ML20087N374

Forwards Response to 840223 Request for Addl Info Re Proposed Programs for Inservice Pump & Valve Testing

ML20087N374
Person / Time
Site:	Hatch
Issue date:	03/26/1984
From:	Gucwa L GEORGIA POWER CO.
To:	Stolz J Office of Nuclear Reactor Regulation
References
NED-84-159, TAC-11260, TAC-11261, NUDOCS 8404030386
Download: ML20087N374 (6)

Text

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• Georgia Power Corrpany 333 Piecmont Avenue

• At!anta, Georg>a 30300 Telephore 404 5266526 Ma. ling Address:

Post Off:ce Box 4545 Atlanta. Georgia 30302 Georgia Power L T. Gucwa tv southern electrc spre.m Manager Nuclear Erg:reerng and Chief Nuclear Eng.neer NED-84-159 March 26, 1984 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz, 011ef Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Cannission Washington, D. C. 20555 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 EDWIN I. HATCH NUCLEAR PLAhT UNITS 1, 2 ADDITIONAL INFO 1 NATION - INSERVICE TESTING PROGRAMS Gentlenen:

Pursuant to your request of February 23, 1984, enclosed as Attachnent 1 is additional information concerning the proposed prograns for the inservice testing of pinps and valves for Plant Hatch Units 1 and 2. The proposed prograns were subnitted to you for review by our letter dated August 12, 1983. For your convenience during the review process, the HEC questions -

have been repeated in our response.

Should you have any questions in this regard, please contact this office.

Sincerely yours, lV &"

L. T. Gucwa JAE/Dbu '

Attach 1ent xc: H. C. Nix, Jr.

Senior Resident Inspector J. P. O'Reilly (NRC Region II)

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8404030386 840326 PDR ADOCK 05000321 P PDR 1\

B ATTACINENI' 1 RESPONSE 'IO RECUES'T FOR ADDITIONAL INECENATION RELATED

'IO 'IEE HA'IGI PROGR.HS FOR INSERVICE TESTING OF PLMPS AND VALVES A. PLMPS - HA'IGI UNITS 1 & 2

1. Please justify why Fuel Oil Transfer pmps should not be included in the IST Progra and tested to meet Code Requirements.

Response

As addressed in our letter dated August 12, 1983, it is the position of Georgia Power Cmpany (GPC) that the Diesel Generator Fuel Oil System is not within the scope of ASME Section XI as defined in NRC Regulatory Guide 1.26, i.e., it is not steam or water containing. For your further information the following is provided:

%e design arrangenent of the system provides for five 40,000 gallon storage tanks each supplying a 1000 gallon day tank. Each storage tank has two 100% capacity transfer pmps that czn transfer diesel fuel to the day tank. In addition, through a header arrangenent any day tank can be filled using any one of the ten pmps.

%e operability of these pumps is verified monthly by Technical Specification requirements. Adequate testing exists, plus frm the above description the loss of a pmp will not prevent transfer of fuel oil to the day tank. %e incorporation of these peps into a Section XI-type testing program is, therefore, not justifiable.

2. Standby Liquid Control peps C41-0001 A & B. Please elaborate on the Basis of Relief Request 7.1.2; i.e., how is this quarterly 2-minute test performed?

Response

Standby Liquid Control (SBIC) is aligned so that each pmp takes suction fra a denineralized water source and discharges through a throttle valve to a test tank. %e pmp is placed into operation and the throttle valve adjusted to obtain a reference discharge pressure. %e level of the test tank is then measured and the pmp then run for two minutes. After the two minute run the tank level is again measured. Flowrcte is then determined by the following equation:

Flow (gpn) = A Tank level (in.) x 4.81 gal./in.

2 min.

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For a situation in which the flowrate is measured by instrument a

, 0-100 gpn instrment . would normally be used for the SBIC pmp flowrate of approximately 43 gpn. %e raiuired accuracy of this instrunent would be + 2% or + 2 gpn. ~

%is corresponds to + .83 inches of water levefin the test tank. %erefore, the accuracy of

' the measured flowrate should be well within code allowable.

3. Relief Request 7.1.3.1. Please define P and Po and verify which value of the conversion factor (0.0433 or 0.433 psig per foot of water is applicable) .

Response ,

% e sguation should read:

A P = Po + (114.5' - River Water Level) x 0.433 where AP is the differential pressure and Po the outlet pressure.

3 B. VALVES - HA'ICH UNITS 1 & 2

1. Does the licensee desire relief from IW-3417(b) and IWV-3523 to permit plant startup with an inoperable valve when permitted by Technical Specifications? Such a request was. subnitted with the initial Valve %st Progran but not with the August 1983 revision.

Response

2e following relief request should be added to the progran:

6.1.23 Test Requirenent IWV-3417 states that when corrective action is required as a result of tests made during cold shutdown, the condition shall be corrected before startup.

6.1.23.1 Basis for Relief Under such conditions startup shall be permitted as

provided in the Technical Specifications.

2. . Relief from Code requirenents (Request 6.1. 5) is raguested for valve C41-F006. Is the sane relief requested for valve C41-F007?

Response

Relief Request 6.1.5 also applies to valve C41-F007.

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3. During the June 23, 1983 meeting between Georgia Power Cmpany and NRC personnel, the NRC staff elaborated on its position that all Category A and B safety-related valves (including air-operated pressure and modulating flow control v::lves) should be strok e-tined. %is test verifies the capability of a valve to perform its safety function as well as ensures that the valve hasn't degraded. In the Valve Test Progres for both Hatch units, Notes 6, 8, 9 and 10 reference subsection IWV-1200 of Section XI of the ASME Code as the basis for not stroke timing the following valves.:

Ell-F068 A & B E51-F105 Ell-F200 A thru D E51-F109 E41-F035 P41-F208 A thru D

%e NRC staff has been advised by the AENE that the exmption provided by IWV-1200 applies to valves that are used only for the purposes listed in this subsection. Please review your relief raluests for the valves listed above and either verify that these valves never provide a safety function or else cmmit to stroke test any valve that may be safety-related.

Response

narther evaluation of the failure of these valves to perform their designated function is required. This evaluation is to be supplied to GIC by its architect-engineer by April 30, 1984. After review by GPC, the results of the evaluation will be transmitted to NRC.

4. 'IVelve air operated valves in each unit's Plant Water Systs (P41-F035 A & B, F036 A & B, F037 A & B, F039 A & B, F040 A & B, and F042 A & B) will be stroke-timed with a maximum time as the only acceptance criterion. We approve this alternative test if the maximm stroke time will accurately reflect degradation of the valve. Please provide the values of the maximm stroke times that will be used in testing these valves.

Response

ne test procedures for these valves have not been implemented.

%ey are scheduled for implementation prior to startup frm the present or future planned maintenance / refueling outage. After impleentation a baseline value will be established and furnished to the NRC.

5. Valves E21-F036 A & B - We agree with the basis that these contalment isolation check valves cannot be verified to be closed and fulfilling their isolation function except during the integrated leak test. Please justify why disassenbly of these valves on a periodic basis would not provide greater assurance of their operability, or ccmnit to such an alternative test.

3/26/84

Response

%is valve has been designated as an inboard contalment isolation valve in the Appendix J progrm; therefore, it was included in the inservice testing progrm. As discussed in the relief rq uest this valve is sealed from the primary contaiment because the test line terminates below water level and outboard of the valve is a seimic seal water systs. %erefore, any leakage through the valve during a loss of coolant accident (ILCA) would not be released to the environment. %e integrated leak rate test (ILRT) is considered to be adequate testing. Disassembly of this valve for inspection would not increase the level of safety and is not considered justifiable.

6. Valve E41-Flll - In the initial Valve Test Progras for Units 1 & 2 relief was rquested for this valve from the leak rate test rquirments of IWV-3420(c) of the 74S75 ASME Code. hty is the same relief (from the requirements of INV-3423 of the 80W80 ASME Code) not rquested in the revised Valve Test Progres?

Response

Relief Rm uest 6.1.2 applies to valves E41-F111 and 2E41-Fill.

7. Valve E51-F015 (sic) - Note 10 in the Unit 1 Valve Test Progra states that the licensee considers this valve exmpt frm stroke timing (See Question 3 above) but the Program indicates that stroke timing will be performed. Please clarify. Also, please clarify why relief rquest 6.1.2 applies to this valve in the Unit 2 Valve Test Progr a and to valve E51-F104 in the Unit 1 Test Progr m .

Response

" Note 10" was an error and should read "Qtr". Relief Equest 6.1.2 should apply to valves E51-F105 and 2E51-F105.

8. Valves 2P41-F339 A & B and 2P41-F340 in the Diesel Generator Cooling systs are included in the Valve Testing Progra for Unit 2 while the equivalent valves (P41-552 A, B, and C and P41-533 A, B, and C) are not included in the Unit 1 Progrm. Please justify this difference.

Response

Valves 2P41-F339 A & B and F340 are air-operated (AO) butterfly valves. P41-F552 A & C are normally open check valves and P41-F553 A & C are normally open manual butterfly valves. These Hatch Unit 1 valves are not required to close to meet a safety function.

3/26/84

C. VALVES - HA'ICH UNIT 2 1 Valves 2B21-F077 A & B - Note 13 of the Unit 2 Valve Testing Program states that closure of this (sic) Category AC valves will be verified quarterly by position indication lights. Please ,

describe how these valves will be leak tested.

Response

Note 13 states that valves 2B21-F077 A & B will be closure tested each cold shutdown, but not more frejuently than once per 3 months. A leak rate test is performed in which air is used to pressurize the water-filled test volme through 2B21-F082 A or B.

%e allowable leakage is limited by Appendix J requirments. %is penetration along with several others is limited to a total leakage of .009 La-

2. Valve 2 Ell-F046 A thru D - Should the Note for this valve, on Sheet 10 of the Unit 2 Valve Testing Progra, be Note 5 rather than Note 297

Response

Note 5 is the correct note.

3. Valves 2P41-F339 A & B and F340. What are the maximm stroke times assigned to these valves?

Response

Please refer to the response to Question B.4.

3/26/84

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