Text

SER Re Inservice Testing Program (IST) & Requests for Relief for Second 10-yr Interval.Ist Program Acceptable for Implementation
	ML13331B190
Person / Time
Site:	San Onofre
Issue date:	06/09/1989
From:	; Office of Nuclear Reactor Regulation
To:	;
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ML13331B189	List: ML13331B188; ML13331B190;
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	NUDOCS 8906210173
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ENCLOSURE 1 SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM AND REQUESTS FOR RELIEF SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 DOCKET NO.:

50-206 INTRODUCTION The Code of Federal Regulations, 10 CFR 50.55 a (g), requires that inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing (IST) of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel.Code and applicable addenda, except where specific written relief has been requested by the licensee and granted by the Commission pursuant to 10 CFR 50.55 a (g)

(6)(i). In requesting relief, the licensee must demonstrate that conformance with certain requirements of the applicable Code edition and addenda is imprac tical for its facility.

Regulation 10 CFR 50.55 a (g)(6)(i) authorizes the Commission to grant relief from these requirements upon making the necessary findings. This Safety Evaluation Report (SER) contains the NRC staff findings with respect to granting or not granting the relief requested as part of the licensee's IST program.

The IST program addressed in this report covers the second ten-year inspection interval from January 1, 1978 to January 1, 1988. The licensee's program is described in letters dated January 24, 1984; June 15, 1984; September 11, 1984; and April 10, 1985. Supplemental information was provided in letters dated March 3, 1986; July 3, 1986; August 18, 1986, and March 17, 1987.

8906210173 890609 PDR ADOCK 05000206 P

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-2 The program is based on the requirements of Section XI of the ASME Code, 1977 Edition through the Winter of 1979 Addenda and remains in effect until January 1, 1988, unless the program is modified or changed prior to the ten year interval end date.

EVALUATION The IST program and the requests for relief from the requirements of Section XI have been reviewed by the staff and their contractor, EG&G Idaho, Inc. (EG&G).

In addition, EG&G and staff members met with licensee representatives on February 2, 3, and 4, 1983 in a working session to discuss questions resulting from the review. The Technical Evaluation Report (TER) provided as Attachment 1 is EG&G's evaluation of the licensee's inservice testing program and relief requests. The staff has reviewed the TER and concurs with the evaluations and conclusions contained in the TER. A summary of the relief request determinations is presented in Table 1. The granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternate proposed testing.

As detailed in TER Section 3.1.1, Southern California Edison Co. has requested relief from the Code flow measurement requirements in Section XI, paragraph IWP-3100, for the motor driven and steam driven auxiliary feedwater pumps, G-10 and G-10S. The licensee has proposed a monthly test by running these pumps using the miniflow lines and by measuring pump differential pressure. Full flow testing during cold shutdown will measure all Code required parameters.

-3 The licensee has not provided sufficient information to demonstrate that instal lation of the flow measurement devices for quarterly testing is impractical. In order for the licensee to assemble the information necessary to support their request for relief, interim relief is granted until July 1, 1988. Granting this interim relief is justified based upon the testing of these pumps which, except for quarterly flow measurement, is in accordance with the Code, the fact that the flow devices are not presently installed, and a reasonable length of time to assemble the necessary data. The licensee should justify the present or proposed alternative testing in terms of all the potential pump failure mechanisms for these pumps and the means by which the IST program will detect degradation. The licensee should include in their discussion, as necessary, the 'pump vibration monitoring techniques to be used, failure rates for similar pumps in use at nuclear power plants, and scheduled maintenance performed on these pumps.

CONCLUSION Based on the review of the licensee's IST program and relief requests, the staff concludes that the IST program will provide reasonable assurance of the operational readiness of the pumps and valves covered by the IST program to perform their safety related functions. The staff has determined that, pursuant to 10 CFR 50.55 a(g)(6)(i), granting relief where the Code requirements are impractical is authorized by law and will not endanger life or property, or the common defense and security.

The staff has also concluded that granting relief is otherwise in the public interest considering the burden that could result if the requirements were

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-4 imposed on the facility. During the review of the licensee's inservice testing program, the staff has not identified any significant misinterpretation or omis sions of Code requirements. Thus the IST program submitted for SONGS-1 as defined above, i3 acceptable for implementation.

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TABLE 1. SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 Summary of Relief RequestsSection XI TER Requirement/Subject/Pump Alternate Relief Action Section or Valve number Method of Testing by USNRC 3.1.1 IWP 3100-1 Monthly differential Interim granted Flow rate measurement pressure mini-flow until July 1, G-10 and G-10S path; cold shutdown 1988 flow rate full flow path 3.2.1 IWP 3100-1 Measure and trend Granted Bearing temperature and pump motor thrust vibration measurement bearing vibration G-47A, G-47B, G-75A and quarterly G-758 3.3.1 IWP 3100-1 None Interim granted Flow rate measurement through next 8-50A and G-50B refueling outage 3.4.1 IWP 3100-1 Monthly dry pump Granted Inlet pressure, dif-testing measur4ng ferential pressure, flow current; refueling rate, vibration, bearing outage shutoff head" temperature measurements test G-45A and G-458 3.5.1 IWP 3100-1 None Interim granted Flow rate measurement through next G-27N and G-27S refueling outage 3.6.1 IWP 3100-1 Monthly thrust Granted Bearing temperature and bearing vibration vibration measurements and temperature G-13A and G-13B measurements and thrust bearing service water lubricating flow observation 3.7.1 IWP 3400 Test within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months Granted Quarterly testing of placing RHR in G-14A and G-148 service if last test was more than three months and quarterly during cold shutdown

TABLE 1. (continued)

Summary of Relief RequestsSection XI TER Requirement/Subject/Pump Alternate Relief Action Section or Valve number Method of Testing by USNRC 3.8.1 IWP 3100-1 Measure total flow Granted Flow rate measurement (both pumps) and G-3A and G-3B ratio with motor current for each pump 3.9.1 IWP 3100-1 Measure vibration Granted Vibration displacement velocity measurement G-200A and G-200B 4.1.1 IWV 3417(a)

Declare inoperable Granted Rapid acting valve if stroke time str'oke time all rapid exceeds maximum dcting power operated value valves 4.2.1.1 IWV 3522 Sample disassefbly/

Granted Full-stroke exercise inspection/manual SIS-003, SIS-004 and full-stroke SIS-010 exercising during refueling outages 4.2.2.1 IWV 3522 Disassembly/

Granted Full-stroke exercise inspection/manual CRS-008 and CRS-009 full-stroke exercising during refueling outages 4.2.2.2 IWV 3522 Sample disassembly/

Granted Full-stroke exercise inspection/manual SIS-303 and SIS-304 full-stroke exercising during refueling outages 4.3.1.1 IWV 3522 Disassembly/

Granted Full-stroke exercise inspection/manual FWS-438 and FWS-439 full-stroke exercising during refueling outages

TABLE 1. (continued)

Summary of Relief RequestsSection XI TER Requirement/Subject/Pump Alternate Relief Action Section or Valve number Method of Testing by USNRC 4.4.1.1 IWV 3522 Disassembly/

Granted Verify valve closure inspection and OWN-306, OWN-309, verification of DWS-306, and DWS-309 valve closure during refueling outages 4.5.1.1 IWV 3412 Full-stroke exercise Granted Full-stroke exercise during refueling out CV-92 ages

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EGG-NTA-7389 Revision 1 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 Docket No. 50-206 H. C. Rockhold R. Bonney Published August 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-ACO7-76ID01570 FIN No. A6812

ABSTRACT This EG&G Idaho, Inc., report presents the results of our evaluation of the San Onofre Nuclear Generating Station, Unit 1, Inservice Testing Program for safety-related pumps and valves.

FOREWORD This report is supplied as part of the "Review of Pump and.Valve Inservice Testing Programs for Operating Reactors" Program being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor

-Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc., NRR and I&E Support.

The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20-19-40-41-2, FIN No. A6812.

Docket No. 50-206 ii

CONTENTS ABSTRACT...........................................

FOREWORD

1.

INTRODUCTION................................................

1...

2.

SCOPE.........................................................

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3.

PUMP TESTING PROGRAM............................................ 9 3.1 Auxiliary Feedwater System.................................

9 3.2 Diesel Fuel Transfer System................................ 10 3.3 Safety Injection System...

.................................11 3.4, Safety Injection Recirculation System....................... 12 3.5 Refueling Water System.................................... 13 3.6 'Saltwater Cooling System................................... 14 3.7 Residual Heat Removal System............................

15 3.8 Feedwater System.......................................... 17 3.9 Containment Spray System................................... 18

4.

VALVE TESTING PROGRAM.......................................... 21 4.1 All Systems.............................................. 21 4.1.1 Rapid Acting Valves................................ 21 4.2 Safety Injection System................................... 22 4.2.1 Category A/C Valves................................

22 4.2.2 Category C Valves..................................

24 4.3 Feedwater System.......................................... 26 4.3.1 Category C Valves.................................. 26 4.4 Diesel Generator Cooling Water System...................... 27 4.4.1 Category C Valves.................................. 27 iii

4.5 Miscellaneous Water Systems................................

28 4.5.1 Category B Valves.................................. 28 APPENDIX A--VALVES TESTED DURING COLD SHUTDOWNS....................... A-1 APPENDIX B--P&ID LIST.............................................. B-1 APPENDIX C--IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW........

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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1

1. INTRODUCTION Contained herein is a technical evaluation of the pump and valve Inservice Testing (IST) program submitted by the Southern California Edison Company (SCE) for its San Onofre Nuclear Generating Station, Unit 1.

The working session with Southern California Edison Company and San Onofre, Unit 1, representatives was conducted on February 2, 3, and 4, 1983. The licensee's resubmittal dated March 3, 1986, was supplemented by letters dated July 3, 1986; August 18, 1986; and March 17, 1987 and constitutes the IST Program for Pumps and Valves. This program was

.reviewed to verify compliance of proposed tests of Class 1, 2, and 3 pumps and valves, whose function is safety-related, with the requirements of the ASME Boiler and Pressure Vessel Code (the Code),Section XI,,1977 Edition, through the Winter of 1979 Addenda. Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER).

Required program changes, such as revised or additional relief requests or the deletion of any components from the IST program, should be submitted to the NRC under separate cover in order to receive prompt attention, but should not be implemented prior to review and approval by the NRC.

In their 1ST program Southern California Edison Company has requested relief from the ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine whether they are indeed impractical.

This review was performed utilizing the acceptance criteria of the Standard Review Plan, NUREG-0800, Section 3.9.6. and the Draft Regulatory Guide and Value/Impact Statement titled "Identification of Valves for Inclusion in Inservice Testing Programs".

These IST Program testing requirements apply only to component testing 1*

(i.e., pumps and valves), and are not intended to provide the basis to change the licensee's current Technical Specifications for system test requi rements.

Section 2 of this report presents the scope of this review.

Section 3 of this report presents the Southern California Edison Company bases for requesting relief from the Section XI requirements for the San Onofre Nuclear Generating Station, Unit 1 pump testing program and EG&G's evaluations and conclusions regarding these requests. Similar information is presented in Section 4 for the valve testing program.

Category A, B, and C valves which are exercised during cold shutdowns and refueling outages and meet the requirements of the ASME Code,Section XI are discussed in Appendix A.

A listing of P&IDs used for this review is contained in Appendix B.

Inconsistencies and omissions in the licensee's program noted in the course of this review are listed in Appendix C. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

2.

SCOPE The EG&G Idaho review of the San Onofre Nuclear Generating Station, Unit 1, inservice testing (IST) program for pumps and valves was begun in January of 1982. The program identified the licensee's proposed testing of safety related pumps and valves in the plant systems listed in Appendix B.

To review the licensee's proposed testing of certain pumps and valves in these systems, they were first located and highlighted on the appropriate system P&IDs. After identifying the components and determining their function in the system, the proposed testing was evaluated to determine if it was in compliance with the ASME Code requirements, based on the component type and function.

For pumps, it was verified that each of the seven-inservice test quantities of Table IWP-3100-1 is measured or observed as appropriate.

For those test quantities that are not being measured or observed quarterly in accordance with the Code, it was verified that a request.for relief from the Code requirements had been submitted.

If the testing is not being performed in accordance with the Code and a relief request had not been submitted, additional information was requested from the licensee to explain the inconsistancy. The Request for Additional Information (RAI) document served as the agenda for the working meeting between the licensee, the NRC, and the EG&G reviewers. The relief requests were individually evaluated to determine if the licensee clearly demonstrated that compliance with the Code required testing is impractical for the identified system components, and to determine if their proposed alternate testing provides a reasonable indication of component condition and degradation. Where the licensee's technical basis or alternate testing was insufficient or unclear, the licensee was requested to supplement or clarify the relief request. The system P&ID was also examined to determine whether the Instrumentation necessary to make the identified measurements is available. If, based on the unavailability of adequate instrumentation or the reviewers experience and system knowledge, it was determined that it may not be possible or practical to make the measurements as described by the licensee in his IST program, a question or comment was generated requesting the licensee to clarify his position.

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The review of the proposed testing of valves verified that all appropriate ASME Code testing for each individual valve is performed as required. The proposed testing was evaluated to determine if all valves that were judged to be active category A, B, and/or C, (other than safety and relief valves) are exercised quarterly in accordance with IWV-3410 or 3520, as appropriate. If any active safety related valve is not full-stroke exercised quarterly as required, then the licensee's justification for the deviation, either in the form of a cold shutdown justification or a relief request, was examined to determine its accuracy and adequacy. The proposed alternate testing was also evaluated to determine if all testing is being performed that can reasonably be performed on each particular valve to bring its testing as close to compliance with the Code requirement as practical.

For valves having remote position indication, the reviewer confirmed that the v-alve remote position indication is verified in accordance with IWV-3300. The reviewer verified that the licensee had assigned limiting values of full-stroke times for all power operated-valves in the IST program as required by IWV-3413. The assigned limits were examined to determine if they are reasonable for the size and type of valve and the type of valve operator. It was also verified that the valve full-stroke times are being measured every time that the valves are full-stroke exercised for the IST program. For valves having a fail-safe actuator, the reviewer confirmed that the valve's fail-safe actuator is tested in accordance with IWV-3415.

It was confirmed that all category A and A/C valves are leak rate tested to either the 10CFR50, Appendix J, and Section XI, IWV-3426 and 3427 requirements, for those valves that perform a containment isolation function, or to the Section XI, IWV-3421 through 3427 requirements for those valves that perform a pressure boundary isolation function. It was also verified that valves that perform both a containment isolation and a pressure isolation function are leak rate tested to both the Appendix J and the Section XI requirements. Furthermore, if any valve appeared to perform a containment isolation and/or a pressure isolation function but was not 4

categorized A or A/C and being leak rate tested, the licensee was asked to verify that those valves had not been categorized improperly in the IST program.

Each check valve was evaluated to determine if the licensee's proposed testing does verify the valve's ability to perform its safety related function(s). Extensive system knowledge and experience with other similar facilities were used to determine whether the proposed tests will full-stroke the check valve disks open or verify their reverse flow closure capability. If there was any doubt about the adequacy of the identified testing, questions were included in the RAI which required the licensee to address these concerns.

A further evaluation was performed on all valves in the program to determine that the identified testing could practically and safely be conducted as described. If the ability to perform the testing was in doubt, a question was formulated to alert the licensee to the suspected problem.

Safety related safety valves and relief valves, excluding those that petform only a thermal relief function, were confirmed to be included in the IST program and are tested in accordance with IWV-3510. Safety related explosively actuated valves were verified to be included in the IST program and tested in accordance with IWV-3610.

After all of the valves in the licensee's IST program had been identified on the P&IDs and evaluated as described above, the P&IDs were examined closely by at least two trained and experienced reviewers to determine if any pumps or valves that may perform a safety related function were not included in the licensee's program. The licensee was asked to reconcile any valves that were identified by this process and had been omitted from the IST program. Also, the list of systems included in the licensee's program was compared to a system list in the Draft Regulatory Guide and Value/Impact Statement titled, "Identification of Valves for Inclusion in Inservice Testing Programs". Systems that appear in the Draft 5

Regulatory Guide list but not in the licensee's program were evaluated and, if appropriate, questions were added to the RAI concerning safety related pumps and valves in those systems.

Additionally, if the reviewers suspected a specific or a general aspect of the licensee's IST program based on their past experiences, questions were written for inclusion in the RAI to clarify those areas of doubt. Some questions were included for the purpose of allowing the reviewers to make conclusive statements in this report.

At the ccmpletion of the review, the questions and comments generated during the review were transmitted to the licensee. These questions were later used as the agenda for the working meeting with the licensee on February 2, 3, and 4, 1983.

At the meeting each question and comment was discussed in detail and resolved as follows:

a. The licensee agreed to make the necessary IST program corrections or changes that satisfied the concerns of-the NRC and their reviewers.

b. The licensee provided additional information or clarification about their IST program that satisfied the concerns of the NRC and their reviewers, and no program change was required.

c. The item remained open for the licensee to further investigate and propose a solution to the NRC.

d.

The item remained open for further investigation by the NRC.

e. The item remained open for further investigation and discussion by both the NRC and the licensee.

A revised IST program dated March 3, 1986, as amended by letters dated July 3, 1986; August 18, 1986; and March 17, 1987, was received and was compared to the previous submittal to identify any changes.

The changes were evaluated to determine whether they were acceptable and if not, they 6

were added to the items that remained open from the meeting.

Several conference calls were held between the licensee, the NRC, and the reviewers to clarify the NRC positions on the open items and discuss the licensee's proposed resolutions.

This TER is based on information contained in the submittals and on information obtained in the meetings and conference calls which took place during the review process.

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3. PUMP TESTING PROGRAM The San Onofre, Unit 1, IST program submitted by Southern California Edison Company was examined to verify that all pumps whose function is safety related are included in the program and are subjected to the periodic tests required by the ASME Code,Section XI, 1977 Edition through Winter 1979 Addenda, and the NRC positions and guidelines. The reviewers found that, except as noted in Appendix C or where specific relief from testing has been requested, these pumps are tested to the Code requirements. Each Southern California Edison Company basis for requesting relief from the pump testing requirements and the EG&G reviewer's evaluation of that request is summarized below.

3.1 Auxiliary Feedwater System 3.1.1 Relief Request The licensee has requested relief from measuring pump flow rate every three months as required by Section XI, table IWP-3100-1, for the motor driven and steam driven auxiliary feedwater pumps, G-10 and G-10S. As an alternative, the licensee has proposed to measure pump differential pressure on a monthly interval by utilizing the miniflow lines and has proposed to measure pump flow rate and differential pressure during cold shutdown.

3.1.1.1 Licensee's Basis for Requesting Relief. Flow instrumentation is not installed in the test loop of this system. For the Auxiliary Feedwater Pumps, alternate testing will consist of the following. At cold shutdown intervals, both pumps will be tested by measuring pump flow rate and pump differential pressure. At monthly intervals, both pumps will be tested by running the pumps using the miniflow lines and by measuring pump differential pressure.

3.1.1.2 Evaluation. Interim relief may be granted as requested since the alternate testing frequency is better than Code requirements and full flow testing during cold shutdown will measure all Code required 9

parameters. However, the licensee should provide further information to enable full evaluation of this relief request in a timely manner. In the update for the next ten year interval the licensee should provide the following information:

The licensee should justify that the present or proposed alternative to the Code is equivalent to the Code required testing. The licensee should discuss all of the potential pump failure mechanisms for these pumps and the means by which the IST program will detect degradation for each of these failure mechanisms. The licensee whould include in his discussion, as necessary, cold shutdown or refueling outage full flow testing, the pump vibration monitoring techniques to be used, failure rates for similar pumps in use at nuclear power plants, and scheduled maintenance performed on these pumps.

3.2 Diesel Fuel Transfer System 3.2.1 Relief Reauest The licensee has requested relief from measuring bearing temperature and vibration in accordance with the requirements of Section XI, table IWP-3100-1 for the diesel fuel transfer pumps, G-47 A, G-47 B, G-75 A and G-75 B. As an alternative, the licensee has proposed to measure and trend pump motor thrust bearing vibration quarterly.

3.2.1.1 Licensee's Basis for Requesting Relief. The Diesel Fuel Transfer Pumps are submergence type pumps located inside diesel fuel storage tanks and are not accessible. Therefore, it is not possible to measure bearing vibration. The pumps are submerged in diesel fuel.

The diesel fuel provides lubrication for the bearings.

Vibration of the pump motor thrust bearing will be measured and trended on a quarterly basis to provide indirect indication of pump degradation. This activity will commence by the end of the next refueling outage.

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3.2.1.2 Evaluation. These pumps are submerged and inaccessible.

Portable temperature and vibration instrumentation cannot be utilized to monitor the pump parameters. Because of the design of these pumps, compliance with the Code requirements is impractical.

Conformance with the Code requirements would only be possible if the diesel fuel transfer system were substantially redesigned. Based on the determination that the Code requirements are impractical, and considering the licensee's proposed alternative measurements of the vibration of the pump motor thrust bearing and the burden on the licensee if the Code requirements were imposed, relief may be granted as requested.

3.3 Safety Injection System 3.3.1 Relief Request The licensee has requested relief from measuring flow rate in acccrdance with the requirements of Section XI, table IWP-3100-1 for the safety injection pumps, G-50 A and G-50 B. The licensee has proposed to measure flow rate quarterly after the next refueling cycle when suitable instrumentation for measurement of pump flow rate will be installed.

3.3.1.1 Licensee's Basis for Requesting Relief. Flow instrumentation is not presently installed in the test loop for these pumps. However, during the next-refueling outage, suitable instrumentation will be installed in the test loops for these pumps to take differential pressure measurements. By the end of the outage, this instrumentation will be in service and flow rate calculations will be performed on a quarterly basis as a part of the Inservice Testing program.

3.3.1.2-Evaluation. The licensee has committed to make these modifications prior to the end of the next refueling outage.

For the balance of the period of the current fuel cycle, interim relief may be granted to test the pumps as proposed by the licensee. The pumps will be monitored on a quarterly basis for inlet pressure, differential pressure, lubricant level and vibration amplitude; bearing temperature will be measured annually. Requiring the licensee to make these modifications 11.

prior to the next refueling outage would impose unnecessary hardship on the licensee without a compensating increase in the level of safety. Taking into account the inservice tests that will be performed as well as the relatively short operational time until the next refueling outage, it is concluded that this interim relief may be granted as requested.

3.4 Safety Injection Recirculation System 3.4.1 Relief Request The licensee has requested relief from measuring inlet pressure, differential pressure, flow rate, vibration, and bearing temperature in accordance with the requirements of Section XI, table IWP-3100-1 for the safety injection recirculation pumps, G-45 A and G-45 B. As an alternative, the licensee has proposed to observe pump running current on a monthly basis and to operate and test the pumps at shutoff head during refueling outages when the normally dry suction sump is filled with water.

3.4.1.1 Licensee's Basis for Requesting Relief. Under normal plant conditions these pumps and their discharge piping are dry. There is no provision to fill the sump during power operation. Thus, it is not possible to obtain hydraulic measurements as required by the Code.

These pumps are located in the containment sump, which is a high radiation area, and are not accessible during operation.

Therefore, it is not possible to take vibration and bearing temperature data.

The requirements of Technical Specification 4.2.II.B(3) will be used in lieu of the Section XI pump testing requirements. This Technical Specification requires that proper starting of each pump be confirmed by observation of running current demonstration on a monthly basis. To be acceptable, pump running current must be less that 150 amps.

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Every refueling or once every 2 years, a test requiring the sump to be filled with water and the pump to be run at shut-off head will be accomplished. No vibration or bearing temperature data will be obtained due to the pump being submerged.

3.4.1.2 Evaluation. The licensee has demonstrated that, with present system design, all parameters required by Section XI cannot be measured.

These pumps are located inside containment in a normally dry sump so the required parameters cannot be monitored nor the pumps tested during power operation. As an alternative the licensee has proposed that proper starting of each pump be confirmed by observation of running current on a monthly basis utilizing an acceptance criterion that motor amperage must be less than 150 amperes. Additionally, the licensee has proposed testing these pumps during refueling outages by filling the containment sump and running them against a shut-off head. Due to system design, this proposed alternate testing is the only practical test available. Conformance with the Code requirements would necessitate a substantial redesign of the containment sump and the safety injection recirculation system. Based on the impracticality of meeting the Ccde requirements, the burden on the licensee if the Code requirements were imposed, and the reasonable assurance of operability provided by the alternative testing proposed by the licensee, relief may be granted as reauested.

3.5 Refueling Water System 3.5.1 Relief Request The licensee has requested relief from measuring flow rate in accordance with the requirements of Section XI, table IWP-3100-1 fcr the refueling water pumps, G-27 N and G-27 S. The licensee has proposed to measure flow rate quarterly after the next refueling cycle when suitable instrumentation for measurement of pump flow will be installed.

3.5.1.1 Licensee's Basis for Requesting Relief. Flow instrumentation is not installed in the test loop for these pumps. However, during the next refueling outage, suitable instrumentation will be installed on both 13

pumps to take differential pressure measurements. By the end of the outage, this instrumentation will be in service and flow rate calculations will be performed on a quarterly basis as a part of the Inservice Testing program.

3.5.1.2 Evaluation. The licensee has committed to make these modifications prior to the end of the next refueling outage.

For the balance of the period of the current fuel cycle, interim relief may be granted to test the pumps as proposed by the licensee. The pumps will be monitored on a quarterly basis for inlet pressure, differential pressure, bearing temperature, lubricant level and vibration amplitude. Requiring the licensee to make these modifications prior to the next refueling outage would impcse unnecessary hardship on the licensee without a compensating increase in the level of safety. Based on the impracticality of meeting the Code requirements, the burden on the licensee if the Code requirements were imposed, and the relatively short operational time until the next refueling outage, rellef may be granted as requested.

3.6 Saltwater Cooling 3.6.1 Relief Request The licensee has requested relief from measuring vibration and bearing temperature in accordance with the requirements of Section XI, table IWP-3100-1 for the saltwater cooling pumps G-13 A and G-13 B. As an alternative, the licensee has proposed to measure thrust bearing vibration and temperature and observe thrust bearing lubricating service water flow monthly.

3.6.1.1 Licensee's Basis for Requesting Relief. These saltwater cooling pumps are submergence type pumps with bearings located under water and inaccessible. Therefore, it is not possible to measure pump bearing vibration or temperature. The pumps bearings are cooled and lubricated by fresh water from the service water system. As an alternative, monthly temperature and vibration measurements on the saltwater cooling pump motor 14

thrust bearings will be taken. Also, once a month, water flow to the pumps bearings will be verified in lieu of lubricant level or pressure.

3.6.1.2 Evaluation. These pumps are submerged and inaccessible. The licensee has demonstrated that, due to pump design and location under water, the vibration measurement and temperature observation requirements cannot be accomplished and, therefor, compliance with the Code requirements is impractical.

Compliance with the Code requirements would only be possible if the saltwater cooling system were substantially redesigned.

Based on the determination that the Code requirements are impractical, and considering the licensee's proposed alternative measurements on the pump motor thrust bearings and burden on the licensee if the Code requirements were imposed, relief may be granted as requested.

3.7 Residual Heat Removal System 3.7.1 Relief Request The licensee has requested relief from testing the residual heat removal pumps, G-14 A and G-14 B, quarterly in accordance with Section XI, IWP-3400 and has proposed to test these pumps during cold shutdowns.

3.7.1.1 Licensee's Basis for Requesting Relief. During normal plant operation, the low pressure RHR system is isolated from the RCS by motor operated valves MOV-813 and MOV-814 which are series valves on the suction side of RHR pumps G-14A and G-14B. Additionally, MOV-833 and MOV-834, the first isolation valves at the RCS boundary, are interlocked with RCS pressure such that these valves may not be opened until RCS pressure has been reduced to 400 psig or less.

The pumps are provided with a 2 inch diameter bypass that is used for safety injection recirculation alternate path hot leg injection and a 3/4 inch diameter bypass that is used for system warmup. If the pump is run with the suction valves MOV-813 and MOV-814 closed, net positive suction head for the pumps would be provided by letdown.pressure. However, for this to be done the pressure control valve (PCV-1105) would have to be 15

placed in the manual position and RCS letdown pressure would be controlled by the plant operators. Since this valve has a very slow response time, it could result in system overpressurization and the lifting of the RHR system relief valve RV-206, which has a setpoint of approximately 480 psig.

Lifting of this relief valve has, historically, led to continued valve leakage and cause for having to perform difficult repairs in Mode 3.

If the RHR pumps are operated in this abnormal configuration, the total flow would be approximately 320 gpm, which is below the minimum flow required for pump hydraulic stability (380 gpm).

Additionally, these pumps are located inside containment within the secondary shield in a high radiation area. Consequently, since they are inaccessible during plant operation, visible abnormalities and deterioration in RHR pump performance during the test would go undetected.

Testing'the pumps without the RHR system in service would force system equipment to be operated in an abnormal manner and, therefore, increase the risk of unanticipated system transients. In addition, as stated previously, it would increase the risk of lifting the system pressure relief valve (RV-206) and possibly damage the pump due to its operation ou'tside of its design conditions.

Past operating experience has demonstrated there is no indication that additional pump testing between plant shutdowns would increase pump reliability. There have been no pump failures during startup of the RHR system in the entire operating history at San Onofre Unit 1. As a result, the pumps should be tested quarterly only during cold shutdown. As an alternative, pumps will be tested within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months of placing the RHR system in service if it has been more than 3 months since the pump's last inservice test. Test frequency during cold shutdown periods will be quarterly.

3.7.1.2 Evaluation. The licensee has indicated that quarterly testing of the RHR pumps would require that this system be placed in an abnormal configuration and could result in system overpressurization and lifting of the RHR system relief valve. In addition these pumps are 16

located inside containment within the secondary shield in a high radiation area and are inaccessible for the purposes of performing the Code required test. As an alternative the licensee has proposed testing the pumps within 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months of placing the RHR system in service if it has been more than 3 months since the pump's last inservice test. The test frequency during cold shutdown periods will be quarterly. Based on the impracticality of complying with the Code requirements to test the pumps quarterly and the licensee's proposed alternative to make all the Code required pump measurements whenever the pumps are placed in service, relief from the Code requirements may be granted as requested.

3.8 Feedwater System 3.8.1 Relief Request The llcensee has requested relief from measuring flow rate in accordance with Section XI, table IWP-3100-1 for each feedwater pump, G-3 A and G-3 B, and has proposed to measure total system,flow rate and assign a flow rate value to each pump.

3.8.1.1 Licensee's Basis for Requesting Relief. Both feedwater pumps discharge to a common feedwater header. From this header, three branch lines (with flow indication) provide feedwater to each of the three steam generators. No flow measuring instrumentation is provided on the individual discharge of each feed pump and therefore, total flow is measured, rather than individual flow. As an alternative, the total flow from both pumps shall be measured. Additionally, input amps to each motor shall be measured. A ratio of the total flow will be credited to each pump based on the input amps. The flow rate credited to each pump will be evaluated per.IWP-3200.

3.8.1.2 Evaluation. The licensee has demonstrated that with present system design individual pump flow cannot be measured. Because of the lack of installed individual pump flow meters, compliance with the Code requirements is impractical and conformance with the Code would only be possible if this system were substantially redesigned. The staff concludes 17

that the alternate testing proposed will give reasonable assurance of pump operability. Based on the determination that the Code requirements are impractical, and considering the licensee's proposed alternative of calculating individual pump flow rate, and the burden on the licensee if the Code requirements were imposed, relief may be granted as requested.

3.9 Containment Spray System 3.9.1 Relief Request The licensee has requested relief from the pump vibration displacement measurement requirements of Section XI, table IWP-3100-1 for the spray chemical addition pumps, G-200 A and G-200 B, and has proposed-to measure pump vibration velocity.

3.9.1.1 Licensee's Basis for Requesting Relief. Existing vibration monitoring equipment cannot meet the Code requirement to measure the displacement vibration amplitude, due to a bandpass filter which deletes vibration input below 350 cycles per minute (350 rpm).

Pump speed is 77,5-155 rpm (variable speed). Vibration probe sensitivity for available equipment is 120 to 9000 rpm when measuring in units of velocity.

As an alternative, these pumps will be tested in units of velocity using existing equipment at greater than or equal to 120 rpm. This will provide vibration monitoring at 1 times rpm where most rotating equipment malfunctions occur. The table entitled "Allowable Ranges of Vibration Velocity for Pump Testing per Subsection IWP" (as attached to this relief request) provides the acceptable criteria for the vibration measurements.

3.9.1.2 Evaluation.

Existing vibration monitoring equipment cannot meet the Code requirements, however, available instrumentation that measures vibration in units of velocity will adequately monitor the pump vibration for identification of degradation. The acceptance criterion provided in the table is an acceptable alternate to the Code requirements.

18

Based on the determination that the licensee's proposed alternative vibration velocity measurements will provide information equivalent to or better than the Code requirement and the burden on the licensee if the Code requirements were imposed, relief may be granted as requested.

19

4. VALVE TESTING PROGRAM The San Onofre Nuclear Generating Station, Unit 1, IST program submitted by Southern California Edison Company was examined to verify that all valves that are included in the program are subjected to the periodic tests required by the ASME Code,Section XI, 1977 Edition through Winter 1979 Addenda, and the NRC positions and guidelines. The reviewers found that, except as noted in Appendix C or where specific relief from testing has been requested, these valves are tested to the Code requirements. Each Southern California Edison Company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request is summarized below and grouped according to system and valve category.

4.1 All Systems 4.1.1 Rapid-Acting Valves 4.1.1.1 Relief Request. The licensee has requested relief from increasing the test frequency of all power operated safety related valves with stroke times of two seconds or less if these valves exhibit an intrease in stroke time of 50% or more in accordance with the requirements of Section XI, IWV-3417(a) and has proposed to declare these valves inoperable if the maximum stroke time is exceeded.

4.1.1.1.1 Licensee's Basis for Requesting Relief--It has been observed through surveillance testing and corrective action that the repeatability of valve stroke times for valves with short stroke times is sporadic and independent of degradation. As an alternative, valves with stroke times of two seconds or less that exhibit an increase in stroke time of 50% or m'ie need not have the test frequency increased. However, if a valve stroke time does exceed its maximum stroke time value, it shall be declared inoperable.

4.1.1.1.2 Evaluation--The licensee has shown that it is not practical to obtain accurate measurements of the stroke times for these rapid-acting valves. Variability of stroke times of rapid-acting power 21

operated valves is primarily a function of the timing method and is not a reliable indicator of valve degradation. Based on the design of these valves the staff has concluded that assigning a maximum stroke time of 2 seconds is a reasonable alternative to the Code requirements for these valves. The licensee has committed to declare these valves inoperable if the maximum stroke time is exceeded. Therefore, since the licensee's proposed alternative is a reasonable alternative to the Code requirements for providing assurance of valve operability, relief may be granted as requested.

4.2 Safety Injection System 4.2.1 Category A/C Valves 4.2.1.1 Relief Request. The licensee has requested relief from exercising safety injection header check valves SIS-003, SIS-004, and SIS-010, in accordance with the requirements of Section XI, IWV-3522 and has proposed to disassemble and inspect these check valves on' a sample basis during refueling outages.

4.2.1.1.1 Licensee's Basis for Requesting Relief--These valves cannot be tested during operation since they provide isolation of the safety injection system from the reactor coolant system. They cannot be tested at cold shutdown due to the requirement that two positive barriers exist between the feedwater system and the reactor coolant system (Technical Specification requirement). This requirement precludes establishing flow through the valve. The valves will be partially disassembled, inspected and manually full-stroked at each refueling outage on a rotating basis (one valve per refueling).

However, if it is found that the full-stroke capability of the disassembled valve is in question, the other two valves will be similarly disassembled, inspected and manually full-stroked during the same outage.

Photographs of the valve "as found" internals will be taken at each inspection and retained as records, taking note of any abnormalities observed.

22

4.2.1.1.2 Evaluation--These valves cannot be exercised during power operation because the flow required would cause dilution of the primary coolant boron concentration and could cause a reactor trip. During cold shutdown, testing could introduce boron into the condensate system and could upset steam generator chemistry control which, in turn, could delay reactor startup.

The NRC staff has concluded that a valve sampling disassembly/inspection utilizing a manual full-stroke of the disk is an acceptable method to verify a check valve's full-stroke capability. The sampling technique requires that each valve in the group must be of the same design (manufacturer, size, model number and materials of construction) and must have the same service conditions. Additionally, at each disassembly it must be verified that the disassembled valve is capable of full-stroking and that its internals are structurally sound (no loose or corroded parts).

A different valve of each group is required tobe disassembled, inspected and manually full-stroked at each refueling, until the entire group has been tested. If it is found that the disassembled valve's full-stroke capability is in question, the remainder of the valves in that group must also be disassembled, inspected and manually full-stroked at the same outage.

Disassembling and inspecting the valve internals and manually stroking on a sample basis each refueling outage is an acceptable alternative testing method to the Code requirements and is the only practical method available to the licensee. The licensee has committed to exercise and verify the-full-stroke capability of these valves by disassembly/inspection and manual-f-1l-stroking. Compliance with the Code required testing method is impractical due to system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's 23

proposed alternative testing, relief from the Code requirements may be granted provided the licensee tests these check valves in accordance with the provisions described above.

4.2.2 Category C Valves 4.2.2.1 Relief Request. The licensee has requested relief from exercising safety injection recirculation pumps discharge check valves CRS-008 and CRS-009, in accordance with the requirements of Section XI, IWV-3522 and has proposed to disassemble and manually full-stroke exercise these valves during refueling outages.

4.2.2.1.1 Licensee's Basis for Requesting Relief--These valves are located on the discharge lines from the safety injection system recirculation pumps, which are located inside containment in a dry sump.

Testing of-the valves would require flow in the discharge lines of the pumps to verify proper operation. This is not practical due to the possibility of filling the suction piping of the refueling water pumps and the charging pumps with debris from the sump.

Both check.valves will be partially disassembled, inspected and the disks hand-stroked during each refueling outage.

Photographs of the valve "as found" internals will be taken and retained as records, taking note of any abnormalities observed.

4.2.2.1.2 Evaluation--The licensee has demonstrated that exercising these valves with flow would require filling the normally dry containment sump which would result in a large volume of potentially contaminated water that must be processed through the radwaste system and could also introduce debris from the sump into the refueling water return line from which the refueling water pumps and charging pumps can take suction.

Disassembly and manually full-stroking to verify proper valve operation is an acceptable alternate testing method to the Code requirements and is the only practical method available to the licensee.

The licensee has committed to exercise and verify the full-stroke capability of these valves by disassembly/inspection and manual full-stroking. Compliance with the Code required testing method is impractical due to system design. Compliance with the Code required 24

testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternative testing, relief from the Code requirements may be granted provided the licensee tests these check valves in accordance with the provisions described in section 4.2.1.1.2 of this report.

4.2.2.2 Relief Request. The licensee has requested relief from exercising safety injection pump discharge check valves SIS-303 and SIS-304, in accordance with the requirements of Section XI, IWV-3522 and has proposed to disassemble and inspect these check valves on a sample basis during refueling outages.

4.2.2.2.1 Licensee's Basis for Requesting Relief--These valves cannot be tested at full design flow without initiating safety injection.

The minimum flow calculated to full-stroke these valves is 3500 gpm. The only available flowpath to test these valves is through a 2 in. bypass line. This line restricts flow to less than the minimum required to full-stroke the valves. Each valve will be partially disassembled, intpected and manually full-stroked at alternate refuelings. Photographs of the valve "as found" internals will be taken and retained as records, taking note of any abnormalities observed. If the full-stroke capability of the disassembled valve is in question, the other valve will be disassembled, inspected and manually full-stroked during the same outage.

4.2.2.2.2 Evaluation--Due to system design, these valves cannot be full-stroke exercised during power operation because that requires a safety injection initiation and the feedwater pumps are utilized to feed the steam generators. During safety injection, the safety injection pumps discharge to the feedwater pumps which discharge to the RCS. These valves cannot be full-stroke exercised during cold shutdown as a low-temperature overpressurization of the RCS could result. Disassembly of these valves to perform a manual full-stroke exercise to verify valve operability is an acceptable alternate testing method to the Code requirements and is the only practical method available to the licensee. The licensee has 25

committed to verify the full-stroke capability of these valves by disassembly. Compliance with the Code required testing method is impractical due to system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternative testing, relief from the Code requirements may be granted provided the licensee tests these check valves in accordance with the provisions described in section 4.2.1.1.2 of this report.

4.3 Feedwater System 4.3.1 Category C Valves 4.3.1:1 Relief Request. The licensee has requested relief from exercising main feedwater pumps discharge check valves FWS-438 and FWS-439, in accordance with the requirements of Section XI, IWV-3522 and has proposed to disassemble and manually full stroke each valve during refueling outages.

4.3.1.1.1 Licensee's Basis for Requesting Relief--These valves cannot be exercised closed due to a hole which is drilled in the valves to relieve pressure between the pumps and the Safety Injection System valves.

During the IST, backflow through these holes could cause reverse rotation of the feedwater pumps with potential for damage resulting. As an alternative these valves will be disassembled, inspected and manually full stroke exercised at each refueling. Photographs of the valve "as found" internals will be taken and retained as records.

4.3.1.1.2 Evaluation--The licensee has determined that closure verification of the check valve on the discharge of an idle pump would result in backflow through the hole drilled in the valve disk and could cause reverse rotation of the pump resulting in damage to that pump.

Disassembly of these valves to perform a manual full-stroke exercise to verify valve operability is an acceptable alternate testing method to the 26

Code requirements and is the only practical method available to the licensee. The licensee has committed to verify the full-stroke capability of these valves by disassembly. Compliance with the Code required testing method is impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternative testing, relief from the.Code requirements may be granted provided the licensee tests these check valves in accordance with the applicable provisions described in section 4.2.1.1.2 of this report.

4.4 Diesel Generator Cooling Water System 4.4.1 Category C Valves 4.4.1.1 Relief Request. The licensee has requested relief from exercising DWN-306 and DWS-306, "keep warm" pump discharge check valves and DWN-309 and DWS-309, attached water pump discharge check valves in accordance with the requirements of Section XI, IWV-3522 and has proposed to'disassemble and verify closure of each valve during every refueling outage.

4.4.1.1.1 Licensee's Basis for Requestina Relief--There are no provisions for checking valve closure. During refueling, preventative maintenance is performed on the diesel generators. As a part of this maintenance, the check valves will be disassembled and inspected at every refueling outage. As an alternate, these valves will be stroked open quarterly, disassembled and inspected at each refueling outage.

Photographs.Vf the valve "as found" internals and retention of records, taking note of any abnormalities observed will be performed.

4.4.1.1.2 Evaluation--The licensee has demonstrated that the only method to verify closure of the valves is periodic disassembly to verify integrity of the valve internals. Disassembling and inspecting the valve internals and manually stroking these valves each refueling outage is 27

an acceptable alternative testing method to the Code requirements and is the only practical method available to the licensee. The licensee has committed-to exercise and verify the full-stroke capability of these valves by disassembly/inspection and manual full-stroking. Compliance with the Code required testing method is impractical due to system design.

Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticali-ty of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternative testing, relief from the Code requirements may be granted provided the licensee tests these check valves in accordance with the applicable provisions described in section 4.2.1.1.2 of this report.

4.5 Miscellaneous Water Systems 4.5.1 Category B Valves 4.5.1.1 Relief Request. The licensee has requested relief from exprcising sphere fire suppression spray header supply valve CV-92, in accordance with the requirements of Section XI, IWV-3412 and has proposed to full-stroke exercise this valve during refueling outages.

4.5.1.1.1 Licensee's Basis for Requesting Relief--Exercising this valve while in operation would allow water from the refueling water storage tank to flow through the fire suppression spray header inside containment. This water would flow over the reactor coolant pumps, residual hea-removal pumps, and other vital equipment. Testing at cold shutdowns could allow water accumulated in the piping to run out the spray nozzles since the nozzles are at a lower elevation than portions of the spray piping. As discussed previously, this water would flow over the reactor coolant pumps, residual heat removal pumps, and other vital equipment. Thus is would be necessary to drain and disable the system to allow exercising the valve. Technical Specifications require that this valve be cycled at least once per 18 months. The valve will be exercised during refueling when the refueling water storage tank is drained.

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4.5.1.1.2 Evaluation--The licensee has demonstrated that it would be necessary to drain and disable the fire suppression spray header to exercise this valve without allowing water to flow over the reactor coolant pumps, residual heat removal pumps, and other vital equipment.

Allowing water to flow over this equipment could result in equipment damage and require extensive clean up.

Draining and disabling the fire suppression spray header during cold shutdown could result in delaying the startup from the cold shutdown condition. Therefore, compliance with the Code required testing frequency is impractical.

Full-stroke exercising this valve at least once per 18 months, during refueling outages when the refueling water storage tank can be drained will demonstrate proper valve operability. Based on the impracticality of meeting the Code requirements, the burden to the licensee if the.Code requirements were imposed, and the alternative testing proposed by the licensee, relief may be granted as requested.

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APPENDIX A VALVES TESTED DURING COLD SHUTDOWNS A-1

APPENDIX A VALVES TESTED DURING COLD SHUTDOWNS The following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full-stroke exercised every three months during plant operation. These valves are specifically identified by the owner in accordance with Paragraph IWV-3412 and 3522 and are full-stroke exercised during cold shutdowns and refueling outages. All valves in this Appendix have been evaluated and the reviewer agrees with the licensee that testing these valves during power operation is not possible due to the valve type and location or system design. These valves should not be full-stroke exercised during power operation. These valves are listed below and grouped according to the system in which they are located.

1. REACTOR COOLANT SYSTEM 1.1 Category A/C Valves Containment nitrogen supply check valve GNI-102 cannot be exercised during power operation because the valve is located inside containment and is not accessible. This check valve provides containment isolation for the nitrogen backup supply to the PORVs and block valves. This valve will be full-stroke exercised during cold shutdowns.

1.2 Category B Valves Pressu:zer power operated relief valves CV-545 and CV-546 should not be exercise~dduring power operation since these valves have shown a high probability of sticking open and are not needed for overpressure protection during power operation. The NRC has concluded that routine exercising during power operation is 'not practical' and, therefore, not required by IWV-3410.

A-3

The PORV's function during reactor startup and shutdown is to protect the reactor vessel and coolant system from low temperature overpressurization conditions and should be exercised prior to initiation of system conditions for which vessel protection is needed. The following test schedule is required:

a.

Full-stroke exercising should be performed at each cold shutdown or, as a minimum, once each refueling cycle. In case of frequent cold shutdowns, testing of the PORVs is not required more often than each three months.

b.

Stroke timing should be performed at each cold shutdown, or as a minimum, once each refueling cycle.

c.

Fail-safe actuation testing should be performed at each cold shutdown.

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.

The licensee has included the PORVs (CV-545 and 546) in the IST program as Category B valves and the PORV block valves (CV-530 and 531) as Category B valves and is exercising them in accordance with the above guidelines.

2. REACTOR COOLANT GAS VENT SYSTEM 2.1 Category B Valves Reactor vessel head vent valves SV-2401, SV-2402, SV-2403, SV-2404, SV-3401, SV-3402, SV-3403, and SV-3404 cannot be exercised during power operation because failure during testing could result in a breach of the reactor coolant system pressure boundary. These valves will be full-stroke exercised during cold shutdown.

A-4

3. CHEMICAL AND VOLUME CONTROL SYSTEM 3.1 Category A Valves Reactor coolant pump seal water return isolation valves CV-527 and CV-528 cannot be exercised during power operation. These valves can be operated full open or full closed only. Closing them during operation would interrupt reactor coolant pump seal water return flow and cause the relief valve in the upstream piping to lift. Additionally, failure of either valve while testing could result in damage to the reactor coolant pump seals due to loss of flow. These valves will be full-stroke exercised during cold shutdown.

3.2 Category B Valves Reactor coolant pump seal water bypass valve CV-276 cannot be exercised during power operation since this would affect operation of the reactor coolant pump seal water system and could damage the reactor coolant pump seals. This valve will be full-stroke exercised during cold shutdowns.

Charging line isolation valve CV-304 cannot be exercised during power operation because full or partial operation could affect reactor coolant level control and could result in a reactor trip. This valve will be full-stroke exercised during cold shutdowns.

Auxiliary spray header isolation valve CV-305 cannot be exercised during power operation because full or partial operation would result in thermal shock to the pressurizer spray header. This valve will be full-stroke.;exercised during cold shutdowns.

Charging header isolation valve FCV-1112 cannot be exercised during power operation because that would inhibit charging water flow and could result in a reactor trip. This valve will be partial-stroke exercised during power operation and full-stroke exercised during cold shutdowns.

A-5

Reactor coolant pump seal water supply valves FCV-1115A, B, C, D, E, and F cannot be exercised during power operation because full-stroke exercising would interrupt seal water flow to the reactor coolant pumps and could result in damage to the pumps seals. These valves will be partial-stroke exercised during power operation and full-stroke exercised during cold shutdowns.

Volume control tank outlet valve LCV-1100C cannot be exercised during power operation because closing this valve would isolate the normal suction path to the charging pumps and consequently interrupt reactor coolant pump seal flow. Alternate flow paths would result in overboration of the reactor coolant system and a plant shutdown.

This valve will be full-stroke exercised during cold shutdowns.

Reactor coolant pump seal water outlet valves PCV-1115A, B, and C cannot be exercised during power operation because they operate full open or full closed only. That would inhibit seal water flow to the reactor coolant pumps which may result in damage to the seals. These valves will be full-stroke exercised during cold shutdowns.

3.3 Category C Valves Charging pumps suction check valve VCC-301 cannot be exercised during power operation because that would interrupt the suction flow path to the charging pumps which could result in a reactor trip. This valve will be full-stroke exercised during cold shutdowns.

Reactor-coolant pump seal water supply check valves RCP-005, 006, and 104 cannot be exercised during power operation without affecting reactor coolant pump seal injection flow which could result in damage to the pump seals. These valves will be full-stroke exercised during cold shutdowns.

Charging line check valve VCC-002 cannot be exercised during power operation because exercising could affect reactor coolant level control and A-6

could result in a reactor trip. This valve will be full-stroke exercised during cold shutdowns.

Auxiliary spray header check valve VCC-003 cannot be exercised during power operation because exercising would result in thermal shock to the pressurizer spray header. This valve will be full-stroke exercised during cold shutdowns.

Seal water heat exchanger bypass check valve VCC-357 cannot be exercised during power operation because that requires isolation of the seal water return line and stopping both charging pumps causes interruption of the reactor coolant pumps seal flow which could result in pump seal damage. This valve will be full-stroke exercised during cold shutdowns.

4. AUXILIARY COOLING SYSTEM 4.1 Category B Valves Reactor coolant pumps thermal barrier cooling coil outlet valves CV-722A, 8, and C, cannot be exercised during power operation because they operate full open or full closed only and exercising would interrupt cooling water flow to the reactor coolant pump thermal barrier cooling coils which could damage the reactor c.oolant pumps. These valves will be full-stroke exercised during cold shutdowns.

4.2 Category C Valves Residual heat removal pumps cooling water return check valves CCW-071 and CCW-074:cannot be exercised during power operation because these two check valves-.discharge through a common flowmeter and verification of flow through one heck valve cannot be accomplished without isolation of the other check valve. The isolation valves for these check valves are located inside containment and, therefore, are inaccessible during power operation. These valves will be full-stroke exercised during cold shutdowns.

A-7

Reactor coolant pump thermal barrier cooling coil inlet check valves CCW-011, CCW-012, and CCW-092 and reactor coolant pump thermal barrier cooling coil emergency inlet check valves CCW-032, CCW-035, and CCW-040 cannot be exercised during power operation because testing requires interruption of the cooling water to the reactor coolant pump thermal barrier cooling coils which could damage the reactor coolant pumps. These valves will be full-stroke exercised during cold shutdowns.

5. RESIDUAL HEAT REMOVAL SYSTEM 5.1 Category B Valves Residual heat removal system flow control valve HCV-602 cannot be exercised'during power operation because this valve is located inside containment at the lowest level in a high radiation area and is inaccessible 'during power operation. This valve has remote position indication of the closed position only, therefore, there is no means of verifying valve full-stroke action during plant operation. This valve will be partial-stroke exercised during power operation and full-stroke exercised during cold shutdowns.

Residual heat removal reactor coolant suction valves MOV-813 and 814 and residual heat removal reactor coolant return valves MOV-83 and 84 an eiulha emvlratrcoan eunvle O-833 and MOV-834 cannot be exercised during power operation because opening these valves could subject the residual heat removal piping and components to above-design pressure. These valves will be full-stroke exercised during cold shutdowns.

5.2 Category C Valves Residual heat removal pump discharge check valves RHR-013 and RHR-014 cannct be exercised during power operation because the residual heat removal pumps must be run to exercise the valves. This can be done only during cold shutdowns due to the system pressure limitations. These valves will be full-stroke exercised during cold shutdowns.

A-8

6. SAFETY INJECTION SYSTEM 6.1 Category 8 Valves Feedwater pump recirculation valves CV-875A and CV-875B cannot be exercised during power operation because opening these valves would allow unborated feedwater to flow into the refueling water storage tank which would dilute its boron concentration. These valves will be full-stroke exercised during cold shutdowns.

Feedwater injection header isolation valves HV-851A and HV-8518 cannot be exercised during power operation because exercising these valves would disrupt feedwater flow to the steam generators which could result in a reactor trip. These valves will be full-stroke exercised during cold shutdowns.

Feedwater pump safety injection header suction valves HV-853A and HV-853B cannot be exercised during power operation because that would' result in dilution of the boron in the refueling water storage tank with feedwater via the safety injection pump minimum flow lines. These valves will be full-stroke exercised during cold shutdowns.

Charging pump safety injection header isolation valves MOV-356, MOV-357, and MOV-358 and refueling water pumps safety injection header cross-tie valve MOV-880 cannot be exercised during power operation because that would disrupt reactor coolant pump seal water flow and could result in damage to the pumps seals. These valves will be full-stroke exercised during cold shutdowns.

Safety injection header isolation valves MOV-850A, MOV-850B, and MOV-850C caNnot be exercised during power operation because they perform a pressure isclation function and opening them while the reactor coolant system is at operating pressure could subject the safety injection system to pressures that are above the design pressure of the system. These valves will be full-stroke exercised during cold shutdowns.

A-9

Containment recirculation pumps discharge valves MOV-866A and MOV-866B cannot be exercised during power operation as these pumps are normally dry and in a standby valve lineup for post-LOCA recirculation.

Testing during normal plant operation could result in loss of recirculation capabilities.

These valves will be full-stroke exercised during cold shutdowns.

Charging pumps refueling water storage tank suction valves LCV-1100B and LCV-11000 cannot be exercised during power operation because full-or partial-stroke exercising would affect reactor coolant level control and could result in a reactor trip. These valves will be full-stroke exercised during cold shutdowns.

RWST outlet isolation valve MOV-883 cannot be shut during-power operation since this would isolate both trains of containment spray which is in violation of Technical Specification 3.3.1. This valve will be

-full-stroke exercised and stroke timed during cold shutdowns.

6.2 Catecory C Valves Charging pumps refueling water storage tank suction check valve RCP-337 cannot be exercised during power operation because that would require shifting the charging pump suction to the refueling water storage tank which would affect reactor coolant level control and could result in a reactor trip. This valve will be full-stroke exercised during cold shutdowns.

Refueling water pumps safety injection header cross-tie check valve VCC-388 cannot be exercised during power operation because that may disrupt reactor cool-ant pump seal water flow and could damage the pump seals. This valve will be full-stroke exercised during cold shutdowns.

7. STEAM SYSTEM 7.1 Category B Valves Main steam atmospheric dump valves CV-76, CV-77, CV-78, and CV-79 cannot be exercised during power operation because testing them would dump A-10

e steam to the atmosphere and could cause a reactor trip. These valves will be full-stroke exercised during cold shutdowns.

8. MISCELLANEOUS WATER SYSTEMS 8.1 Category B Valves Containment spray header isolation valves CV-82 and CV-114 cannot be exercised during power operation because that would cause the refueling water storage tank to partially drain to the containment spray piping and into the containment through a drain in the spray piping. These valves will be full-stroke exercised during cold shutdowns.

8.2 Category C Valves Refueling water pumps discharge check valves CRS-304 and CRS-305 and refueling water pumps suction check valve CRS-301 cannot be exercised during power operation because of the potential for flooding the fire protection or containment spray piping with borated water. these valves will be full-stroke exercised during cold shutdowns.

9. FEEDWATER AND CONDENSATE SYSTEM 9.1 Category B Valves Main feedwater control valve bypass valves CV-142, CV-143, and CV-144, main feedwater flow control valves FCV-456, FCV-457, and FCV-458, and main feedwater header shutoff valves MOV-20, MOV-21, and MOV-22 cannot be full-stroke exercised during power operation because that would disrupt feedwater flow and could result in a reactor trip. These valves will be partial-stroke exercised during power operation and full-stroke exercised during cold shutdowns.

Main feedwater pumps discharge valves HV-852A and 852B and main feedwater pumps suction valves HV-854A and HV-854B cannot be exercised during power operation because these valves operate full open or full A-11

closed only. Full-stroke exercising them during normal operation would cause a loss of feedwater to the steam generators which would result in a reactor trip. These valves will be full-stroke exercised during cold shutdowns.

9.2 Category C Valves Main feedwater control valve bypass check valves FWS-378, FWS-379, and FWS-417 cannot be exercised during power operation because that would interfere with the operation of the steam generator level control system and could result in a reactor trip. These valves will be full-stroke exercised during cold shutdowns.

Main feedwater header check valves FWS-345, FWS-346, and FWS-398 cannot be exercised during power operation because that would interrupt

-feedwater flow to the steam generators and could result in a reactor trip.

These valves will be full-stroke exercised during cold shutdowns.

10.

AUXILIARY FEEDWATER SYSTEM 10.1 Category B Valves Auxiliary feedwater header flow control valves FCV-2300, FCV-2301, FCV-3300 and FCV-3301 cannot be fail-safe tested during power operation because testing these valves requires removing all power from the control system of one train. Deenergizing and energizing this control loop requires verification of the bistable setpoints. This control loop is normally energized in Modes 1 through 5. These valves will be fail-safe tested during cold shutdowns to reduce the frequency of deenergizing and energizing the control loop to minimize degradation of the control loop components.

10.2 Category C Valves Auxiliary feedwater pumps discharge check valves AFW-303 and AFW-304 and the auxiliary feedwater header checks listed below cannot be exercised A-12

during power operation because that would require injecting cold water into the steam generators and would result in thermal shock to the steam generators. These valves will be full-stroke exercised during cold shutdowns.

AF-309 AFW-312 AFW-318 AFW-321 AFW-324 AFW-310 AFW-317 AFW-320 AFW-322 A-13

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APPENDIX B B-1

APPENDIX B The P&IDs listed below were used during the course of this review.

System P&ID Revision Reactor Coolant 568766-17 26 Reactor Coolant Gas Vent 568766-17 26 Chemical and Volume Control 568767-21 18 Auxiliary Cooling 558768-15 17 Residual Heat Removal 568768-15 15 Safety Injection 568769-15 33 Reactor Cycle Sampling 568770-12 11 Radioactive Waste Disposal 568772-23 23 Steam 568773-14 14 Circulating Water 568775-24 24 Miscellaneous Water Systems 568776-22 31 Chemical Feed 568777-16 16 Feedwater and Condensate 568779-22 22 Compressed Air 568780-19 19 Air Conditioning 568782-20 18 Turbine Cycle Sampling 568783-12 12 Post Accident Containment Hydrogen Monitoring 568784-18 18 Nitrogen 568784-18 18 Diesel Fuel f] Storage and Supply 41-1 5154031-2 3

Diesel Generator Cooling Water 5154028-1 1

5154033-1 1

Diesel Generator Starting Air 5154029-2 2

5154034-1 1

Auxiliary Feedwater 5159570-0 0

High Radiation Sampling 5159580-0 8

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APPENDIX C C-1

APPENDIX C The following item was left unresolved at the working meeting and subsequent discussions with the licensee.

PUMPS

1. Credit has been taken for the operability of the thermal barrier emergency cooling pump (TBEC) for three potential events:

(1) loss of offsite power, (2) fire in the 4 kV room or lube oil reservoir area, and (3) station blackout.

The licensee states that the thermal barrier emergency cooling pump need not be included in the IST program for the following reasons:

A.,

A loss of offsite power that lasts more than a few minutes is very improbable at San Onofre and has never been experienced. During a brief loss of,offsite power, cooling in the primary system leakage through the RCP seals will normally be accomplished by the thermal barrier coils with flow provided by the TBEC pump. However, if the TBEC pump is inoperable, recovery from this event can be accomplished by relying on the emergency diesel generators.

b. A fire in the 4 kV switchgear room or lube oil reservoir area would lead to essentially total station blackout until the dedicated shutdown (DSD) system is brought into operation. The O0 system provides seal cooling water through seal injection to the reactor coolant pumps during the initial phase of its operation and is specifically designed to achieve cold shutdown in the event of a fire that renders normal safe shutdown systems inoperable. The interruption of seal cooling and seal injection for the period required to initiate seal injection from the DS system has been evaluated and determined to be acceptable.

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Thus, credit need not be taken for operation of the TBEC pump in case of a fire in the 4 kV switchgear room or lube oil reservoir area.

c. Station blackout continues as an unresolved safety issue and is not a design basis event at this time. The duration of the event to be considered has not been established. In addition, the ultimate resistance of the reactor coolant pump seals has not been determined. Therefore, the need for the TBEC pump has not been established. Under these conditions, it is not appropriate to include the TBEC pump in the IST program.

This pump is used in a safety related function to provide emergency cooling to the Reactor Coolant Pump (RCP) thermal barrier in order to protect the'RCP seals. The seals form a part of the Reactor Coolant.System boundary and must be protected in order to prevent a LOCA. Therefore,, the pump and associated valves are required to be included in the'IST program and tested in accordance with the requirements of Section XI.

2.

The licensee has requested relief from measuring auxiliary feedwater pump flow rate but has not provided enough information to fully evaluate the request for relief (see section 3.1.1 of this report).

Interim relief may be granted as requested, however, the licensee should provide further information for this relief request in a timely manner as detailed in section 3.1.1 of this report.

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ML13331B190

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