ML20237C019
| ML20237C019 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/16/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20237C022 | List: |
| References | |
| LIC-87-806, TAC-54804, NUDOCS 8712180049 | |
| Download: ML20237C019 (16) | |
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Omaha Public Power District 1623 Hametj Omaha. Nebraska 68102-2247 402/536-4000 December 16, 1987 LIC-87-806 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
References:
1)
NRC Letter " Request for Additional Information on the Inser-vice Test Program" (TAC No. 54804) dated June 24, 1987 (NRC-87-201) 2)
OPPD Letter " Draft Responses to NRC Questions on the Fort Calhoun Station IST Program dated October 30, 1987 (LIC-87-710) 3)
NRC Letter " Meeting Summary of Meetings Held on October 14 and 15. 1987 at Fort Calhoun Station" dated November 16, 1987 (NRC-87-346) 4)
NRC Letter "NRC Open Items As A Result Inservice Testing Program Meeting - Fort Calhoun Station, Unit 1," dated December 1, 1987 (NRC-87-357)
Gentlemen:
SUBJECT:
Review of Fort Calhoun's ISI Program The above references define the questions, responses and open items that de-veloped in the recent roview of Fort Calhoun Station's ISI Program Plan by the NRC.
In the meeting of October 14 and 15, OPPD agreed to submit a revised ISI Program Plan incorporating changes resulting from 1) commitments made by 0 PPD in the course of this meeting and 2) proposed resolution of open items. This letter fulfills that agreement.
This letter transmits two attachments. Attachment #1 is an " Explanation of OPPD Proposed Revisions to the ISI Program Resulting from Sources Other than Issues that were Closed During the October 14 and 15, 198/ Meeting." Attach-ment #2 is a proposed revision to the " Fort Calhoun ISI Program Plan." These documents are for the NRC's use in preparing an SER on the proposed ISI Pro-gram.
W 8712180049 871216 k
PDR ADOCK 05000285 I
G DCD e 5,ia r meinument tgta gopponunay
i Document Control Desk 1
December 16, 1987 i
Page 2 In addition.to changes discussed during the October meeting, OPPD's corrective j
action program following the intrusion of water into Fort Calhoun's instrument air system included additional revisions to the valve testing portion of the ISI Program. These are described in Attachment I and included in Attachment 2.
If you have any additional questions concerning this matter, please contact us.
Sincerely,
)
R. L. Andrews Division Manager I
Nuclear Production
]
s RLA/sa Attachments c:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, DC 20036 i
R. D. Martin, NRC Regional Administrator Anthony Bournia, NRC Project Manager P. H. Harrell, Senior Resident Inspector e
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Attachment #1 Explanation of OPPD Proposed Revisions to Fort Calhoun's ISI Program Resulting from Sources Other than Issues that were Closed During the October 14 and 15, l
1987 Meeting.
1.
Proposed closure of items identified in the referenced meeting as "Open Items for the Licensee":
To provide continuity with reference documents, open items will be iden-i tified by question number and the proposed resolution will be preceded by a statement of the question and OPPD's response to the question.
J Ouestion A-5 The NRC position is that the emergency diesel generator air start system and the fuel oil transfer system perform a safety-related function and that the appropriate pumps and valves should be included in the ISI program and tested in accordance with Section XI.
Oriainal Response 4
During meetings held with the NRC staff, the above position was clarified to specifically require the diesel air start solenoid valves and the compressor 1
discharge check valves to be included in the ISI program and tested to the requirements of Saction XI.
This position also applies to the diesel fuel oil transfer pumps and valves.
These valves and pumps are not presently in the ISI program. OPPD will evaluate this concern and provide a formal response by December 15, 1987.
Proposed OPPD Resolution of Onen Item OPPD agrees that the diesel air start solenoids valves (SA-147,148,197 and 198) and the starting air compressor discharge check valves (SA-137, 138, 187 and 188) could perform an active function in mitigating the consequences of an accident and should be included in the ISI Program.
The air start valves will be full flow stroke tested by ST-ESF-6 by alternately disabling one of the air start valves during the monthly diesel start test.
The valve operation will be considered acceptable if the diesel is ready to accept load in the time limit specified in ST-ESF-6. The air start valves are added to the ISI Program as Category B valves.
The compressor discharge check valves are verified to function in the open direction by the presence of satisfactory pressure in the air receiver, so no specific test to verify full flow is necessary. These check valves will be added to the ISI Program as Category C valves and tested in the closed position by monitoring the pressure on the compressor discharge upstream of the check valves when the receiver is pressurized and the compressor is off.
It is OP?D's position that the diesel fuel storage in the unit mounted day tank 3
is adequate to handle the safety needs. The 550 gallons per unit of diesel fuel in the base mounted day tank provides for about five hours of diesel run
Attachment #1 (cont.)
A-5 (cont.)
time without transferring fuel from the Fuel Oil Storage Tank F0-1.
In the un-likely event of a failure of both transfer pumps, a low level alarm on a separ-ate 300 gallon wall mounted fuel tank would notify the operator prior to the start of consumption of the 550 gallon tank. This would provide adequate time to restore the fuel transfer system.
The operation of the fuel oil transfer pumps is verified by ST-ESF-6. The Fuel Oil Transfer System need not be includ-I ed in the ISI Program.
Question A-6 1
Has a reactor vessel head vent system been installed at Fort Calhoun? If so, the appropriate valves should be included in the ISI program.
Oriainal Response Valves HCV-176,177 and 180 (1" solenoid valves in RV Head Vent System) will be included in the ISI program as Category B valves. These valves cannot be exer-cised quarterly during power operation since this would vent high temperature /
pressure reactor coolant to the quench tank. These valves will be exercised and stroke timed. The licensee will further evaluate the possibility of test-ing these valves during cold shutdowns.
These valves are not presently in the ISI program.
Proposed OPPD Resolution of Open Item These valves will be tested at cold shutdown when the RCS is depressurized.
They appear in the ISI Program as Category B valves tested at cold shutdown.
I Ouestion B-1 Do valves A/HCV-742, B/HCV-742, C/HCV-742, and D/HCV-742 (E-3) perform a con-tainment isolation function? Should they be included in the ISI program and categorized A?
Oriainal Responte These valves are 1" block valves to the containment pressure transducers. OPPD must further evaluate all safety functions of these valves. These valves do not receive any safety signal to close and remain open during all accident scen-l arios. However, the B, C, and D valves are closed during portions of the Appen-dix J 1eak rate testing. These valves are not presently in the ISI program.
OPPD's position related to these valves will be addressed in our revised ISI i
program plan.
Proposed OPPD Resolution of Open Item These are normally open, fail open valves. They receive no CIAS or other safe-l ty signal, so they are passive valves. They are tested both open and closed during the Type C, Appendix J test. The reason these valves are in the Appen-dix J test is to facilitate leak testing of other components.
Since these valves are passive and do not function as containment isolation valves, they need not be in the ISI Program as Category A or B valves.
]
Attachment #1 (cont.)
Question E-4 What are the consequences of a loss of cooling water to a containment air cool-ing unit? Refer to the Relief Request for HCV-400A-D, -401A-D, -402A-D, and
-403A-D.
Should these valves be categorized A?
l Oriainal Response These valves are 8" CCW block valves to the containment air cooling units.
OPPD will evaluate the exercising frequency for these valves (cold shutdown or quarterly) and provide our results in the revised ISI program plan. These valves are not currently leak rate tested per Appendix J since the system pres-sure is greater than peak accident pressure and the system is in operation post-accident. These are Category B valves tested during CS in the present ISI pro-gram.
Proposed OPPD R.esolution of Open Item These valves are on the outside of the containment. Technical Specification 2.4(1) indicates that if the rest of the containment cooling system components identified in this section are operable and one of these valves fails during an IST, seven days would be available to repair the valve before the plant would have to be shut down.
If a second component were inoperable, the plant would have to be shut down in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless both components were repaired.
If these valves were tested during plant operation, failure of one of the valves in a nonconservative position could result in entering an LCO.
This is con-trary to OPPD policy. The test frequency on these valves will remain CS.
Question F-1 Provide a more detailed technical justification stating why valve PCV-1849 cannot be exercised during power operation and cold shutdowns.
Oriainal Response PCV-1849 is a 2" gate valve that serves as containment isolation on the instru-ment air.
Failure of this valve in the closed position during testing would result in other valves supplied with air through this valve failing in their fail-safe position and could result in a plant shutdown.
OPPD will determine if this valve can be exercised during cold shutdown.
If so, the ISI program will be modified. This valve is presently tested at refuel-ing outage frequency.
Proposed OPPD Resolution of Open Item During cold shutdown when the RC pumps are running, the loss of instrument air caused by closing PCV-1849 would cause the loss of pressure control and level control functions inside the containment.
However, this valve could safely be stroke tested during the cold shutdown if the RC pumps were off and the RCS was i
depressurized.
The test frequency of this valve will be changed to include i
cold shutdown when RC pumps are off and the RCS depressurized.
I l
l Attachment #1 (cont.)
Question G-7 Review the safety functions of the following valves to determine if they should be included in the ISI program (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)
LCV-218-1 (I-1)
CH-188 (E-4)
LCV-101-1 (B-2)
FCV-269Y E-23866-210-121 (C-7)
CH-149 E-2386F ?10-121 (C-7)
Oriainal Response No credit is taken for the operability of the charging pumps in any accident scenario.
CH-187, 188 and 189 are 2" discharge check valves on the. charging pump dis-charge and, therefore, do not need to be included,in the ISI program. These valves are presently not included in the ISI program.
Valves LCV-101-1 & 2 perform no safety function and need )wt be rKclu d in the ISI program. These valves are presently not in theilSI program!/
OPPD will determine if credit is taken for emergency boration flowpath, g
IIk b
1
_P_rr_0 Dosed OPPD Resolution of Open Items d
Although credit is not taken for the CVCS in the accident analyses in Section j 14 of the USAR, its ftu.ction is listed as a condition for operation of the f/
plant in the Technical Specification. On this basis, OPPD plans to leave the *-
's CH-156isa3"checkvalveonthechakingpumpsuctionfromtheSIRWT.
This j
valve will be added to the ISI Program and tested to opan at refueling.
See l
the ISI Program for test fr?quency justification.
CH-187, 183 and 189 described above are added to the ISI Program and tested to.
open quarterly.
LCV-218-1 is a 3" three-way valve on the inlet to the Volume Control Tank.
j This valve fails in a position that permits flow to the volume-control tank.
4 *:
It performs no specific safety function and need not be included in ',he ISI ) A
- / l Program.,
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1 LCV-218-3 is a 3" gate valves on the charging pump suction.
Itisaddedtot!rQ
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ISI Program and stroke tested at cold shutdown. See the ISI Program for'fre-quency. justification.
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FCV-269Y and CH-149 are a 1" block valve and check valve respectively.: They y
are normally closed valves that reside in a line which is closed by oner valves (FCV-269 and CH-151) during an' accident condition. These' valves ~do not i
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have a safety function and need not be included in the ISI Program.
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i Attachment #1 (cont.)
l G-7 (cont.)
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j CH-166 is a 4 ches.N valve on the discharge from the volume control tant.
This
' valve is norma 1Yy open during operation whenever a charging pump is running.
Failure of this valve to open or close would rot prevent suction flow to J.he charging pumps. This valve is not required to perform er specific safety' func-tion and need not be included in the ISI Program.
It is OPPD's belief that these actions agree with the NRC position stated in' '
I NRC-87-357, dated December 1,1987, from Anthony Bournia to R. L. Andreves, t
Ouestion H-4 q
RevW the safety functica cf the following valves to determine if dioy shoald be categorized A/C.
How are these valves full-stroke exercised and what is the frequency of that exerciting?
SI-194 SI-200 SI-206 SI-195 SI-201 SI-212 SI-101 SI-203 SI 216 SI-198 SI-204
. SI-220 Orioinal Resconiq OPPD will fur?her evaluate the full stroke exercise test method and frequency for the follos ng valves:
SI-208 SI-207 SI-212 SI-211 Sl-216 SI-215 SI-220 SI-219 The foliewing valves will continue to be categorized A check valves:
SI-194 SI-200 SI-208 SI-195 SI-201 SI-212
]
SI-197 SI-203 SI-215 i
SI-198 SI-P.04 SI-220 The following valves' are full stroke exercise (cpen during refueling outages:
SI-195 S1-198 SI-201 SI-204 Exercising these valves during cold shutdowns could result in a low tercerature overpressurization of the RCS; thus we will not test these va7ves 6uNng cold i
shutdowns.
(
OPPD will determine if the following valves can be full stroke exercised during.
cold shutdowns utilizing residual heat removal capability:
i SI-194 SI-197 SI-200 SI-2G1 Proposed OPfD Resolution of Open Items SI-208, 212, 216, 220, 207, 211, 215 and 219 are 12" check valves on the SI
t 5,
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i Attachment #1 (cont.)
H-4 (cont.)
lines between the SI Tanks and the RCS.
They will be stroke tested during re-fueling by dumping the Safety Injection Tanks to the RCS while using ultrasonic techniques to monitor valve position. This is not a proven technique, but will be evaluated during the 1988 refueling outage.
SI-194,197, 200 and 203 are 6" check valves on the Safety Injection System.
0 OPPD determined that full stroke testing these valves during cold shutdown is
)
feasible.
These valves will be stroke tested at cold shutdown.
Question H-8
)
Provide a more detailed technical explanation why valves SI-121 and -129 cannot be full-stroke exercised during cooling operations.
Oriainal Response SI-121 and 129 (8" check valves on LPSI pump discharge) may be full stroke exer-cised during cold shutdowns. These valves are presently tested during refuel-ing outages.
OPPD will determine if full accident flow through these valves can be achieved during cold shutdown.
If appropriate, these valves will be stroke exercised l
during cold shutdown.
{
OPPD Resolution of Open Item There are certain accident conditions, when RCS pressures are low, that flow rates through these valves can be as high as 2300 gpm. This flow rate is not routinely achievable because of system configuration during cold shutdown and refueling. The valve manufacturer indicates that a flow of 10 ft/sec (roughly 1500 gpm) is adequate to fully open this valve if it is in good condition.
OPPD proposes to establish a reference pressure differential across the fully open valve at 1500 gpm during the 1988 refueling. This will be done in combin-
)
ation with a one time sample disassembly to verify the valve is in good condi-1 tion and to validate the correlation between the measured differential and oper-able valve condition.
In the future, the valve's condition will be tested at cold shutdown by measuring the differential pressure across the valve at a flow rate of 1500 gpm and comparing it with the reference value.
Question H-10 In reference to valves SI-159 and -160, the NRC staff position is that disas-sembly of check valves is an acceptable alternate method to utilize to full-stroke exercise check valves and that the disassembly be performed each re-fueling outage on a sampling basis instead of at the frequency proposed.
Oriainal Response SI-159 and 160 are 24" check valves on the SI suction lines from the contain-ment sump.
The NRC staff position on sample disassembly (i.e., one valve dis-assembled and inspected each refueling outage) was explained to the licensee.
The licensee has explained the problems with disassembly (i.e., rad waste, ALARA, etc.) for these valves.
Attachment #1 (cont.)
H-10 (cont.)
OPPD will further evaluate an increased test frequency for these valves. Pre-sent ISI program call for disassembly and inspection of alternate valves every five years.
Proposed OPPD Resolption of Open Item SI-159 was removed for inspection in 1980 and 1985.
SI-160 was removed for in-spection in 1981. After twelve years of service there is no sign of degrada-tion or any characteristic which would have a negative impact on valve operabil-ity. The removal and inspection of one of these valves requires 60 manhours and requires processing of 4100 gallons of radioactive waste water (at a cost of about $2,500) and results in 0.5 man-rem of radiation exposure.
It is OPPD's position that these valves have demonstrated their capability of with-standing their environment without deterioration for twelve years, so a once per five year inspection frequency is adequate to ensure valve operability.
The benefit derived from increasing the inspection frequency of this valve does not justify the cost or exposure. The valve inspection frequency of once per i
five years should remain as is.
Ouestion H-11 Review the safety function of valves SI-175 and SI-176 to determine if they should be categorized A/C. How are these valves full-stroke exercised during refueling outages?
Oriainal Response SI-175 and 176 are 12" check valves on the containment spray lines inside the containment. These valves are not required to be leak rate tested per Appendix J, and, therefore, do not need to be categorized A.
Proposed OPPD Resolution of Ooen Item The NRC's position, as stated in NRC-87-357, dated December 1, 1987, from Anthony Bournia to R. L. Andrews, is that these valves need to be included in the ISI Program and exercised.
It is impractical to full flow stroke test these valves because to do so would require actuation of containment spray.
OPPD takes the position that since these valves are not Appendix J tested, they are not containment isolation j
valves.
In view of the above, two actions could be taken to satisfy the NRC l
concerns about not exercising them:
1)
Include SI-175 and 176 in the ISI Program and perform a sample disassem-bly once per refueling outage to satisfy the test requirement, or 2)
Physically remove SI-175 and 176 from the containment spray lines.
The ISI Program has incorporated Option 1), but if evaluation demonstrates that i
these valves provide no required function, Option 2) will be adopted during the next refueling outage.
I
1 Attachment #1 (cont.)
Question H-12 How are valves SI-207, SI-211, SI-215, and SI-219 full-stroke exercised during j
refueling outages?
Oriainal Response i
Check valves SI-207, 211, 215 and 219 on the 12" safety injection tank drains 1
are partial-stroke tested during refueling outages. OPPD will evaluate a full-stroke exercise test.
Proposed OPPD Resolution of Open Items l
SI-208, 212, 216, 220, 207, 211, 215 and 219 are 12" check valves on the SI lines between the SI Tanks and the RCS.
They will be stroke tested during re-fueling by dumping the Safety Injection Tanks to the RCS while using ultrasonic techniques to monitor valve position. This is not a proven technique, but will be evaluated during the 1988 refueling outage.
Question H-13 Review the safety function of the following valves to determine if they perform i
a safety-related function.
If so, they should be included in the IST program.
(Sheet 1)
HCV-304 (E-7)
HCV-2937 (H-5)
FCV-326 (D-5)
HCV-305 (E-6)
HCV-2938 (F-5)
HCV-335 (E-4)
HCV-306 (D-7)
HCV-2947 (H-4)
HCV-344 (E-4)
HCV-307 (D-6)
HCV-2948 (F-4)
HCV-2987 (B-6)
HCV-2907 (G-7)
HCV-2957 (H-3)
.SI-323 (C-6)
HCV-2908 (F-7)
HCV-2958 (F-3)
HCV-308 (D-6)
HCV-2917 (G-7)
HCV-2967 (H-3)
HCV-2988 (D-6)
HCV-2918 (F-7)
HCV-2968 (F-3)
HCV-2927 (G-6)
HCV-2977 (H-2)
HCV-2928 (F-6)
HCV-2978 (F-2)
)
Oriainal Resoonse Valves HCV-308 and 2988 (2" parallel valves on lines that tie the charging pump discharge to the HPSI header) perform a long term core cooling function and will be included in the ISI program as Category B valves and tested during cold shutdowns. These valves are not presently included in the ISI program.
I HCV-335 (12" block valve between LPSI pump discharge and shutdown heat exchang-ers) performs no safety function in the open position. This valve is normally closed and considered passive, therefore, need not be included in the ISI pro-gram. This does not change the ISI program.
SI-323 (4" check valve in HPSI discharge) will be included in the ISI program as a Category C check valve.
This valve can only be verified to full stroke open during safeguards testing during each refueling outage since this is the only time a full flowpath is available for this system.
This valve is not pre-sently included in the ISI program.
Attachment #1 (cont.)
H-13 (cont.)
l 0 PPD will determine if SI-323 performs a safety function in the closed position and, if so, how closure capability is verified.
All other valves in this list are locked open in their fail-safe position and need not be included in the ISI program (i.e., IST program unchanged).
Proposed OPPD Resolution of Ooen Item l
SI-323 protects the class 1503R pipe from the discharge pressure of the charg-ing pumps, so it should be tested to verify closure.
The design pressure of-J the class 1503R pipe is 1600 psig. This valve can be tested in the closed pos-ition by opening HCV-308 or HCV-2988 to allow charging pump discharge pressure to the downstream side of the valve while monitoring pressure on the upstream side at PI-309. The closed test will have to be done at refueling when the charging pressure is below 1600 psi to avoid overpressurizing the upstream pipe if SI-323 should fail. The full flow stroke test may only be done during re-fueling outages when the HPSI pump can be started without danger of exceeding
)
low temperature overpressure protection limitations. This valve will be added i
to the ISI Program and tested open and closed at refueling outage.-
HCV-304, 305, 306, 307 and 2987 have been added due to instrument air considera-tions.
See Section 2.A of this Attachment.
Question H-15 How are valves SI-208, -212, -216, and -220 full stroke exercised?
Oriainal Resoor se i
Check valves SI-208, 212, 216 and 220 are on the 12" safety injection lines imrnediately upstream of the RCS injection point. These valves are partially l
stroke tested during refueling outages. OPPD will evaluate the practicality of full stroke testing.
Proposed OPPD Resolution of 09en Items I
SI-208, 212, 216, 220, 207, 211, 215 and 219 are 12" check valves on the SI lines between the SI Tanks and the RCS.
They will be stroke tested during refueling by dumping the Safety Injection Tanks to the RCS while using ultra-sonic techniques to monitor valve position.
This is not a proven technique, but will be evaluated during the 1988 refueling outage.
Attachment #1 (cont.)
Question I-1 Review the safety fuaction 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)
HCV-400F (G-1)
HCV-403F (G-2)
HCV-482B (G-3)
HCV-401E (F-1)
HCV-2898C (F-2)
HCV-483A (F-3)
HCV-401F (G-1)
HCV-2898D (G-2)
HCV-483B (G-4)
HCV-402E (F-1)
HCV-2899C (F-2)
HCV-2813C (D-5)
HCV-402F (G-1)
HCV-2899D (G-2)
HCV-28130 (E-5)
]
HCV-2808C (E-5)
HCV-2812C (E-5)
HCV-28090 (F-5) 1 HCV-2808D (E-5)
HCV-2812D (E-5)
HCV-2809D (F-5)
HCV-2810C (E-5)
HCV-2811C (F-5)
HCV-2815C (F-5).
HCV-2810D (E-5)
HCV-2811D (F-5)
HCV-2815D (F-5)
HCV-2814C (F-5)
HCV-281AD (G-5)
CW-188 (C-4)
CW-189 (C-4)
Oriainal Response OPPD will determine if the raw water to CCW interface valves perform an active safety function within the scope of our safety analyses.
Proposed OPPD Resolution of Open Items These valves, except for CW-188, switch to implement RW backup to CCW in the e' ent of a complete loss of the CCW system.
It is OPPD's position that com-plete loss of the CCW system is not a credible occurrence because of redundancy of active components and safety design of this system. Hence, no credit is taken for RW backup in the safety analysis and these valves are not required to be in the ISI Program.
CW-188 is a 20" check valve that is always open when the plant is in operation to permit Raw Water flow througn the Component Cooling Heat Exchanger.
It has no active safety function in the closed position. This valve is not required to be in the ISI Program.
Question J-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 exer-cise.
Oriainal Response There are no unidentified check valves on the current P&ID's.
This question refers to MS-351 and MS-352, 2" check valves on the steam line to the turbine driven auxiliary feedwater pump, FW-10. 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.
OPPD will determine a method and frequency of full stroke exercising these check valves and will determine if these check valves perform a safety function in the closed position. These valves are not presently in the ISI program.
Attachment #1 (cont.)
Proposed OPPD Resolution of Open Items It is OPPD's position that these valves do not perform a safety function in the closed position.
If a steam line broke and one of these check valves failed to close so that no drive steam got. to FW-10, an operator would recognize the pro-blem because of loss of steam generator level within 10 minutes which would leave ample time to close YCV-1045A or B to restore steam flow to FW-10 before the steam generator boiled dry. MS-351 and 352 will not be tested in the closed position.
It is OPPD's belief that these valves fully open during the routine flow test of the turbine driven AFW pump (FW-10) even though the steam flow is only one third of the design flow rate. There is no time when this pump is routinely operated at full flow conditions.
OPPD proposes to demonstrate operability of these valves by measuring pressure drop across the valve during the flow test of FW-10.
When the first differen-tial pressure is measured, a sample valve disassembly will be done to verify valve operability and to validate the " reference" pressure drop.
Future valve performance will be evaluated relative to this reference pressure drop.
The ISI Program has been revised to include the quarterly stroke test of these valves to the open position.
If the implementation of this test proves imprac-tical, an alternative would be to sample disassemble one of these valves each refueling outage.
Question L-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. Addi-tionally, normally open PORV block valves should be included in the IST program and exercised in accordance with Section XI to provide isolation protection in the event that the PORVs should fail open.
Oriainal Response HCV-150 and 151 (2)" block valves under the PORVs) will be_ included in the IST program as Category B valves and exercised on a cold shutdown frequency.
These valves are not presently in the IST Program.
PORVs are never exercised, however, the pilot valves may be exercised during surveillance test ST-PORV-1 prior to cooldown below 300*F.
The PORVs (PCV-102-1 and 2) perform no safety function at operating conditions.
During heatup and cooldown the PORVs provide the only source of low temperature overpressure protection. A surveillance test is in place that functionally tests the PORV low temperature ;etpoint function, but stops short of opening the PORVs. These valves are pilot operated valves that require pressure across the valve in order to open.
Experience indicates that stroke testing the PORV at temperature and pressure can be potentially damaging to the valve.
It is OPPD's position that it is nc,t practical to stroke test the PORVs.
4
Attachment #1 (cont.)
Further Clarification of NRC's Positign The following is from NRC-87-357, dated December 1, 1987, from Anthony Bournia to R. L. Andrews.
1 The NRC position is that the pr.essurizer power operated relief valves (PORVs) should be included in the IST program as Category B valves and tested to the j
requirements of Section XI. However, since the PORVs have shown a high probab-i ility of sticking open and are not needed for overpressure protection during power operation, the NRC has concluded that the IWV-3410 provisions for evercis-i ing quarterly during power operation is "not practical" and, therefcre, not re-l quired by 10 CFR 50.55a(g).
The PORVs' function during reactor startup and shutdown is to protect the reac-tor vessel and coolant system from low-temperature overpressurization condi-tions and should be exercised prior to initiation of system conditions for l
which vessel protection is needed.
Exercising of the PORVs should be performed 1
after the operability of the block valves is assured by exercising and stroke timing. The following test schedule is required:
a.
Full-stroke exercising should be performed at up.h cold shutdown or, as a minimum, once each refueling cycle, b.
Stroke timing should be performed at each cold shutdown, or as a minimum, once each refueling cycle, Fail-safe actuation testing should be performed at nch cold shut-c.
down.
d.
The PORV block valves should be included in the IST program and tested quarterly to provide protection against a small break LOCA should a PORV fail open.
In case of frequent cold shutdowns, testing of the PORVs is not e.
required more often than each three months.
)
Proposed OPPD Resolution of Open Items HCV-150 and 151 cannot be stroke tested during operation because failure of one of these valves would cause entry into an LC0 as defined in Technical Specifi-l cation 2.1.6(5)-
These valves will be tested at cold shutdown.
]
HCV-150 and 151 and PCV-102-1 and 2 will be included in the ISI Program and tested at cold shutdown frequency. Acceptance criteria for stroke times on PCV-101-1 and 2 are omitted from the ISI Program pending test definition.
1
_ - - - - - - - - - - ~ - - - - -
I Attachment #1 (cont.)
2.
Definition of valves added to Fort Calhoun's ISI Program because of the review of the instrument air system.
A.
HCV-304, 305, 306, 307, and 2987 are 4" gate valves in the HPSI pump dis-charge header.
(P&ID CE-E-23866-210-130-1 of 2) These valves were dis-cussed in question H-13 and were excluded from the ISI Program because j
they were Locked Open, Fail Open valves and were therefore considered passive.
Further investigation showed that one or more of these valves may be called on to close for long term core cooling.
These valves have been added to the ISI Program as Category B valves to be tested at cold shutdown. Justification for the test frequency may be found in the ISI Program.
B.
HCV-2808A&B, 2809A&B, 2810A&B, 2811A&B, 2812A&B, 2813A&B, 2814A&B, and 2815A&B are 11" globe valves on the CCW lines to the HPSI, LPSI, and CS pump bearing coolers and HCV-474 is a 2" globe valve on the CCW supply line to these coolers.
(P&lD GHDR-11405-M-10) These valves were dis-
)
cussed in question E-5 and were excluded from the ISI program as passive valves because administrative procedures were in place to insure they are open during operation. The more conservative view taken by the instrument air review did not take credit for the administrative procedure. These valves are added to the ISI Program as Category B l
valves and are stroke tested quarterly.
1 C.
HCV-489A&B, 490A&B, 491A&B and 492A&B are 10" butterfly valves on the i
CCW lines to the Raw Water / Component Cooling Water heat exchangers.
(P&ID GHDR-11405-M-10)
These valves were not included in the ISI Program because administrative procedures required that the number of valves required for emergency cooling loads were open at all times.
The more conservative view taken during the instrument air review included these values in the ISI Program.
These are now Category B valves and will be stroke tested quarterly.
D.
The small instrument air check valves installed on safety related air accumulators that have been identified as safety related by the instru-ment air review are added to the Category C valve list in the ISI Pro-gram. Most of these instrument air check valves are on accumulators for proce.ss valves that are already in the ISI Program.
These IA check valves will be tested on the same frequency as the process valve to which they are attached.
Seven of the IA check valves are attached to components that are outside the scope of the ISI Program such as dampers or bubblers on level controllers.
They are IV-712A-C, IV-871E-C, IV-871F-C, IV/383-A/FIC-C, IV/383-B/FIC-C, IV/383-C/FIC-C and IV/383-D/
FIC-C. These IA check valves will be tested quarterly.
E.
HCV-238, 239, 240, 344, 345, 864 and 865, LCV-383-1, LCV-383-2, YCV-1045A and YCV-1045B are valves that were categorized as B valves in the existing ISI Program.
The instrument air study identified these valves as having safety related air accumulators (i.e., the air accumulator drives the valve to a safety related position other than the valve's failure position). The tests of these valves have been expanded to in-clude stroke timing in both directions.
j l
l l
Attachment #1 (cont.)
3.
Miscellaneous explanations relating to the questions discussed in the refer-enced October Meeting.
To provide continuity with reference documents, the question and OPPD's response will precede the discussion as applicable.
Question A-1 Provide a list of all valves that are Appendix J, Type C, leak rate tested and at included in the ISI program and categorized A or A/C.
Response
The following valves will be included in the IST program as Category A or A/C as applicable and tested to the requirements of Section XI. None of these valves are presently in the IST Program.
j HCV-821A & B (see B-2)
A/HCV-742 (see B-1)
HCV-820A & B (see B-2)
B/HCV-742 (see B-1) l C/HCV-742 (see B-1) l D/HCV-742 (see B-1)
HCV-883A & B (see B-2) i HCV-884A & B (see B-2) i Valves HCV-344, HCV-345 and RC-147 are not reauired to be leak rate tested per Appendix J, therefore, need not be Category A in the ISI program.
Discussion Valve RC-147 was erroneously placed in the list of valves in the question response during the October meeting. RC-147 is not Appendix J. Type C, leak rate tested, so it was removed from consideration to be added to the ISI Program in the above response that was amended after the meeting. The disposition of the valves remain-ing on this list was handled in the response to the questions B-1 and B-2.
1 Ouestion K-1 Do valves FW-161 and FW-162 perform a safety function in the closed position? If so, they should be exercised to that position.
Response
FW-161 and 162 are 16" check valves in the main FW line insid9 coattinment.
It is OPPD's positica that these valves perform no safety function in the closed post-tion. The upstream motor operated valves perform the feedw.ter header isolation function.
It also appears that these valves perform no safety function in the for-i ward flow direction. The licensee is investigating removing these valves from the IST program.
I l
Discussio_q It was determined that FW-161 and 162 do not perform an active safety function in the open or closed position. These valves have been removed from the ISI Progrcm.
j