as a result of loss of cooling flow to the component cooling water heat exchangers?

3. How are valves 35WP-V705 and 706 verified to close during quarterly testing?

4. Do valves 35WP-V14 and 47 (P&ID 25212-26933 Sh. 2 locations F-9 and F-2) have reautred fail-safe positions?

0. Instrument Air System l

1. Provide a more detailed technical justification for not full-stroke exercising valves 3IAS-V131 and 809 quarterly during power operations.

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2. Are there any valves I the air / nitrogen supply to the MSIVs and mainfeedwaterisolahonvalveswhosefailurecouldpreventthese isolationvalvesfrobperformingtheirsafetyrelatedfunctions?

} P. Fire Protection System i.

1. Arevalves3FPW-663and668(PSID8o.25212-26946Sh.2 coordinates C-4 and B-4) Appendix J, Type C, leak rate tested?

i Q. Control Buildina HVAC System,

1. Is credit taken for operability of the control room chilled water j system to meet post accident control. room habitability.

requirements? If so, all applicable active system valves should i .

be included in the IST program and be tested to the Code requirements.

R. Containment Structure Ventilation System

1. Is valve 3CVS-V19 over required to change position in order to (

} mitigate the consequences of an accident, shutdown the reactor to

[ the cold shutdown condition, or to perform any other safety  ;

related function? If so, it is an active valve and must be exercised and have its stroke time measured quarterly in accordance with the Code. If not, it should be identified as being a passive valve in the IST program.

f l S. Containment Monitorina System ,

1. Are valves 3LMS-11, 12, 13, and 14 (P&ID No. 25212-26954 l l '

l coordinates G-6, G-7, and G-8) Appendix J. Type C, leak rate I tested? .

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T. Emeroence Diesel Generator Systems

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1. 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 includ,e4'in the IST program and be tested in accordance with the Code. Review all active valves in these diesel generator sub-systems to determine if they shoul,d be included in the IST program.

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2. PUMP TESTING PROGRAM

1. How are the pump inlet pressures and flowrates measured for the c.

I service water pumps during quarterly testing?

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2. How are the pump inlet pressures measured for the MCC and rod

! control area service water booster pumps during quarterly testing?

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! 3. How are the pump flowrates measured for the boric acid transfer l pumps during quarterly testing? f 1i '

i' 4. How are the pump inlet pressures measured for the emergency generator fuel oil transfer pumps during quarterly testing?

}* 5. How are the pump flowrates measured for the steam generator j auxiliary feedwater pumps during quarterly testing? j i ,

J J 6. Provide the basis for the proposed pump vibration velocity  ;

i acceptance criteria (refer to Relief Request No. R-19).

1; c Does the "controlotron" provide readout repeatability within the

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accuracy limits of Section XI, Table IWP-4110-17 i

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8. . Are the pump vibration velocity measurements taken at the locations specified in Section XI, IWP-45107 Do the vibration  :

instruments used to make these measurements meet the accuracy and i range requirements of IWP-4110 and -41207 i j

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