ML20236C862

Requests Meeting W/Util to Discuss Inservice Testing Program Questions & Comments Listed in Encl.Date Util Will Be Prepared to Support Meeting Requested

ML20236C862
Person / Time
Site:	Peach Bottom
Issue date:	10/22/1987
From:	Martin R Office of Nuclear Reactor Regulation
To:	Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
TAC-61189, TAC-61190, NUDOCS 8710270371
Download: ML20236C862 (16)

Text

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4 October.22, 1987 Docket Nos.:. 50-277/50-278' Mr. Edward G. Bauer, Jr.

.Vice President and General Counsel-Philadelphia ElectricLCompany 2301 Market. Street:

~ Philadelphia,-Pennsylvania 19101,

SUBJECT:

PEACH BOTTOM ATOMIC POW'R.E STATION INSERVICE--TESTING PROGRAM REVIEW (TAC NOS 61189 AND161190)

The NRC staff and-its consultants'at the' Idaho' National Engineering i

Laboratory have completed a. preliminary review of the Inservice Testing Program J proposed for the Peach Bottom tomic, Power Station. lAiset of questions and.

i comments have been developed as set forth in the enclosure; IW e are requesting al meeting.to discuss these issues with.your staff, utilizing the' enclosure-as the' agenda for the meeting. We also request .that you inform us of the date.by_

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which your staff will be prepared to support this meeting.

Sincerely,

/s/

l Robert E. Martin, Project Manager:

Project Directorate I-2 Division of. Reactor Projects

Enclosure:

As stated L DISTRIBUTION: l

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SVarga/BBoger. JPartlow WButler ACRS.(10)

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october 22, 1987 k * . . * * ,/

Docket Nos.: 50-277/50-278 Mr.' Edward G. Bauer, Jr.

Vice President and General Counsel Philadelphia Electric' Company i

2301 Market Street Philadelphia, Pennsylvania 19101

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION INSERVICE TESTING PROGRAM REVIEW-(TAC NOS. 61189 AND 61190)-

The NRC staff and.its consultants at the Idaho National Engineering-Laboratory have completed a preliminary review of the Inservice Testing Program-proposed.for the Peach Bottom Atomic Power Station. A set of questions and' coninents have been' developed as: set forth in the enclosure. We are requesting a meeting to discuss these issues with your staff utilizing the enclosure-as the agenda for the meeting. We also request that you inform us of the date by which your staff will be prepared to support this meeting.

Sincerely, l

[ d Robert E. Mart'n, Project Manager Project Directorate I-2 Division of Reactor Projects

Enclosure:

As stated l

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- PEACH BOTTON, UNITS 2 AND 3 IST PROGRAM REVIEW QUESTIONS VALVE TESTING PROGRAM j

A. General Ouestions and Comments l

1. Explain the following statement taken from Paragraph 7.2, p. 7-1;

'In cases where the elapsed interval has exceeded 100% of the l specified interval, the next test interval shall commence at the end of the original specified interval." Does this statement mean that valves may not be tested at the. Code-specified frequency or at the frequency for which relief has been requested and granted? i

2. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined j by 10 CFR 50, Appendix J. Relief from Paragraphs IWV-3421 through -3425 (1980 Edition through Winter 1981 Addenda) for containment isolation valves presents no safety problem since the

- intent of these paragraphs is met by Appendix J requirements, however, the licensee must comply with the Analysis of Leakage Rates and Corrective Action Requirements Paragraphs IWV-3426 and

-3427 (1980 Edition through Winter 1981 Addenda). Additionally, those valves that serve both a containment isolation function and a pressure isolation function must be leak tested to both Section XI and Appendix J requirements. (Relief Request 7.3.1).

3. Are components subject to Section XI testing declared inoperable immediately after failure or after a certain time period?

(Relief Request 7.3.2) 1

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j.1 '4. ' Relief Requests.thatl reference the FSAR, Technical'

!- Specifications, and'other documents should be expanded to'. provide a brief~ discussion of the technical-information contained in the~

applicableLdocument.

.The NRC staff position i,5 that the emergency diesel generator air, >

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start' system'(from the' air receivers to the engine) performsLa safety-related function and that.the approprlateLvalves should be'-

included in the IST program and'testedLin accordance with Section XI. Provide the P&ID for this system forLoursreview. ,

6. The NRC staff position concerning stroke time measurements of power. operated valves is that those measurements must be trended i in:accordance'with Section XI so'the information can be utilized:

to monitor valve degradationiand predict valve failure. 'The- l exception to this position is explained-as follows.

Rapid-acting valves are defined as those power. operated valves -l that stroke in 2 seconds or less. Relief from the trending requirements of Section.XI (Paragraph IWV-3417(a). 1980 Edition.

through Wirter 1981 Addenda) presents no safety concerns for

- these. valves since variations in the stroke times.will be affected by slight variations in the response' times of the personnel performing the tests.- However, the. staff does require that the licensee assign a maximum limiting stroke time of.

2 seconds to these valves in order to obtain this Code relief.

Where this requirement cannot be met, the licensee is required to meet the Code. (Relief Requests 7.3.23, 7.3.24, and 7.3.25.)

7. Provide the limiting value of full-stroke time for all power.

operated' valves in the IST program.

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8. .The Code permits valves to be exercised during' cold shutdowns.

where.it is not practical to exerciseLduring plant operation, Land-

these val,ves'are specifically identified'by the-licensee and'are.

full-stroke exercised during cold shutdowns. LThe staff requires-thatthelicenseeprovideatechnical/justificationfor.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-

.practibal-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:

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 completeLor. 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 sh'utdowns 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 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.,

9. Provide P&ID M-367, Containment Atmosphere Control, for our review.

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10. Provide P&ID M-368, Radioactive Waste System, for ourireview..

11. Provide P&ID M-372, Containment Atmosphere Dilution System, for-our review.

12. -Provide.P&ID M-391,-Standby Gas Treatment System, for our. review.

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- 13. Provide the'P&ID that show's the Automatic Depressurization'Systemi accumulator piping system air supply check valves, q

14. The NRC position concerning instrument sensing line excessEf. low check valves.is that.these valves:do perform a safety-related.

function and that they should be': included in the IST program as Category.A/C valves.

15. Provide the P&ID that sh'ows t'he diesel generator raw water cooling system. j

16. The. justification for Relief Request 7.3.28~ states: " Existing 3 plant surveillance test procedures document most;of.the special-test conditions and parameters identified in the Subsection on IWV of Section XI." Are all parameters required by Section XI documented during surveillance testing?.

17. Is Peach Bottom Station required to have an operational safety grade post accident sampling system? -If so, the associated valves should be included in the IST program and' tested in accordance with Section XI.

18. Does the control room ventilation system perform any safety-related function?. If-so, the' appropriate support system.

valves should be included in the IST program.;

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,, 19. Review the> safety-related function'of the'reactoribuilding-cooling water system-to' determine if the system'should'be-included;in the.IST-program and the applicable components. tested in accordance with the requirements of Section-XI.

20. The NRC staff has concluded'that the applicableIleakitest procedures and requirements for containment isolation valves arec determined by.-10 CFR 50 Appendix .1, however, the licensee must comply withlthe Analysis:of: Leakage Rates and Corrective Action Requirements Paragraphs'offSection XI, IWV-3426 and -3427. .Does-the current Peach Bottom IST program meet this NRC. staff position?;

B.- Emeraency Service Water System

1. Do valves VV-33-515A and'B perform a safety function in both the open and closed positions? If so,:how'are they. full-stroke exercised quarterly?

2. How are valves VV-33-513.--514, and -516. verified to full-st'roke exercise if manual valves are utilized to isolate ~the emergency service water system from the service water system? (Relief-Request 7.3.12.)

3. Review the safety-related function of valves 2-513, 2-514, 2-516, and M0-2972 to determine if-they should be included in the IST program. (Drawing ISI-M-315 (F-2)].

C. Reactor Buildina Coolina Water System

1. Provide P&ID M-316 for our review. Also see-Question'A.19.

D. Diesel Oil System

1. Provide P&ID M-323 for our review.

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' Chilled Water System s E

1. Provide P&ID M-327 for our review.

F. Emeroency Coolina System

1. Review the safety-related function of valves M0-2804A and--2804B to determine if they should be included in the IST program andL tested in accordance with Section XI. (Drawing ISI-M-330'(C-2)]

2. Provide a more detailed technical justification for.not  ;

l- full-stroke exercising valves VV-48-0-506, 504A, and -5048 during j cold shutdowns. (Relief Request 7.3.13.)

G. Instrument Nitroaen System y

1. Provide P&ID M-333 for our review.

H. Main Steam System

1. . Describe the exercising program for the MSIVs, A0-1-80A-D and

. A0-1-86A-0. Are these valves partial-stroke and full-stroke exercised quarterly as indicated in the " Test" column? What is l

the significance of the (1) in the " Notes" column?-

! 2. Explain the significance of the (2) and (3) .in the " Notes" column cor.cerning valves RV-1-71 A-H, J-L. Dual category valves must be I ter,ted in accordance with the requirements of.Section XI that apply to each category or relief requested from those requirements as necessary.

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3. Provide a more detailed technical explanation why valves VRV-307-A-H, J-L cannot be exercised'during cold shutdowns.

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l 4. Why are valves RV-1-70-A and -B categorized B/C when.

Drawing ISI-M-351 indicates a simple relief valve?

5. Provide a detailed technical justification for not full-stroke exercising valves'M0-1-74 and M0-1-77 quarterly during power operation. What is the significance of the (9) in the " Notes" column?

1. Reactor' Recirculation System

1. What is the safety-related function of valves M0-2-43-A and -87 What is.the significance.of the (4) in the " Notes" column?

Provide a detailed technical justification for not full-stroke exercising these valves quarterly during power operation if they do, in fact, perform a safety-related function.

2. Provide a detailed technical justification for not full-stroke exercising valves M0-2-53-A and -B quarterly during power operation. What is the significance of the (4) in the "No'es" column?

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3. Review of the safety-related function of valves MO-2-54-A and -B to determine if they should be included in the IST program and tested in accordance with Section XI.

l J. Feedwater System  ;

1. Provide a detailed technical justification for not full-stroke exercising valves M0-6-38-A and -B quarterly during power l operation. What is the significance of the ('10) in the " Notes" column?

2. Review the safety-related function of valves M0-29A and -B to determine if they should be included in the IST program and I tested in accordance with Section XI.

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~ K. Reactor Water Cleanup System

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1. What is the safety-related function of valve VV-12-627 (Relief 1 Request 7.3.4.)

L. Control Rod Drive System

1. The NRC staff position is that valves CV-13-126. -127. -138, ,

-114, and -115 perform a safety-related function and.should be l included in the IST program and tested to demonstrate proper operability. (Relief Request 7.3.5).

M. Standby Liauid Control System i

1. Provide a detailed technical justification for not full-stroke exercising valves XV-11-14-A and -8 quarterly in accordance with Section XI. What is the significance of the (6) in the " Notes" column? j

2. How are valves VV-11-43-A and -B verified to full-stroke exercise with flow?

N. Reactor Core Isolation Coolina System i

1. Since valve M0-13-15 is the turbine steam supply and located inside containment; would failure of this valve while testing render an entire safety system inoperable?

2. Provide a detailed technical justification for not full-stroke exercising valve A0-13-22 quarterly during power operation.  ;

3. Provide a detailed technical justification for not full-stroke exercising valve VV-13-29 quarterly during power operation. How is this valve full-stroke exercised during cold shutdowns? How 8

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is a full-strok'e exercise of this valve verified? Should this valve be categorized A/Cf

4. How are valves VRV-13-139-A', -8, -C, and -0 individually verified l to full-stroke exercise quarterly;during power operation?

5. Provide P&ID M-360 for our review.

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6. Review the safety-related function of valves M0-13-27 and -41 to!

determine if they should be categorized A.

7. Does valve VV-13-19 perform a safety-related function in both the open and closed positions?

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0. Residual Heat Removal System l

1. Provide a detailed technical justification for not full-stroke ,

I exercising valves A0-10-46-A and -B quarterly. What is the f significance of the (5) in the " Notes" column?

2. Provide a detailed technical justification for not full-stroke ]

exercising valves M0-10-32 -33, -17, and -18 quarterly. What is 1 the significance of the (11) in the " Notes" column?

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3. What is the exercising frequency of valve VV-10-N214M37 The two j alternate test frequencies discussed in Relief Request 7.3.11 do ;l r

not agree with each other. Can this valve be full-stroke l exercised each cold shutdown.

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5. Is the stroke time.of valves SV-10-4221, -4222, and -4223 )

measured in accordance with Section XI since they are continuously in use?

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, 6. What is the identity and location of.the following valves listed on page'7-32 of Table 7.2.1? f

-A 1 RV -A RV RV -B RV -B RV -C RV -C l

RV-10-- -D RV-32 . -0

7. How are valves VV-10-19-A,.-8, -C, and -O verified to full-stroke exercise quarterly?

8. Do any of valves VV-10-51, -63, -64, -73, :-183-A, -183-B, -184-A, j and -184-B perform a safety-related function in both the open and l closed positions?

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9. Are valves VV-10-71-A and -B manual, passive valves? If not, l they must be exercised in accordance with Section XI or relief requested from the Section XI requirements for Category B

. valves. Should valves VV-10-710, -710, and -71E also be included l in the IST program?

10. What are the P&ID locations of valves M0-32-89-A, -C, and -D7

11. Review the safety-related function of valve VV-10-177 to '

determine if it should be included in the IST program. ,

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12. Review the safety-related function of valves M0-10-13A, -138,

-13C, and 130 to determine if they should be _ included .in the IST program. ,

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'9 P. Core Sprav System l

1. Review the safety-related function of valves MO-14-26-A-and -B to l determine if they should be categorized A.

2. Provide a detailed technical justification for not full-stroke I

exercising valves A0-14-13-A and -8 quarterly, What is the significance of the (5) in the " Notes" column?

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3. Why is the exercising frequency for valves A0-14-15-A and -8 ,

different than that for A and -B valves?

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4. How are valves VV-14-66-A,.-B, -C, and -D verified to full-stroke exercise-quarterly?

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5. What is the P&ID lo:ation of valves M0-14-70 and -717

6. Do any of these valves perform a safety-related function in both the open and closed positions?

VV-14 22-A VV-14-23-A l

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VV-14-22-B VV-14-23-B ,

VV-14-22-C VV-14-23-C j l

VV-14-22-b VV-14-23-D

7. Is the stroke time of valves SV-14-4224 and -4225 measured in accordance with Section XI since they are continuously in use?

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V Q. Fuel Pool Coolina System

1. Provide an. exercising frequency for valves VV-19-MK237M3 (2 valves) that meets the requirements of Section XI because "whenever the RHR system is required to cool the spent fuel pool" is not a defined test interval. .(Relief Request 7.3.14)-

2. Is credit taken in any accident analysis for operability of.the spent fuel pool couling system?

R.. Hi_ah Pressure Coolant Injection System- l

1. Provide the P&ID that shows the. system location of valve A0-23-4807.

2. Is valve M0-23-15 accessible during power operation? -Would failure of this valve.in the closed position while testing render an entire safety system inoperable?

3. Provide a detailed technical justification for not full-stroke exercising valve A0-23-18 quarterly. What is the significance of the (5) on the " Notes" column?

4. Review the safety-related function of valve MO-23-58'to determine if it should be categorized A.

5. How are valves VRV-23-140-A, -B, -C and--D individually verified to full-stroke exercise quarterly during power operation.?

6. Provide a detailed technical justification for not full-stroke exercising valve VV-23-62 quarterly'during power operation. How is this valve full-stroke exercised during cold shutdowns?

Should this valve be categorized A/C?

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7. Provide P&ID M-366 for our review.

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8. What-is the safety-related function of valve VV-23-22?

9. Does valve VV-23-32 perform any. safety function in the closed position?

10. Does valve VV-23-61 perform any safety function in the closed position?

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1 PUMP TESTING PROGRAM. .j w

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1. .Why is relief requested from measuring bearing temperatures'on all safety-related pumps except.the high pressure coolant injehtion pump? Does the required 30 minute run time result in suppression pool heating?

2. Provide the documentation that demonstrates that all parameters required by Section XI. Table IWP-3100-1, are recorded during' j pump tests. (Relief Request'6.3.3.) .]

3. The NRC position is that lack of install instrumentation is not a suitable long term justification for not performing the required g

.Section XI testing. Pump relief request 6.3.6 will be affected l by this staff position.

4. Provide a detailed technical-justification for not establishing reference values for flow and differential pressure on the RHR and high pressure service water. pumps. The NRC position is that pump reference values must be established, recorded, and compared to previous test results in order to monitor pump degradation and j l ,

to aid in predicting pump failure. (Relief Request 6.3.7.)  !

5. The NRC position concerning pump differential pressure _is that all parameters listed in Table IWP-3100-1 must be recorded during pump tests. (Relief Request 6.3.8.)

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6. Provide a more detailed technical justification for not testing

, the emergency cooling water pump and the emergency service water booster pumps in accordance with Section XI at least during cold shutdowns.

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