ML20236S144

Summary of 871014 & 15 Inservice Testing Program Working Meetings W/Util & Eg&G at Site to Discuss Questions & Comments Resulting from Review of Pump & Valve Inservice Testing.List of Attendees Encl

ML20236S144
Person / Time
Site:	Fort Calhoun
Issue date:	11/16/1987
From:	Bournia A Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8711240249
Download: ML20236S144 (24)

Text

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November 16, 1987 Docket No. 50-285 LICENSEE: Omaha Public Power District FACILITY: Fort Calhoun Station, Unit 1 s

SUBJECT:

MEETING

SUMMARY

OF MEETINGS HELD ON OCTOBER 14 AND 15, 1987 AT FORT CALHOUN STATION Working meetings were held at Fort Calhoun Station (FCS) with Omaha Public Power District (OPPD), Nuclear Regulatory Commission (NRC), and NRC consultants l

(EG&G representatives) to discuss the questions and comments resulting from the review of the FCS pump and valve inservice testing. A list of attendees and their affiliation is provided as Enclosure 1.

The purpose of the meetings were to discuss questions which were submitted to .

OPPD prior to the meeting. The questions and OPPD's responses served as the  !

agenda for the meetings which are shown in Enclosure 2. At the opening of the meeting, the utility representatives were given a brief introduction outlining the agenda and the methods used for the documentation of questions, comments, I and responses. This was followed by detailed discussion concerning specific l pumps and valves in the Fort Calhoun program. These discussions resulted in three open items for the NRC and fourteen open items for the licensee which are specifically identified in Enclosure 2.

h l

Anthony Bournia, Project Manager Project Directorate _IV J Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation {

Enclosures:

As stated i cc w/ enclosures:

See next page

! D RIBUTION

-Cocket File NRC PDR Local PDR PD4 Reading

! J. Calvo A. Bournia K. Dempsey 0GC-Bethesda E. Jordan J. Partlow ACRS (10)

PD4/PM PD4/D A N l ABournia: sr JCalvo 11/lg/87 11/M /87 l

l 8711240249 871116 PDR ADOCK 05000285 P PDR

_ _ _ _ _ _ _ _ _ _ _ _ - )

.45 4'

. i Mr. : R. . L'. Andrews Fort Calhoun Station

' Omaha Public Power District- . Unit No. 1 cc:

Harry H. Voigt, Esq.

-LeBoeuf' Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW .)

~I

-Washington, D.C. 20036

.Mr. Jack Jensen, Chairman i l

Washington County Board of Supervisors Blair, Nebraska- 68008 q 1

1 Mr. Phillip.Harrell, Resident Inspect'or U.S. Nuclear Regulatory Commission. ,j P. O. Box 309 .

.I L. Fort Calhoun,. Nebraska 68023' q Mr. Charles B. Brinkman, Manager Washington Nuclear Operations C-E Power Systems 7910'Woodmont Avenue

] ,

I Bethesda, Maryland 20814 .

Regional Administrator, Region IV.

U.S. Nuclear Regulatory Commission ,

Office of Executive Director i for Operations j d

611 Ryan Plaza Drive',. Suite 1000 Arlington, Texas 76011 Harold Borchert, Director Division of Radiological Health Department of Health 301 Centennial Mall, South P.O.' Box 95007 Lincoln, Nebraska 68509 W. G. Gates, Manager -

Fort Calhoun Station 'l 1

P. O. Box 399 Fort Calhoun, Nebraska- 68023 i

H 1

j i

--u_d-2-__._--.___2-_mm

ENCLOSURE 1 1

LIST OF ATTENDEES l INSERVICE TESTING PROGRAM WORKING MEETINGS l

NRC OPPD Anthony Bournia Rick Kellog Kenneth Dempsey Terry Patterson*

Chuck Bloyd i Jim Lechner* 1 Jeff Spilker {

John Ressler i Linda Gundrum* i Gary Gates

• l Jan Uden* 1 Bill Hansher i EG&G ,

l l

HerbRockhold l Terry Cook

• Attepded October 14, 1987 only l

l l

~l

i

.* o

. ENCLOSURE 2 FORT CALHOUN STATION IST PROGRAM REVIEW QUESTIONS I. VALVE TESTING PROGRAM A. General Questions and Comments s

1. Provide a list of all valves that are Appendix J, Type C, leak rate tested and not included in the IST program and categorized A 3 i

or A/C.

Response

The following valves will be included in the IST program as Category A j l

I or A/C as applicable and tested to the requirements of Appendix J.

l HCV-821A and B A/HCV-742 HCV-820A and B RC-147 B/HCV-742 I

C/HCV-742 0/HCV-742 l

HCV-883A and B l HCV-884A and B 1

l Valves HCV-334 and HCV-335 are not required to be leak rate tested per -

Appendix J and, therefore, need not be Categorized A in the IST program.

2. The NRC differentiates, for valve testing purposes, between the cold shutdown mode and the refueling mode. That is, for valves l identified for testing during cold shutdowns, it is expected that the tests will be performed both during cold shutdowns and each refueling outage. .However, when relief is granted to perform 1

tests on a refueling outage frequency, testing is expected only.

during each refueling outage. In addition, for extended refueling outages, tests being performed are expected to be.

maintained as closely as practical to the Code-specified frequencies.

Response

The staff position was explained to the licensee.

i

3. Relief Requests that reference the FSAR, Technical Specifications, and other documents should be expanded to provide a brief discussion of the technical information contained in the applicable document.

Response

A brief discussion of the applicable Technical Specification requirement will be provided in any relief request or cold. shutdown justification that references a Tech. Spec.

4. Does the spent fuel pool cooling system perform a. safety-related function? If so, the appropriate pumps and valves should be included in the IST program.

l

Response

The licensee feels the spent fuel pool cooling system does-not perform a specific active function in shutting down the reactor or mitigating the consequences of an accident. .A safety grade make-up water supply.

is available _from the transfer canal drain pumps and the safety injection refueling water tank.

The spent fuel pool cooling pumps and valves need not be included in the IST program.

2

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__________,m_ m_

I The NRC position is that the' emergency diesel generator. air start

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S.

system and the fuel oil transfer system perform a safety-related function and that the appropriate: pumps and. valves should be included in the IST program and tested in accordance with Section XI.

Response

t The licensee was informed that the~NRC staff expects that the diesel j air start solenoid valves and the compressor discharge check valves-are required to be included in the IST program and tested to the requirements of Section XI.

This staff position also applies to the diesel fuel oil transfer pumps l

and valves.

This is an OPEN ITEM for the licensee to evaluate this. staff position.

6. Has a reactor vessel head vent system been installed at Fort Calhoun? If so, the appropriate valves should be included in the IST program.

Response

0

' Valves HCV-176, -177, and -180 will be included in th'e IST program as Category B valves. These valves cannot be eFerCised. quarterly during W

power operation since this would vent the high temperature /high i pressure reactor coolant systen to the quench tank. .These. valves will be exercised and stroke timed and the licensee will.further'esalvate '

the possibility of testing these valves dur.ing cold:shutdowe.s.

(However, the test interval may have to be extended to: refueling' outages.)

7. Does the control room ventilation system perform a safety-related function? If so, the appropriate. support' system valves should be-included in the IST program. + l 3-4 ,

m

~

Response

The licensee stated that Appendix M indicates the control room would continue to function in the event of loss. of air' conditioning. The-CCW valves providing cooling to the_ air conditioning.for the control room need not be. included in the'IST. program. s

8. Valves that are' identified as passive in .the IST program do not require a request for relief from exercising according to IWV-3700.

Response

Relief requests for not exercising passive valves will be deleted.

9. Provide the documentation that ensures that IWV-3300.is being -

met. (42 mote position indication verification).

Response

The.remte valve position indication is verified to be accurate in accordance with the Code. A statement to'this affect will be included-in the IST program.

10. Provide the~ documentation that ensures that IIWV-3415 is being .

met. (Fail-safe testing of valves.) .;

I a

.I Respong :  ;

Thefail-safe-testingofvalvesthat,havearequNytfail-safe l position wil.1 be performed in accordance with.Section XI IWV-3415  :

1

11. Provide a list of all power operated valves in' the IST program '

i that are not stroke timed when they are exercised?. --

l l ll; l

i I, ;4 1

.q

l. '.I

Response

All power operated active valves will have a maximum permissible stroke time identified in the IST program.

B. Containment Heating, Cooling and Ventilating System (11405-M-1)

1. Do valves A/HCV-742, B/HCV-742, C/HCV-742, and D/HCV-742 (E-3) perform a containment isolation function? Should they be included in the IST program and categorized A?  !

Response

This is an OPEN ITEM for the licensee to further evaluate all safety functions of these valves. These valves do not receive any safety

^

signal to close and remain open during all accident scenarios.

However, the B, C, and D valves are closed during portions of the Appendix J leak rate. testing.

2. If the following valves are leak rate tested as containment isolation valves they should be included in the IST program and i

categorized A.

HCV-821A (E-5) HCV-883A (E-5) .

HCV-8218 (E-5) HCV-883B(E-5)

HCV-820A (E--5) HCV-884A(E-5)

HCV-820B (E-5) HCV-8848(E-5)

Response

These valves will be included in the IST program as category A valves and tested to the Code requirements.

5 m_...-..__ .-_.m.__ _ __.m_uu

C. Demineralized Water System (11405-M-5)

1. Review the safety function of valve DW-163(H-4) to determine if it should be included in the IST program and categorized A/C.

Response

i Valve DW-163 is not currently leak-rate tested as a containment isolation valve and need not be included in the IST program.

O. Vaste Disposal System (11405-M-6 and 11405-M-7) l

1. What is the normal position of valve WD-816 (M-6, E-3)? Should a this valve be included in the IST program and categorized A?

Response

Valve WD-816 is not Appendix J 1eak rate tested as a containment .

isolation valve. This is a normally open manual valve and need not be included in the IST program.

E. Component Cooling System (11405-M-10 and 11405-M-40)

'l

1. Provide a more detailed technical justification stating why valves HCV-425A, HCV-4258, HCV-425C, and HCV-4250 cannot be exercised during cold shutdown.

l l Response:

These valves will be exercised during cold shutdowns. j

2. Provide- a more detailed technical justification stating why the ,

reactor coolant pumps cannot be stopped to allow exercising valves HCV-438A, HCV-438B, HCV-4580, a.,d HCV-438D during cold shutdowns, j 6 I i '

1 1

w

'- . Response:

The RCp seal water is not. normally stopped during cold shutdowns. The-pump manufacturer also requires seal flow whenever RCS temperature is greater than approximately 130'F. These. valves will be exercised during cold shutdowns when the' RCPs are stopped and RCS temperature 'is

<130*F and during-each refueling outage.

3. In reference to the exercising frequency'of valves HCV-467A, B, C, and D, what are the consequences of failure to met Technical Specification 2.13?

Response

These valves will be exercised during cold: shutdowns because failure

~

in the closed position could result in exceeding the Technical Specification concrete temperature limit and could also affect ex-core nuclear instrumentation. The cold shutdown justification will be supplemented with this information.

4. What are the consequences of a loss of cooling water to a containment air cooling unit? Refer to the Relief; Request for l HCV-400A-D, -401A-D, -402A-D, and -403A-D. Should these valves i be categorized A?

.]

-i Response:  ;

d This is an OPEN ITEM fee the licensee to further' evaluate the exercising frequency for these valves (cold shutdown of quarterly). .. )

These valves are not currently leak' rate ' tested per Appendix J since the sy> tem pressure .is greater than peak accident pressure and ,is f assumed to be operating post-accident. t

5. Review the safety. function of the following: valves to determine. 1 if they should be included 'in' the IST program. (11405-M-10) 7

, .t

i i

HCV-2898A(A-2) HCV-2814A (G-3) HCV-2809A (G-4)

HCV-28148 (F-3) HCV-28098 (F-4)  :

HCV-28988 (B-2) J HCV-2899A(A-3) HCV-2815A (G-3) HCV-2810A(G-4) i HCV-2899B(B-3) HCV-2815B (F-3) HCV-28108 (F-4)

HCV-480 HCF-2813A (G-3) HCV-2811A(G-5) j HCV-28118 (F-5) {

HCV-481 (A-4) HCV-2813B (F-3) i i

HCV-484 (B-4 HCV-2808A (G-3) HCV-2812A(G-5))

HCV-485 (B-4) HCV-2808B (F-3) HCV-28128 (F-5)

HCV-478 (D-4) l

Response

i Valves HCV-480, -481, -484, -485 and -478 will be included in the IST program as Category B valves and tested to the Code requirements.

The remainder of the listed valves need not be included in the IST j

program since they are either passive or non-safety related.

6. Do valves AC-101, -104, and -107 perform a safety function in both the open and closed positions? If so, they should be l exercised to both positions. l

Response

i l

These valves do perform a safety function in the closed position and will be identified as such in the IST program and verified to close quarterly.

F. Instrument Air System (11405-M-264 Sheet 1 of 5) j

1. Provide a more detailed technical justification stating why valve PCV-1849 cannot be exercised during power c;eration and cold shutdowns.

8

Response

Failure of valve' PCV-1849 in the closed position 'during testing would result in other valves that are supplied with' air through PCV-1849 f ailing in their f ail-safe positions and could result in a plant -

shutdown.

This is an OPEN ITEM for the licensee to determine if this valve can be exercised during cold shutdowns.

l G. Chemical and Volume Control system (E-23866-210-120' and E-23866-210-121)L

1. Provide a more detailed technical explanation stating'why valves TCV-202 and HCV-204 cannot be exercised during cold shutdowns.

1

Response

These valves will be exercised during cold shutdowns.

2. . Provide a more detailed technical justification stating why the reactor coolant pumps cannot be stopped to allow' exercising of salves HCV-206 and HCV-241 during cold shutdowns.

Response

The RCP seal water is not normally stopped during cold shutdowns. The pump manufacturer also requires seal flow whenever RCS temperature is greater than approximately 130 F. These valves will'be exercised during cold shutdowns when the RCPs are stopped and RCS temperature is

<130*F and during each' refueling outage.

3. What alternate system configurations have been investigated.to

allow full-stroke exercising of> valve I.CV-218-2 during cold 1

shutdowns? ..

9 .

. . - _ _ _ . _ _ _ _ _ _ _ . ,_m

Response

Valve LCV-218-2 will be exercised during cold shutdowns.

4. Provide a more detailed. technical justification for-not' :

> full-stroke exercising valves .HCV-240. and -249 quarterly , Review the safety function of valve CH-205:(A-8,.E-23866-210-120, Sheet 1) to determine if'it'should be included in .the IST program.

Response

Valves HCV-240 and -249 cannot be exercised quarterly since a' thermal shock to the pressurizer, spray nozzle would occur; resultingein :

premature failure of. the nozzle and ~a large scale RCS pressure transient would occur that could cause plant shutdown. 1These valves will be'. exercised during cold shutdowns.

Valve CH-205 will be included in the IST program as a.. category C valve

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and exercised during c'old shutdown'in conjunction with .the exercising _

of the above block valves.

1

5. What-alternate- system configurations..have been in'v estigated to allow full-stroke exercising valves HCV-258, HCV-265,' and HCV-268 during cold shutdowns?

Response

These valves will be exercised during cold shutdowns.

6. Review the safety function of valve CH-198.to' determine'if it should be categorized A/C. Provide a more detailed technical .

~

explanati'on stating why this valv'e cannot'be full-stroke.

exercised during cold shutdown.

10

= - _ - _ _ ____ __:_ __-_ _

.a Response: 4 1

Valve CH-198 is not currently leak rate tested per Appendix.J, therefore, it need not be categorized A/C. This valve is full-stroked '

open during normal plant operation'.

7. Review the safety functions of the following valves to determine.

if they should be included in the.IST progras (E-23866-210-120, Sheet 1).

CH-166 (I-4) CH-156 (G-2) CH-189(E-7)

LCV-218-3 (G-2) CH-187 (E-2) LCV-101-2 (B-2) l LCV-218-1(I-1) CH-188 (E-4) LCV-101-1.' ( B-2)' l i FCV-269Y E-238866-210-121 (C-7) . )

CH-149 E-238866-210-121 (C-7) I Response: .,

j J

OPPD states that no credit is taken for'the opera:ility of the l charging pumps in any accident scenario.

l This is an OPEN ITEM for NRC to further evaluate this condition.

Valves CH-187, -188, and -189 may be deleted from the IST program if the charging pumps do not perform a safety function. :We agree these  ;

valves perform no safety function in the closed position.

Valves LCV-101-1 and -2 perform no safety-relatec function and need not be included in the IST program.

This is an OPEN ITEM for the' licensee to determine if credit is taken for an emergency boration 'f'owpath.

i 11

H. Safety Injection System (E23866-210-130)

1. Are valves HCV-347 and HCV-348 passive valves?. Why is stroke time not measured?

Response

HCV-347.and -348 are not passive valves and should be exercised and stroke timed during cold shutdowns. These valves cannot be exercised .

quarterly since they are interlocked closed when RCS pressure is

>250 psia.

2. Are valves LCV-383-1 and LCV-383-2 interlocked with valves HCV-383-3 and HCV-383-4 such that failure of one valve.to operate would prevent operation of the others? Could that failure result in failure of any safety injectior systems?

Response

The answer to both questions is no. These valves will be exercised, and stroke timed quarterly.

3. Provide ~a more detailed technical explanation stating why valves HCV-2916, HCV-2936, HCV-2956, and HCV-2976 cannot be full-stroke exercised at the Code specified frequency.

Response

If failure in the open position occurred while testing, the Technical Specification Limiting Condition for Operation states that the plant must be shut down within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to the inability to maintain safety injection tank levels. These. .

valves will be exercised and stroke timed during cold shutdowns.

12

4. Review the safety functions of the following valves to determine i if they should be categorized A/C. How.are these'. valves j full-stroke exercised and what'is the frequency of that exercising?

SI-194 SI-200 51-208

'SI-195 SI-201 51-212 l a

SI-197 SI-203 SI-216-  !

SI-198 SI-204 SI-220 j

Response

l \

The following valves will continue to be categorized A check valves. s SI-194 SI-200 SI-208:.51-195 SI-201 SI-212- ]

SI-197 SI-203 SI-21'6 {

SI-198 SI-204. 51-220- 1 This is an OPEN ITEM for the licensee'.to further evaluate.the full-stroke exercise test method and frequency for the following valves. .

! a

! SI-208 SI-207 l

SI-212 SI-211 '

SI-216 SI-215 SI-220 S1-219 l '

The following valves are full-stroke. exercised open during refueling outages because exercising;during cold shutdowns could: result in a Llow .j

, temperature-overpressurization of the reactor' coolant' system:

SI-195 51-198 S'l-201 51-204' j t

1 h

L13-p.

2_-_-__:. - _

m ,

, .i

- It is an OPEN ITEM for the licensee to determine.if the following j valves can be full-stroke exercised during' cold snutdowns utilizing l residual heat: removal capability:

51-194 SI-197 SI-200 SI-203

5. What alternate system configurations have been investigated toi allow full-stroke exercising valves HCV-344 and HCV-345 during- t

)

power operation and cold shutdowns? Are these two valves leak j l

rate tested in accordance with Appendix J?-

1 Response: l HCV-344 and -345 will be exercised during cold shutdowns when the a inside containment manual isolation valves can be closed to-prevent .

the possibility of spraying containment.

These valves are not required to be leak rate tested per Appendix J, therefore, they will not be categorized A.

6. Provide a more detailed technical justification explaining why- -i valves Sf-100 and -113 cannot be full-stroke exercised quarterly.  !

1 i

Response

The only full flow flowpath for these check valves is into the RCS and the HHSI pumps cannot overcome normal operating RCS pressure. Testing i these valves during cold shutdowns could result'in a low temperature-overpressurization of the RCS. These' check valves will be j full-stroke exercised during each refueling outage during the -

safeguards testing.  ;

7. Provide a more detailed technical .i;stification explaining why valves SI-139 and -140 cannot be 'ull-stroke exercised during cold shutdowns.

'i 14 a

_--_._=_w

Response: ,

'l SI-139 and -140 can only be full flow exercised open during refueling j i

when the full flow flowpath is,available for the quantity of water- i required to full-stroke exercise these check valves. J l

i;

8. Provide a more detailed. technical explanation why valves SI-121 and SI-129 cannot be full-stroke exercised during shutdown cooling operations.

Response

Valves SI-121 and -129 may be full-stroke exercised during cold. ,

1 shutdowns. This is an OPEN ITEM for the -licensee to determine if full ]

accident flow through these valves can be achieved during cold shutdowns.

9. Explain why the containment spray test line (6 in. SI-601R) cannot be' utilized to exercise the containment spray pump discharge check valves during cold shutdowns?' .,

J

Response

Test line 6" SI-601 R cannot be utilized during cold shutdown since both shutdown cooling heat exchangers are required to be operable /available. Check valves SI-135, -143,'and -149 will be full-stroke exercised during each refueling outage.  ;

10. In reference to valves SI-159 and -160,.the NRC staff position is

-that disassembly of check valves is an acceptable alternate method to utilize to full stroke exercise check valves' and~that the disassembly be performed each refueling cutage on a. sampling l basis instead of at the frequency proposed.

4

.15

]

S

Response

The NRC staff position on sample disassembly was explained to the:

licensee. The licensee has explained the problems with' disassembly' :l (i.e., rad waste, ALARA, etc.) of these._ valves. j This is an OPEN ITEM for the licensee to furtha evaluate a' test frequency for these valves. 4 1

11. Review the safety' function of valves SI-175 and SI-176 to i determine if they should be categorized A/C. How are these l

valves full-stroke exercised during refueling outages?  !

I

Response

l i

These valves are not required to be leak rate tested per Appendix J. l This is an OPEN ITEM for NRC to evaluate the licensee's' statement that a I

the containment spray system is redundant to the containment air i filtration and cooling system and therefore n'eed not be exercised.

(Refer to Technical Specification 2.4 Bases) H 1

12. How are valves SI-207, SI-211,51-215, and 51-219 full-stroke exercised during refueling outages? _ j

Response

This is an OPEN ITEM for the licensee to further evaluate the full-stroke exercise test method and frequency for these valves. )

13. Review the safety function of the following valves to determine-if they perform a safety-related function. If so, they should be-included in the IST program. (Sheet 1)_ i I

16

a

.)

HCV-304(E-7) HCV-2937.(R-5) FCV-326 (D-5).

HCV-305 (E-6)

HCV-2938 (F-5) ' HCV-335 (E-4)L j HCV-2947 (H-4)_ HCV-2987 (B-6) l HCV-306(0-7) J HCV-307 (D-6) HCV-2948 (F-4) SI-323 (C-6) ]

HCV-2907 (G-7) HCV-2957 (H-3) HCV-308(0-6)

HCV-2908 (F-7) HCV-2958 (F-3) HCV-2988(D-6)

HCV-2917(G-7) HCV-2967 (H-3) i HCV-2918 (F-7) HCV-2968 (F-3) 1 HCV-2927(G-6) HCV-2977 (H-2) i HCV-2928(F-6) HCV-2978 (F-2) l

Response

I Valves HCV-308 and -2988 will be included in the IST program as category B valves and tested during cold shutdowns.

Valve HCV-335 performs no safety function in the open position. This valve is normally closed and is considered passive,:therefore, it need not be included in the IST program.

1 Valve SI-323 will be included in the IST program as a category C check valve. This valve can be verified to full-stroke open only during safeguards testing during each refueling outage since'.this is the only time a full flow flowpath is available for this system.

This is an OPEN ITEM for the licensee to determine if this valve l

performs a safety function in the closed position and, if so, how closure capability is verified.

9 All other valves in this list are locked open in their safety function l position and need not be included in the IST program.

i

14. Review the safety function of the following check valves to -

determine if they must_ change position to provide pump minimum flow protection. If so, then they should be included in the IST program. -(Sheet 1) .

l 17 ')

1

.- l SI-104 (F-7) SI-304(F-4) SI-301 (F-2)

SI-110 (F-6) SI-303 (F-4)51-300 (F-1)

SI-117 (F-5) SI-302 (F-3)51-153(F-1)

Response

These valves will be included in the IST program as category C valves  ;

and exercised to the open position quarterly. These valves perform no safety function in the closed position.

15. How are valves SI-208, -212, -216, and -220 full-stroke exercised?

e

Response

This is an OPEN ITEM for the licensee to further evaluate the full-stroke exercise test method and frequency for these valves.

d

16. Do the following valves perform a pressure boundary isolation function and should they be categorized A/C7 l

SI-207 SI-219 SI-216 SI-195 SI-211 SI-208 SI-220 SI-196 51-215 SI-212 SI-194 SI-197 SI-198 51-200 SI-202 SI-204 SI-199 5I-201 SI-203 SI-205

Response

l The following twelve valves are identified in the Technical Specifications as pressure boundary isolation valves, are leak rate {

l tested, and are categorized A in the IST program: j l

1 SI-198 SI-201 SI-203 J l

SI-208 SI-216 SI-195 51-212 51-220 51-197 51-200 S1-194 SI-204 1

18 l

1 i 1

1 L _-

7 i

l J

The remainder of the valves listed are not leak rate tested as pressure isolation valves,

17. Review the containment isolation function of the following valves j to determine if they should be included in the IST program, l categorized A/C, and leak tested-in accordance with Appendix J.

(Sheet 2)

I SI-222(H-1) SI-188 (H-5) SI-190 (H-7) l l

SI-187(H-5) SI-189(H-6) j l

Response

l These thermal relief valves are inside containment and discharge into the containment. These valves are not required to be leak rate tested l per Appendix J, therefore, they need not be categorized A in the IST i program.

l I. Raw Water System (11405-M-100) i

1. Review the safety function of the following valves to determine if they should be included in the IST program.

HCV-400E (F-1) HCV-403E (F-2) HCV-482A (F-3) j HCV-400F(G-1) HCV-403F (G-2) HCV-4828 (G-3)

HCV-401E (F-1) HCV-2898C (F-2). HCV-483A (F-3)

HCV-401F (G-1) HCV-2898D (G-2) HCV-4838(G-4)

HCV-402E (F-1) HCV-2899C (F-2) HCV-2813C (D-5)

HCV-402F(G-1) HCV-28990 (G-2) HCV-28130 (E-5)

HCV-2808C (E-5) HCV-2812C (E-5) HCV-2809C (F-5)

HCV-2808D(E-5) HCV-28120 (E-5) HCV-28090 (F-5)

HCV-2810C (E-5) HCV-2811C (F-5) HCV-2815C (F-5)

HCV-2810D(E-5) HCV-28110 (F-5) HCV-28150 (F-5)

HCV-2814C (F-5) HCV-2814D (G-5) CV-188 (C-4)

CW-189 (C-4)

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Response

This is an OPEN-ITEM for the licensee to determine if the raw water'to-CCW interface valves are safety-related.'

2. Do valves. RW-115, -117, -121, and -125 perform a safety function in both the.open and shut positions? If so, they should be.

exercised to both positions.

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Response

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These raw water pump discharge checks do. perform'a safety function in' the closed position and will be verified to close quarterly.

J. Main Steam System'(11405-M-252)

1. Review the safety functions of the unidentified . check. valves installed in the-auxiliary feedwater pump turbine steam supply lines to determine if.they should be included in the IST program and individually! verified to full-stroke exercise. q

Response

The valve identifiers are MS-351 and MS-352.

AFW turbine steam supply check valves MS'-351'and -352 perform a safety function in the open position to supply steam to the AFW turbine and are partial-stroked open at least quarterly.

This is an OPEN ITEM for the licensee to determine a method and frequency of full-stroke exercising these check valves.

It is also an OPEN ITEM for the licensee to determine'if these;. check!

valves perform a safety function in the. closed; position. .

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2. Review the safety function of.the.following valves to' determine-2 if they should be included in the'IST program.

HCV-10418 (B-1) hCV-10428 (B-2)-

HCV-1040 (B-1)

Response

Valves HCV-1041B and -1042B are assumed to fail open in the accident analysis for steam line break and are identified'as non-codeLclass.

valves. These valves need not be included in the IST. program.

Valve HCV-1040 is non-code class and non-safety related and need not be included in the IST. program.

3. Provide a detailed technical justification for not full-stroke exercising valves HCV-1041A and -1042A during cold shutdowns? '

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Response

.] i Valves HCV-1041A and -1042A, MSIVs, will be ful'l-stroke exercised and- I i

streke timed during cold shutdowns.

-l K. Steam Generator Feedwater System (11405-M-254 and'11405-M-253)'

1. Do valves FW-161 and FW-162 perform a safety function in the closed p sition? If so, they should be exercised to that position. ,

Response

The licensee has . stated tha, +hese ' valves perform no : safety function in the closed position. The up'. 'oam motor operated valves perform-  :

the feedwater header isolation,funct 9 ,

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2. How are valves FW-173 and FW-174 full-stroke exercised quarterly?

Response: ,

Valve FW-173 can be full-stroke exercised only during' cold shutdowns:

as stated in the.new relitf request. Valve'FW-174 can be full-stroke exercised open only during refueling outages by valve disassembly.

These valves will be verified closed quarterly.

3. Review the safety function of valves FCV-1368 (C-5), FCV-1369 (D-5), and FW-672 (0-5), P&ID M-253, to determine if they should be included in the IST program. .

Response

Valves FCV-1368 and -1369 are normally open and failure in the open position would not result in less than safety flowrate. to the -steam generators. These valves need not be included in the IST program.

Valve FW-672 will be include'in the IST program and verified to open quarterly during AFW pump testing.

l L. Reactor Coolant System (E-23866-210-110) i 1. The NRC position is that the PORVs should be included :in the IST program and should be exercised during cold shutdown or: prior to establishing conditions where the PORVs are utilized for '

low-temperature overpressure protection. ' Additionally, normally open p0RV block valves should be included in the IST program and exercised in accordance with Section XI to. provide leak-protection in the event that the PORVs should fail open..

Response

Valves HCV-150 and -151 will be included in. the'IST program as Category B valves and will be exercised.ona cold. shutdown frequency.

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The PORVs are never exercised, however, the . pilot valves may be exercised during surveillance test ST-PORV-1 prior to cooldown below :

300 F.

This is an CPEN ITEM for NRC to evaluate the adequacy of this (Reference T.S. 2.1.6 (5))

testing.

II. PUMP TESTING PROGRAM A. Provide a more detailed technical explanation stating why pump test data cannot be analyzed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of completion of pump testing.

Response

Data obtained during pump testing will be evaluated within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> af ter completing pump testing. The Code requirement is' met.

B. The NRC position is that both flow and differential pressure be measured during the performance of pump testing, i.e.,'all quantities required by Table IWP-3100-1 should be recorded and that lack of ,

installed instrumentation is not a suitable long term justification for not performing the required Section XI testing.

Response

1 A discussion of measurement of pump flowrate and differential pressure was held and the licensee need not install any more instrumentation to satisfy the Section XI requirements as a result of this meeting.

1 Response: .;

C. Provide the documentation that demonstrates that the low pressure safety injection and containment spray pumps are tested in accordance with Section XI?

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. 1 The test para ,eters at the bottom of page 19 of the IST program apply 1

to all pumps listed on that page and not only the HPSI pumps.

i Additional Comments:

Pump rotative speed will be measured for the turbine driven auxiliary ,

feedwater pump during quarterly testing. )

Pump relief request on instrumer,tation dated August 18, 1987 is sati sf actory.

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