ML20236M955

Requests Response to Encl Nrc/Inel Review Comments & Questions Re Rev 6 to Pump & Valve Inservice Testing Program Submitted in Licensee .Meeting to Discuss Encl Issues Also Requested

ML20236M955
Person / Time
Site:	Limerick
Issue date:	11/06/1987
From:	Clark R Office of Nuclear Reactor Regulation
To:	Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
TAC-56245, NUDOCS 8711130347
Download: ML20236M955 (16)

Text

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November 6,'~1987 I g, m . , .,

2 p . Docket No. 50-352 Mr. Edward G. Bauer, Jr.

Vice President and General Counsel Philadelphia Electric Company- l 2301 Market Street Philadelphia, Pennsylvania 19101

Dear Mr. Bauer:

"]

SUBJECT:

INSERVICE TESTING PROGRAM (TAC N0. 56245) l RE: Limerick Generating Station, Unit 1

'Your letter of July 21,.1987 submitted Revisi~on'6 to the Limerick Unit 1 Pump and Valve Inservice. Testing (IST)'. Program. The NRC staff and its consultants at the Idaho National Engineering Laboratory haveicompleted a preliminary review of the revised program. The reviewers concluded that clarifications .are '

needed on a number of valves and on four aumps as identified in the enclosed

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set of questions and comments. .Some of t1e questions are the same as . .I identified in our letter to you.on 0ctober 22, 1987 regarding'the Peach Bottom.

IST- Prog ram.

1 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 ]

l us of the date by which your" staff will be prepared to support this meeting.

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Original signed by Richard J. Clark Richard J.-Clark, Project' Manager-Project Directorate I-2 Division of Reactor' Projects 1/II '

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Enclosure:

1 As stated cc: Service List -

DISTRIBUTION ,

(Docket file #' ACRS(10) I NRC PDR/LPDR .JTsao PDI-2' Reading JPartlow BBoger EJordan ,

WButler 0GC-Bethesda M0'Brien' RClark/RMartin-

.PDI-2/P PDI-2/D I '

RClarki WButler. l

///6fa/87 \\ / /87 8711130347 871106 PDR ADOCK 05000352 p PDR

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• 8 '%, UNITED STATES 8 n NUCLEAR REGULATORY COMMISSION  ;

, g~ o E WASHINGTON, D C,20555

%,, 4. * * + p November 6, 1987 1

.j-Pocket No. 50-352 I Mr. Edward G. Bauer, Jr.

Vice President and General Counsel I Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

Dear Mr. Rauer:

)  !

SUBJECT:

INSERVICE TESTING PROGRAM (TAC NO. 56245) l RE: Limerick Generating Station, Unit 1 l Your letter of July 21, 1987 submitted Revision 6 to the Limerick Unit 1 Pump i and Valve Inservice Testing (IST) Program.. The NRC staff and its consultants:

at the Idaho National Engineering LLboratory have completed a. preliminary review of the revised program. The reviewers concluded that clarifications are .j needed on a rumber of valves and on four pumps as identified in the enclosed- l set of questions and comments. Some of the questions are the'same as identified in our letter to you on October 22, 1987 regarding the Peach Bottom I IST Program.

l 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.  !

. Cl rk, Prnj )ect Manager roject Dire torate I-? 4 ivision of Reactor Projects I/II '

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Enclosure:

i As stated cc: Service List l

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- Mr. Edward G. Bauer, Jr Limerick Generating Station Philadelphia Electric Company Units 1.& 2 '

1 CC:

Troy B. Conner, Jr., Esquire Chairman Board of Supervisors of Conner and.Wetterhahn .. Limerick Township; '

1747 Pennsylvania Ave, N.W. 646 West Ridge Pike Washington, D. C. 20006 Limerick, Pennsylvania 19468 ,

Barrv M..Hartman

' Frank R. Romano, Chairman Office of General Counsel Air & Water Pollution Patrol j Post Office Box 11775 61 Forest Avenue 1 Harrisburg, Pennsylvania 17108 Ambler, Pennsylvania -19002 Federic M.=Wentz Dept. of Environmental Resources ..

County Solicitor ATTN: Director, Office Radiologic- q County of Montgon'ery l Health- l Courthouse .P..J. Box 2063 -

Norristown, Pennsylvania 19404 Harrisburg,' Pennsylvania 17105 l u

Mr. John Franz, Plant Manager Mr. David Stone  !

Limerick Generating Station . Limerick Ecology Action, Inc.

l Post Office Box A P. 0. Box 761 .  ;

Sanatoga, Pennsylvania 19464 Pottstowr., Pennsylvania 19464 '

Mr. Karl Abraham l

Thomas Gerusky, Director Public Affairs Officer Bureau of Radiation Protection Region I PA Dept. of Environmental. Resources U.S. Nuclear Regulatory Commission P. O. Box 2063-631 Park Avenue Harrisburg, Pennsylvania 17120 King of Prussia, PA 19406 Mr. Gene Kelly Governor's Office 'of. State Senior Resident Inspector . Planning and Development- . . l U.S. Nuclear Regulatory Commission ATTN: . Coordinator,- Pennsylvania P. O. Box 47 State Clearinghouse- l Sanatoga, Pennsylvania 19464 P. O. Box 1323 Harrisburg, Pennsylvania 17102-

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Philadelphia Electric Company Limerick Generating Station 1/2 cc:

Director, Pennsylvania Emeraency ,

Management Agency l Basement, Transportation & i Safety Building 1 Harrisburg, Pennsylvania 17120 H I

Robert L. Anthony Angus Love, Esq. l Friends of the Earth 107 East Main Street' of the Delaware Valley Norristown, Pennsylvania '19402.

103 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Helen F. Hoyt, Chairman Charles E. Rainey, Jr. , Esquire Administrative' Judge Chief Assistant City Solicitor Atomic Safety & Licensing Board Law Department, City of Philadelphia U.S. Nuclear Regulatory Comission One Reading Center Washington, D.:C. 20555' i 1101 Market Street, 5th Floor Philadelphia, PA 19107 David Wersan, Esq. Dr. Jerry Harbour Assistant Consumer Advocate Administrative Judge Office of Consumer Advocate Atomic Safety & Licensing Board 1425 Strawberry Square U.S. Nuclear Regulatory Commission l Harrisburg, Pennsylvania 17120 Washington, D. C. 20555-1 Dr. Richard F. Cole Mr. Spence W. Perry, Esq.

Administrative Judge Associate General Counsel Atomic Safety & Licensing Board Federtl Emergency Management Agency U.S. Nuclear Regulatory Commission Room 840 Washington, D. C. 20555 500 C St., S.W.

Mr. J. T. Robb, NS-1 l

Philadelphia Electric Company l l

2301 Market Street 1 Philadelphia, Pennylsvania 19101 Timothy R. S. Campbell, Director i Department of Emergency Services 14 East Biddle Street West Chester, Pennsylvania 19380 l

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• i LIMERICKGENERATINGSTATION,UN[

pVMP AND VALVE INSERVICE TESTING PROGRAM ,

REVIEW QUESTIONS AND COMMENTS

1. VALVE TESTING PROGRAM A. General Questions and Comments l

1. . Provide a listing of the limiting values of full-stroke time for all power operated valves'in the Limerick IST program for our review.

2. Provide a list of all valves that are' Appendix J, Type C, leak rate tested and that are not included in the Limerick IST. program '

and categorized "A" or "A/C".

3. The NRC has concluded that the applicable leak test procedures and requirements for containment isolation valves are determined by 10CFR50, Appendix J. Relief from Paragraphs IWV-3421 through

-3425 for containment isolation valves presents no safety problem since the intent of IWV-3421 through -3425 is met by Appendix'J

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requirements, however, the licensee shall comply with Paragraphs IWV-3426 and -3427. Does the current Limerick IST program meet this staff position?

4. Excess flow check valves'should be included in the IST program'as Category A/C' valves and tested in'accordance with Section XI to the extent practical.

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5. Those valves, if any, that perform both a containment isolation q function and a pressure boundary isolation function must be leak-te:ted to both Appendix J and Section XI requirements.

.6. The stroke time of rapid-acting valves must be measured and corrective action.taken if those stroke times exceed.the maximum 1 limiting value of full-stroke time. The NRC staff will grant relief from the trending requirements of Section XI (Paragraph 'I IWV-3417(a))'for these' rapid-acting valves;'however, in. order to obtain.this relief, the licensee must assign a maximum limiting stroke time.of two seconds to these valves.

7. Explain the statement: "In cases where the elapsed interval:has

. exceeded 100 percent of the specified interval, the next test interval shall~ commence at the end of'the originally specified interval." See Section 7, Paragraph-7.2, p'.7-2.

8. Relief requests and-Remarks that reference the-FSAR, Technical -1 Specifications, and other documents should be expanded to provide -

a brief discussion of the applicable technical information j contained in the referenced document.

9. Cate0ery C relief valves included in the IST program _are defined as active valves, therefore, relief valves should be tested in-accordance with Section XI, Paragraph IWV-3500.

10. Flow control valves that have a required fail safe position should be included in the IST program and fail safe tested to the extent practir.al.

11. The Code permits valves to be exercised during col'd shu'tdowns-where it is not practical to exercise.them during plant operationL and these valves are specifically identified by.the l'icenseeLand' are full-stroke exercised during cold shutdowns. The.NRC. staff.-

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requires that the licensee provide a technical justification for each valve that cannot be exercised quarterly during power operation that clearly explains the difficulties or hazards that would be encountered during that testing. The staff will then verify that it is not practical to exerciso those valves and that the testing should be performed during cold shutdowns.

12. Relief request and cold shutdown justification bases should-indicate the negative consequences that make te' sting at the Code required frequency impractical such as endangering personnel, equipment damage, or resulting in a plant shutdown.

B. Main Steam System

1. What is the safety-related function of valves HV-01-108, -109,.

-111, and -150?

i C. Emergency Service Water System i 1. What is the correct identification of the valves located on P&ID 1 1

! M-11, Sh. 1, 0-17 One of the valves is identified HV-051A and 1

the other is identified HV-0158.

2. How are valves 11-0064A, .00648, -0065A, and -0065B full-stroke exercised quarterly?

3. Review the safety-related function of valve 11-1044 to determine if it should be exercised to both the open and closed positions.

Why are Category C valves 11-0062, -1011, and -1012 leak rate

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l. tested? Are these valves full-stroke exercised to the open position?

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5. Review the safety-related function of va@ns 11-0029i -0033A,

-0033B,-0035{and-0043todeter.5tneif{Nheyshouldbeincluded , , < ~

in the IST progrka and exercisedL in aceordance with the q ..

requirements of SectioncXI. l

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6. Describe the adrnini$krative, contrMs utilized'to ensbre that the valves . listed iS the. emergency service water syste'mf bp. 2 and 3

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3 of 3, do not inadvertently chang'e pNsitjon. .

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C. RHR Service Water System /

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1. Havesystemmodificationsbeencompletedtoa'llowexercYsing valves 12-0030 and -0031 in eccordance with Section XI? Do'these- L

, valves perform any safety fuhetion in the open position?

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2. Review the saf ty-related function of val e 1 -LV- 06'to determine if it should be included in the IST program and . tested 1 in accorda.nce with Section XI.' pfli>r/. j p, ,

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l D. Reactor Enclosure Cooling Water System \

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Provideadetailedtechnicaljustifjcationfornobfu}i-stgoke exercisingvalvesHV-13-106,-107,b108,abdN.11'dkYhdo): ,.

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shutdowns. , }3 y ..

E. Diesel Fuel Oil Transfer and Ai Sta I Syst .htg U '

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1. The diesel generator air' star't solenoid valves'should be included i ,

in'the IST proyam and test W in accordance with the requirements: 6a .. _

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y. f^ i't, f- x l 2. Review the safety-related function.of valves 20-PSV421A, -121B,

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-121C,and-121DtodetermineifIheyshouldb1inclhded%nthe- +

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1 IST program. 1liht',;b[F f

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F. MSIV Leakage Control System

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'1.};,Howarevalves40-1F-010and-011 full-strokeexercised

') quarterly? /

b q G. Nuclear Boiler $y.itemk r 6 } ,

'V l Provide a more detailed technical justification for Act'

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s fnil-strokeexercisingvalves41-1F010Aand-1F010Bquarter)y. i' 7 <'

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2. Provide a more detailed technical justification for not g nsuring the stroke time of valves PSV-41-1F013E, H, K, M, and 5 when they 1 are full-stroke exercised. '

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L 3. Review the categorization of valves PSV-41-1F013A, B, C, D, F, G, '

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'  ?> r> J, L, and N to determine if they should be categorized B/C. ,

4. Provide a more detailec' technical justification for not g full-stroke e,x'ereising g

valves PSV-41-1F037A through S and -1F097A e . ,

,Pi through 51 durM0,(.oid shutdowns.

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'$j/, Provide a mciro ' detailed technical justification for not s

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,( full-stroke exercising valves 1F036E, H, K, M, and S during cold shutdowns. t 1

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6. Provide a detailed technical justification for not full-stroke g 7 exercising valves 41-1036A and -1036B during cold 5,hutdowns. i r.

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7. Provide the P&ID that shows the location of valves HV-41-140,-

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-141, -142, and -143. I 1

8. Ar'Kthe Ms1Vs stroke timed in accordance with Section XI or in atcoydance with station Technical Specifications? Should relief be b grested,from the trending requirements of Section XI? ,

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H. Nuclear Boiler Instrumentation System' -

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

exercising valves hV-42-147A,. -147B, -147C, and' -147D quarterly.

I. Reactor Recirculation System

1. Provide a detailed technical justification for not full-strok'e exercising valves HV-43-1F031A and'-1F031B during;each cold .

shutdown.

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2. What is the safety-related function of valves'HV-43-1F023A and '

-1F0238?

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3. Provide a more detailed tec.hnical justification for not l;

full-stroke exercising-valves 43-1F004A'and -1F004B during cold shutdowns.

l l 1 J._ Reactor Water Cleanup System

1. Provide a deta.iled. technical justification for, not full-strokel l- exercising valves 44-HV-1F001, -1F004, and.-HV-1F029 quarterly.

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K. Control Rod Drive Hydraidic System ' '

l 1. Provide the P&ID that shows the' location of' valves .'iV-46-125,- '

1 l -126,.-127, and -128. Provido a more. detailed'. technical justification for not full-stroke exercising these' valves during_

cold shutdewns. .,

2. How is check . valve 47-1-15 verified- to close' during control' rod scram' testing?

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3. Provide a detailed technical justification for not measuring the j stroke time of valves XV-47-1-26 and -27 quarterly. LAre these-l

valves fail safe tested?

4. How is check valve 47-1-38 verified to close duringLeontrol rod scram' testing?'

L. Standby Liquid Control System 'l

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1. Provide.a more detailed' technical justification for not.

full-stroke exercising ~ valves HV-48-1F006A, -1F006B, 48-1027, and- 'j

-1F007 quarterly. Why can injection to the vessel be performed 4 only during refueling outages?

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2. How is full-stroke exercising of valves 48-1F033A,-1F033B, j

-1F033C verified during pump tests?- 'l 1

M. Reactor Core Isolation Cooling System l

1. Provide a more detailed technical justification for not )

full-stroke exercising valves 49-HV-1F008, -1F012, -1F013, and

-1F060 ouarterly,

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2. How are valves 49-1032, -1033, -1F064, and -1F065 individually.

verified to close?

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3. Does valve 49-1F011 perform a safety-related function in the closed position?

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How is valve 49-1F030 full-stroke exercised quarterly?

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5. How are valves 49-1017, -1018, -1F068, and -1F081 individually verified to full-stroke exercise?

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6. Why.isCategoryCvalve4'9-1F028lehkratetested?

i N. RCIC Pump Turbine System q

1. -Review the safety-related function of valve 50-1006 (B-3) to.

determine if it should be included in the IST program and' tested-in accordance with Section XI. )

O. Residual Heat Removal System

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1. Provide a more detailed technical justification for not full-stroke exercising the following valves during cold shutdowns:

51-HV-1F009 51-HV-1F015A 51-HV-1F0153 .

51-HV-1F017B 51-HV-1F017D 51-HV-1F041A 51-HV-1F041B 51-HV-1F041C '51-HV-1F041D.

51-HV-1F050A 51-HV-1F050B- 51-HV-1F008: ,

51-HV-1F022 51-HV-1F023

-2. What are the' consequences of valves 51-1F031A, -1F031B, -1F031C, and -1F031D~failing open following an exercise. test? How'would- 1 that failure be. detected?  !

3. How are valves 51-1F046A,'-1F046B, -1F046C, and.-1F0460 verified to full-stroke exercise quarterly?.

4. What is the safety-related function of valves PVC-51-1F051A,

-1F051B, HV-1F052A, and -1F052B7 Is credit taken for operation of the steam condensing mode at Limerick Station?

5. Can check valve 51-1F078 be full-stroke exercised utilizing;the-manual actuator?

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6. How are the following valves individually verified to shut?'

51-1F1115A 51-1F1115B 51-1F1115C, I 51-1F11150 51-1F1116A 51-1F1116B 51-1F1116C 51-1F1116D 51-1F090A 1 51-1F090B 51-1F090C 51-1F090D I 51-1F032A 51-1F032B 51-1F033A' j 51-1F033B 51-1F089A 51-1F089B 51-1F089C 51-1F0890

7. Provide the P&ID that shows the location of valves HV-51-142C and < j

-142D.

8. . Appendix B identifies valve PSV-51-101B as a Category C. check valve while P&ID ISI-M-51, Sh.1 of 2, identifies.it' as a relief - )

' valve. Which identification is correct? Does this valve have to-l change position to' perform its safety function?

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9. Why are valves 51-HV-1F047A and -1F047B full-stroke' exercised quarterly and parallel valves 51-HV-182A and -1828 are not? I i 10. Provide the P&ID that shows'the location of valve 51-1F.077.

11. Why is valve PSV51-1F055A categorized A/C, passive, while PSV51-1F055B is categorized A/C, active?

P. Core Spray System l .

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1. Provide a more detailed technical. justification for not  !

full-stroke exercising valves HV-52-1F005, -108, -1F006A,

-1F0068, and -1F037 during cold shutdowns.

2. How are valves 52-1F029A, -1F029B, -1F030A, -1F030B, -1045A 3

-1045B, -1046A, -1046B, -1048A, and -1048B individually verified f to shut?

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3. How are valves 52-1F036A, -1F0368,'-1F036C,.and.-1F0360 verified ~

to full-stroke exercise quarterly? I

4. Provide a detailed technical justification for not' full-stroke j exercising valves 52-1051A and -1051B quarterly.. ]

Q. High' Pressure Coolant Injection System 1

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1. Provide a more detailed technical justification for not full-stroke exercising valves HV-55-1F003 and -1F072 quarterly. .l l

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2. Provide a more detailed technical justification for not: l full-stroke' exercising. valve HV-55-1F007 quarterly.

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3. Does valve 55-1F019 perform a safety function in'.the-closed-- ,

position?

4. How is valve 55-1F045 full-stroke exercised quarterly?:

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5. How.is valve 55-1F046 verified to full-stroke. exercise. quarterly?:

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6. How are valves 55-1F077, -1F078, -1048, and -1049 individually- ~

verified to shut? .

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7. How are valves 55-1F080, -1F094, -1025, and -1026 individually.

verified to full-stroke exercise quarterly? O

8. Provide a more detailed technical' justification for' not i l full-stroke exercising' valve 55-HV-1F105. quarterly. )

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How is valve 55-1058 full-stroke exercised'during co1d shutdowns?l

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10. Provide a more detailed technical: justification-for.not' full-stroke exercisingLvalve 55-1059'duringl cold. shutdowns.

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11. Review the safety-related function of valves 56-1F052, -1F057, )

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-1065, -1F081, and PSV-125 to determine if they should be included in the IST program and tested in accordance with Section XI.

1 R. Containment. Atmospheric Control System

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1. Provide the P&ID that shows the location of valves HV-57-103,

-125, -113, and -122. )

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2. How many valves are installed in the primary containment vacuum. )

relief valve assemblies? If there are more than the four listed in the program, then the other valves in the assemblies'should

.also be included in the IST program. ,

S. Primary Containment Instrument Gas System l 1. Identify the equipment affected and the consequences of its l failure if valve 59-HV-101 or -102 were to fail closed while being exercised quarterly.

I j 2. What is the safety-related function of valves 59-HV-140,- -141, l l

-142, and -143?

l T. Liquid Radwaste Collection System '

1. Provide the P&ID that shows the continuation of 4" lines HBB-164' and -165.

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2. PUMP TESTING' PROGRAM 1

1. Is differential pressure measured or calculated during tests of.

the standby liquid control pumps?  :

- 2. How is flow' measured during tests of the standby liquid. control .'l i

pumps?

l 3. How is flow measured during tests of.the'RHR' service water pumps?

4. Has the installation of the instrumentation been completed to-allow measuring inlet and differential pressure on the safeguard piping fill pumps? i 1

. 5. How is flow measured during tests'of the diesel fuel oil trans'fer ]

pumps?

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