ML17229B067
| ML17229B067 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/16/1999 |
| From: | Dibiasio A, Fresco A, Grove E BROOKHAVEN NATIONAL LABORATORY |
| To: | Joseph Colaccino NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML17229B065 | List: |
| References | |
| CON-FIN-J-2402 TAC-MA0664, TAC-MA0665, TAC-MA664, TAC-MA665, NUDOCS 9903240027 | |
| Download: ML17229B067 (104) | |
Text
e ting Program esting Program ATTACHMENT2,
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- ,::-.;: ',';--':-,, TECHNICALEVALVATIONREPORT,
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Units 1 and'2:: "
- Florida Power k, Light Compacny Unit 1 Thirrd Ten-Year Interval Pump and Valve Inservice Tes Unit 2 Second Ten-Year Interval Pump and Valve Inservice T I%"-
Docket Numbers: 50-335 aud 50-389 g4
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~i TAC Numbers: MA0664 and MA0665 t9 W'ecember 1, 1998 Prepared by:
A. M. DiBiasio, A. Fresco, and E. Grove Department ofAdvanced Technology
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- Engineering Technology Division '
Brookhaven National Laboratory Upton, New York 11973 Prepared for:,
J. Colaccino, NRC Technical Monitor Division ofEngineering Offi'ceerofNuclear Reactor Regulation U; S;.Nuclear Regulatory Commission
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ABSTRACT This report presents the results ofBrookhaven National Laboratory's evaluation ofthe relief requests, cold shutdo'wn and refueling outage justifications and, for selected systems, a review of the scope ofFP&L St. Lucie Plant, Unit I and 2, ASME Section XIPump and Valve Inservice Testing Program.
CONTENTS Page ABSTRACT..
1.0
2.0 INTRODUCTION
PUMP IST PROGRAM RELIEF REQUESTS 2.1 Relief from Instrumentation Requirements 2.1.1 Relief Request No. PR-01, AuxiliaryFeedwater and Hydrazine Pumps 2.1.2 Relief Request No. PR-07, Reactor Coolant Charging Pumps..
2.1.3 Relief Request No. PR-08, Hydrazine Pumps 2.2 Relief from Hydraulic Requirements..
2.2.1 Relief Request No. PR-02, AuxiliaryFeedwater Pumps.......
, 2.2.2 Relief Request No. PR-03,.Boric Acid Makeup (BAM)Pumps 2.2.3 Rel!ef Request No. PR-04, Containment Spray (CS) Pumps 2;2.4 Relief Request No. PR-05, High Pressure Safety Injection (HPSI) Pumps 2.2.5 Relief Request No. PR-06, Low Pressure Safety Injection (LPSI) Pumps 2.2.6 Relief Request No. PR-09, Hydr'azine Pumps 2.3 Relief from Corrective Action Requirements 2.3.1 Relief Request No. PR-11, Use ofAnalysis in Lieu ofCorrective Action 2.3.2 ReliefRequest No. PR-12, LPSI Pumps
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.2 4
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.. 26 3.0 VALVEIST PROGRAM RELIEF REQUESTS..
3.1 Relief Valves..
3.1.1 Relief Request No. VR-01, Temperature Stability 3.1.2 Relief Request No. VR-02, Alternate Ambient Temperature.....
3.1.3 Relief Request No. VR-03, Test Accumulators..
3.1.4 Relief Request No. VR-19, Containment Vacuum Breakers......
3.1.5 Relief Request No. VR-20, Sodium Hydroxide and Hydrazine Storage Tanks'acuum Breakers 3.1.6 Relief Request No. VR-22, CVCS Regenerative Heat Exchanger Thermal Relief Valve 3.2 Safety Injection System..
3.2.1 Relief Request No. VR-04, PIV Test Frequency 3.2.2 Relief Request No. VR-05, PIV Test Frequency 3.2.3 ReliefRequestNo. VR-06, PIVTestFrequency
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.. 40 44
CONTENTS (Cont'd) 3.3 3.4 3.5 3.6 3.2.4'elief Request No. VR-21, HPSI to RWT Check Valves'est Frequency Main Steam System 3.3.1 Relief Request No. VR-07, SGs to Turbine Check Valves........
Feedwater System 3.4.1 Relief Request No. VR-10, Feedwater to Steam Generator Check Valves 3.4.2 Relief Request No. VR-11, AFW Pump Min-FlowCheck Valves..
Instrument AirSystem 3.5.1 Relief Request No. VR-12, Vacuum Breaker and MSIV Accumulator Supply Check Valves Containment Spray System 3.6.1 Relief Request No. VR-14, RWT Discharge Check Valves.
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3.6.2 Relief Request No. VR-15, CS to Eductors Check Valves........
3.6.3 Relief Request No.'VR-16, Containment Sump Discharge Check Valves 3.6.4 Relief Request No. V-17, CS Pump Discharge Check Valves...,.
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.48
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.... 57 4.0 VALVETESTING DEFERRAL JUSTIFICATIONS..........................
59 5.0 IST SYSTEM SCOPE REVIEW.
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59 6.0 IST PROGRAM RECOMMENDED ACTIONITEMS..
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7.0 REFERENCES
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65 APPENDIXA
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A-1
Technical Evaluation Report Pump and Valve Inservice Testing Program St. Lucie Units 1 and 2
1.0 INTRODUCTION
Contained herein is a technical evaluation ofAmerican Society ofMechanical Engineers (ASME) Section XIpump and valve inservice testing (IST) program reliefrequests and deferral justifications submitted by Florida Power &, Light Company (FPAL) for its St. Lucie Plant.
Additionally, this technical evaluation report contains, for selected systems, a review ofthe scope ofSt. Lucie's ASME Section XIPump and Valve Inservice Testing Program.
St. Lucie is a Combustion Engineering Pressurized Water Reactor (PWR) that began commercial'operation in December 1976 (Unit 1) and August 1983 (Unit 2).
Florida Power k Light submitted the Unit 1 Third and Unit 2 Second Ten-Year Interval Inservice Testing Program on January 12, 1998 (Ref. 1). One program document contains the IST program for both units (Ref. 2). The licensee states that this program is based on the requirements ofthe 1989 Edition ofthe ASME Section XI Code. This program revision supersedes all previous submittals. In response to a conference call held August 3, 1998, the licensee provided additional information via revised reliefrequests, deleted two reliefrequests, and submitted three additional reliefrequests (Ref. 3).
The licensee in Section 6.5 ofthe IST Program states that the Unit 1 third ten year interval extends from February 11, 1998 to February 10, 2008; and the Unit 2 third ten year interval extends from August 8, 1993 to August 7, 2003. Based on the date ofcommercial operation, the Unit 1 interval should extend from December 1996 to December 2006. ASME Section XI, gWA-2430(c) allows each interval to be extended or decreased by as much as one year.
Adjustments shall not cause successive intervals to be altered by more than one year from the original pattern ofintervals.Section XI,gWA-2430(e) also allows the interval to be extended
, for units that are out ofservice continuously for six months or more. The licensee should provide an explanation ofthe interval dates in the IST program.
AdditionallyUnit 2 is in its second, not third interval; as stated in the submittal letter. The IST Program should be corrected.
Title 10 ofthe Code ofFederal Regulations,
$50.55a $(f) (Ref. 4) requires that inservice testing ofASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI ofthe ASME Boiler and Pressure Vessel Code (Ref. 5) and applicable addenda, except where specific reliefhas been requested by the licensee and granted by the Commission pursuant to
$50.55a $(f)(6)(i),or where an alternate has been requested and authorized pursuant to $50.55a
$(a)(3)(i) or (a)(3)(ii). Section 50.55a $(f)(4)(iv)provides that inservice testing ofpumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of $50.55a, subject to the limitations and modifications listed, and subject to Commission approval. In rulemaking to 10CFR50.55a,
78 I
8 9 8
819926 *II, 757N.15, 8
8 666).
8 989 Edition ofASME Section XIwas incorporated into paragraph (b) of $ 50.55a.
The 1989 Edition provides that the rules for inservice testing ofpumps and valves are as specified in ASME/ANSI OMa-1988 Part 6 and 10, and OM-1987 Part 1 (Refs. 6-8). The voluntary update ofUnit 2's IST Program to the requirements ofthe 1989 Edition of Section XI, in its entirety, provides an acceptance level ofquality and safety and it is recommended that approval be granted in accordance with 10CFR50.55a (fj(4)(iv).
The review ofthe IST Program was performed utilizing the Standard Review Plan, Section 3.9.6; Generic Letter 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," the Minutes ofthe Public Meeting on Generic Letter 89-04, and Supplement to the Minutes; NUREG-1482; NUREG/CR-6396; and the recently published summary ofthe public workshops held in January and February 1997 on IST(References 9-15). The IST Program requirements apply only to component (i.e., pump and valve) testing, and are not intended to provide a basis to change the licensee's current Technical Specifications for system test requirements.'ection 2 ofthis report presents the 11 pump reliefrequests and Brookhaven National Laboratory's (BNL)evaluation.
Similar information is presented in Section 3 for the 18 relief requests for the valve testing program.
Section 4 and Appendix A contain the evaluation of78 justifications to defer valve testing to cold shutdowns or,refueling outages.
Results ofthe IST scope review for selected systems is presented in Section 5. Section 6 summarizes the recommended actions for the licensee, resulting from the reliefrequest and deferred testing justification evaluations, and the review ofthe IST Program scope for selected systems.
BNL recommends that the licensee resolve these items in accordance with the evaluations, conclusions, and guideli'nes presented in this report.
2.0 PUMP IST PROGRAM RELIEF REQUESTS In accordance with $50.55a, FP&L has submitted 11 reliefrequests for pumps at St. Lucie which are subject to inservice testing under the requirements ofASME Section XI. The reliefrequests have been reviewed to verify their technical basis and.determine their acceptability. The relief requests, along with the technical evaluation by BNL, are summarized below. No evaluation of reliefrequest PR-10 was performed since it does not address Code Class pumps 2.1 Relief from Instrumentation Requirements 2;1.1 Relief Request No. PR-01, AuxiliaryFeedwater and Hydrazine Pumps ReliefRequest: The licensee has requested relieffrom the requiiements ofOMa-1988, Part 6,
$4.6.1.2, which requires that the full-scale range ofeach analog instrument shall not be greater than three times the reference value, for the auxiliary feedwater pumps, 1C and 2C, and hydrazine pumps, 2A and 2B.
Licensee 's Basis For Relief: "Part 6, Table 1, requires the accuracy ofinstruments used to measure rotational speed to be equal to or better than +2 percent based on the full-scale reading ofthe instrument. This means that the accuracy ofthe actual measurement can vary as much as
+6'percent, assuming the range ofthe instrument is extended to the maximum allowed deviation (3 times the reference value).
Pump speed is often measured with portable test instruments where commercially available instruments do not necessarily conform to the Code requirements for range. In these cases, high quality calibrated instruments may be used where the reading accuracy, is at least equal to the Code-requirement for full-scale accuracy. This willensure that the measurements are always more accurate than the accuracy as determined by combining the requirements ofPart 6, Table 1, and Paragraph 4.6.1."
Proposed Alternate Testing:
Whenever portable instruments are used for measuring pump speed, the instruments willbe such that the reading accuracy is +2 percent or better.
Although the licensee has not provided specific information regarding the range or accuracy, if the range is greater than 3 times the reference value, the accuracy ofthe instrument must be
+0.66 percent or better to achieve a reading accuracy of+2 percent or better.
Evaluation:
OMa-1988, Part 6, $4.6.1.2, requires that the full-scale range ofeach analog instrument shall not be greater than three times the reference value. Part 6, Table 1 specifies that speed instrumentation have an accuracy of2% offull scale.
The combination ofparagraph 4.6.1.2 and Table 1 could result in a speed instrument reading accuracy of+6% ofthe reference value.
P As discussed in NUREG-1482, $5.5.1, when the range ofa permanently installed analog instrument is greater than three times the reference value but the accuracy ofthe instrument is more conservative than the Code, the staff willgrant reliefwhen the combination ofthe range and accuracy yields a reading at least equivalent to the reading achieved from instruments that meet the Code requirements, i.e., up to + 6%. The use ofany available instruments that meet the intent ofthe Code requirements for the actual reading would yield an acceptable level ofquality and safety for testing.
The licensee has proposed that whenever measuring pump speed with portable instruments, the instruments willhave a reading accuracy of+ 2% or better. Therefore, the licensee's proposed method for measuring pump speed provides an acceptable level ofquality and safety and it is recommended that the alternative be authorized in accordance with 10 CFR 50.55a(a)(3)(i).
As noted in NUREG-1482, $5.5.1, when using portable instruments, the staff recommends that the licensee include in the IST records an instrument number for tracing each instrument and a calibration data sheet for verifying that the instruments are accurately calibrated. If instrumentation becomes commercially available which meets the Code requirements that the 3
full-scale range ofeach analog instrument shall not be greater than three times the reference value, and the licensee is procuring replacement instruments, the licensee should withdraw this reliefrequest and procure instruments which meet the Code requirements.
2.1.2 Relief Request No. PR-07, Reactor Coolant Charging Pumps ReliefRequest.'he licensee has requested relieffrom the requirements ofOMa-1988, Part 6,
$4.6.1.6, which requires the frequency response range ofthe vibration measuring transducers and their readout system to be from one-third minimum pump shaft rotational speed to at least 1000 Hz, for the Reactor Coolant Charging Pumps 1A, 1B and 1C, and 2A, 2B, and 2C.
Licensee 's Basis For Relief: "The reactor coolant charging pumps operate at approximately 205-210 rpm which equates to a rotational frequency of3.41 Hz. The one-third minimum speed frequency response required for the vibration instrumentation correlates to 1.13 Hz (68 cpm).
The vibration instrumentation presently in use at St. Lucie is the Bentley Nevada model TK-81 with 270 cpm probes.
The TK-81 integrator frequency response is essentially flat down to 120 cpm (cycles per minute) [equal to 2 Hz] where the displayed output ofthe instrument slightly increases to approximately +1dB at 100 cpm. The -3dB frequency response is reached at approximately 54 cpm. The velocity probes used with the TK-81 are a special low frequency probe nominally rated down to 270 cpm (-3 dB). This is only slightly higher than the expected rotational (1X) speed ofthe charging pump (205 - 210 cpm). The 1X (205 cpm) vibration frequency components willbe somewhat attenuated by the probes, but not eliminated. Overall vibration levels would still show an increasing value ifa problem developed whose characteristic frequency was 1X running speed.
There are virtually no mechanical degradation scenarios where only a sub-'synchronous vibration component would develop on the charging pumps. For example:
- 1. Oil whirl (0.38X - 0.48X) is not applicable to a horizontal, triplex, reciprocating pump.
- 2. A light rub/impact could generate 0.5X (102.5 cpm) vibration components, but would also usually generate a sequence ofinteger and half integer running speed components.
A heavy rub generates increased integer values ofmultiple running speed components, as well as processing the 1X phase measurement.
In either case the overall vibration level would still show an increase from both the attenuated sub-synchronous and 1X vibration components as well as the higher harmonic vibration components.
- 3. Looseness in the power train would likely be indicated by increasing 1X and 2X vibration components.
These signals would be slightly attenuated but again not completely eliminated.
Based on the above information, the use ofthe Bentley Nevada 270 cpm probes with the portable TK-81 instrument provides sufficiently reliable data to identify changes from baseline readings to indicate possible problems with the pumps."
Additionally, the licensee in tfieirAugust 22, 1994 response to the open items for the previous Unit 2 IST interval states: "In 1991, St. Lucie purchased the Bentley Nevada model TK-81 vibration instrument with an additional set oflow frequency probes (270 cpm). Atthat time, this instrument was evaluated as the best instrument available for all four requirements.
However, even though this instrument had a low frequency response, it was still not low enough to meet the Code requirements...At the time oftheir purchase, the Bentley Nevada 270 cpm probes with the portable TK-81 instrument had one ofthe lowest frequency responses available.
In the subsequent years followingthe purchase, improvements have been made in lowering the, frequency cutoffofvibration instruments.
However, St. Lucie cannot justify the expense of purchasing new vibration equipment each time some new instrument appears on the market with a lower frequency response.
The amount ofpossible gain provided by new instruments is not justified. The present use ofthe Bentley Nevada 270 cpm probes with the portable TK-81 instrument is capable ofcollecting reliable data to identify changes from baseline readings to indicate possible problems with the pumps..."
Proposed Alternate Testing: During testing ofthese pumps, the vibration instrumentation used willbe the Bentley Nevada model TK-S1 with 270 cpm probes, or equivalent.
Evaluation:
OMa-19S8, Part 6, $4.6.1.6, requires that the frequency response range ofthe vibration measuring transducers and their readout system be from one-third minimum pump speed to at least 1000 Hz. Section XIpreviously required that the frequency response range of the readout system be from one-half minimum speed to at least maximum pump shaft rotational speed (IWP-4520(b)). This change was made by the ASME OM Code Committees in order to more adequately envelop all potential noise contributors that could indicate degradation.
The lower limitofthe range is to allow for detection ofproblems such as bearing oil whirl and looseness ofbearings.
The charging pumps operate at very low speeds (i.e., at 3.48 Hz). The licensee has proposed to use vibration instrumentation with a lower frequency limitof4.5 Hz. This instrumentation cannot measure subharmonic vibration or vibr'ation at the running speed for'the charging pumps.
To identify sources ofnoise and vibration, the peaks ofthe measured frequency spectra are correlated with data pertaining to the possible vibration source components in the machine.
Vibrations at one-third ofrunning speed may indicate "oilwhip" injournal bearings, or looseness in other types ofbearings.
Though the reliefrequest does not describe the type ofbearings in the charging pumps, it does indicate that oil whip is not applicable to this type ofpump. Rotor or seal rub is another type ofproblem found at subharmonic vibration levels. The licensee has stated that rubs may be detected by increases in overall vibration levels. Additionally, loose seals and bearings, bearing and coupling damage, poor shrink fit,torsional critical, and bearing-
support resonance are also indicated in subharmonic levels. Problems such as misalignment, unbalance, loose impeller, bent shaft,,bearings eccentric, case distortion, and shaft out ofround may be detected at pump running speed (Ref. 16). The licensee has addressed looseness in the power train and has stated that although the signal at 1X would be attenuated, it would not be eliminated.
At the time the equipment was purchased, in 1991, the licensee stated that this instrumentation had one ofthe lowest frequency responses available.
Since that time, the licensee has indicated
'that equipment with lower frequency response limits has come available. Itwould be burdensome to require the licensee to purchase new equipment each time more advanced'quipment came available, as the licensee has stated, however, the need to adequately assess the health ofthe pumps is necessary.
The licensee has not provided sufficient information on the hardship or unusual difficultyassociated with complying with the Code, or at least obtaining equipment that could measure to the running speed ofthe pumps. The majority ofpump problems are identified at 60% to 1X running speed, and this is often where the peak vibration levels are found. Numerous utilities have procured and utilize vibration measurement equipment that have frequency response ranges down to 1.'5-2 hz. (e.g., Monticello).
The license has based much ofthe justification on the fact that the sub-synchronous and 1X vibration signal would be measured, although attenuated, and that the overall vibration level
'ould show a relative increase.
The Code requires reciprocating pump vibration to be measured on the bearing housing ofthe crankcase, approximately perpendicular to both the crankcase and the line ofplunger travel. Peak vibration measurements are required to be taken. The Code acceptance criteria for vibration includes both relative limits based on the reference value and absolute limits. The licensee has not proposed compensatory actions, such as adjusting the acceptance criteria for the attenuated signals. Moreover, the frequency spectrum ofcomplex signals generated by machines is characteristic ofeach machine or each pump, constituting a unique pattern, referred to as the "machine signature."
Analysis ofthe signature, as opposed to the peak, allows identification ofvibration sources, and monitoring the change over time permits evaluation ofthe mechanical condition ofthe pump. A commitment to perform spectral analysis and trending, and adjusting the Code acceptance criteria to account for the attenuated signal may provide reasonable assurance ofthe pumps'perational readiness.
In conclusion, it is recommended that long term relief as requested be denied.
The licensee should procure new equipment that meets the Code requirements, or revise and resubmit the reliefrequest to address the specific hardship and how the proposed alternative provides an acceptable level ofsafety.
Immediate compliance would result in a hardship because ofthe time required to procure new instrumentation.
Therefore, it is recommended that the alternate proposed by the licensee be authorized, in a'ccordance with 10CFR50.55a(a)(3)(ii), for an interim period ofone year to allow the'licensee either to procure new equipment that meets the Code requirements or revise and resubmit the reliefrequest.
The proposed testing provides reasonable assurance ofoperational readiness ofthe charging pumps in the interim period because these normally operating pumps are tested quarterly and the majority ofthe modes ofpump
degradation could be detected with existing vibration instrumentation, except for the subharmonic and first harmonic modes.
2.1.3 Relief Request No. PR-08, Hydrazine Pumps ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988, Part 6,
$4.6.1.6, which requires the frequency response range ofthe vibration measuring transducers and their readout system to be from one-third minimum pump shaft rotational speed to at least 1000 Hz, for the Hydrazine Pumps 2A and 2B.
Licensee 's Basis For Relief: "The hydrazine pumps are characterized as metering pumps operating at extremely slow speed (approximately 39 rpm). This equates to a rotational frequency of0.65 Hz. In accordance with the Code, the required low limitofthe frequency response for the vibration instruments would be one third ofthis or 0.21 Hz. Portable instruments satisfying this requirement are commercially unavailable.
The low frequency vibration instrumentation presently in use at St. Lucie is the Bentley Nevada model TK-81 with a 270 cpm probe. The TK-81 integrator frequency response is essentially flat down to 120 cpm (cycles per minute) where the displayed output ofthe instrument slightly increases to approximately+1dB at 100 cpm. The
-3dB frequency response is reached at approximately 54 cpm. The velocity probe used with the TK-81 is a special low frequency probe nominally rated down to 270 cpm (-3 dB). For this reason, vibration readings taken, even with the low frequency probe, are essentially meaningless and ofno value in identifying degradation ofthese pumps.
Furthermore, the classical analysis of rotating components upon which the Code is based is not readily adaptable to slow moving components such as'are installed in these pumps.
These pumps are standby pumps and little degradation is expected with respect to vibration performance between testing periods. The mechanism ofwear and degradation ofrotating machinery are time and cycle dependant and, in this case, the number ofrepetitive wearing actions (cycles) is small both in frequency and absolute numbers.
The pumps cycle approximately 2220 times per hour and operation is typically limited to 1-2 hours per year.
Thus, the probability ofany significant pump deterioration over the plant's lifetime is extremely small. Note that these pumps are designed and built for continuous operation."
Proposed Alternate Testing: The pumps willbe maintained and inspected in accordance with the licensee's Preventative Maintenance Program, which reflects the recommendations ofthe pump's manufacturer.
This includes, at a minimum, periodic changing ofthe crankcase oil and oil analysis to identify significant wearing ofthe internals.
Evaluation:
The containment spray hydrazine pumps operate at very low speeds.
OMa-1988, Part 6 requires that pump vibration be measured with the frequency response range ofthe vibration measuring transducers and their readout system to be from one-third minimum pump speed to at least 1000 Hz. The lower limitofthe range is to allow for detection ofproblems such as bearing oil whirl and looseness ofbearings.
The vibration instrumentation available to the
licensee cannot measure subharmonic or the first to seventh harmonic. The pumps operate at 0.62 Hz and the vibration probe is rated to 4.5 Hz. Based on the lack ofcommercially available vibration instrumentation with an adequate frequency response range low enough to detect pump degradation, it is impractical to comply with the Code requirements.
To require the licensee to replace the pump to allow vibration to be measured would impose a hardship without a compensating increase in the level ofquality and safety.
The licensee has proposed that in lieu ofmeasuring pump vibration, the pumps would be maintained and inspected in accordance with the licensee's preventative maintenance program and has committed to perform, at least, oil analysis. Additionally, the pump willbe run quarterly, with speed and discharge pressure measured, and at refueling outages, flowrate willbe determined in accordance with Relief Request PR-09. An effective preventative maintenance program could be adequate for determining bearing and pump degradation that could impact the pumps'peration readiness.
In designing an effective preventative maintenance program, the licensee, in addition to incorporating manufacturer recommendations, should consider previous maintenance and failure histories for these components, as well as industry data. Industry techniques used for pump diagnostics include, in addition to vibration measurements, measurements oflube oil temperature/pressure, motor amp/current signature, lubricant analysis (properties, small wear particles, chemistry content), bearing temperatures, motor termination temperature and pattern, switch gear temperature and pattern, trending broken rotor bars, and periodic disassembly and inspection. The licensee has not specified in the request, however; the specific inspections and maintenance proposed (other than oil analysis), or their periodicity. The licensee would need to document these, as well as the acceptance criteria and the maintenance/inspection results. This documentation would be subject to NRC inspector review.
In conclusion, it is recommended that relieffrom the Code requirements be granted in accordance with 10CFR50.55a(f)(6)(i), based on the impracticality ofcomplying with the Code vibration measurements requirements given the current commercially available instruments.
The "
preventative maintenance program designed by the licensee must be adequately documented and corrective actions must be taken such that there is reasonable assurance that any degradation mechanism detected willnot cause further degradation such that the pump would fail before the next pump test/maintenance or before repairs can be performed.
Itshould be noted that the licensee implied in the basis that since these pumps are designed and built for continuous operation, and they are only operated periodically, they are not prone to degradation.
However, the periodic use ofthese pumps may result in additional or different failure modes highlighting the importance ofa meaningful preventative maintenance program.
2.2 Relief from Hydraulic Requirements 2.2.1 Relief Request No. PR-02, AuxiliaryFeedwater Pumps ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988, Part 6,
$5.1 and 5.2, which requires flowrate to be determined and compared to its reference value quarterly for the auxiliary feedwater (AFW) pumps 1A, 1B 1C, 2A, 2B, and 2C.
Licensee 's Basis For Relief: "There are only two practical flowpaths available for performing inservice testing ofthe AFW Pumps. These include the primary flowpath from the Condensate Storage Tank (CST) to the main feed supply lines and thence to the steam generators, and the minimum-flowrecirculation (mini-recirc and bypass test loop) which recirculates back to the CST. The former is provided with flowrate measuring instrumentation; however, the mini-recirc line is a fixed resistance circuit with no flowinstrumentation.
Full or substantial flowtesting ofthese pumps'is not practical during plant operation for several reasons. During auxiliary feedwater injection via the main feedwater lines while the plant is operating at power, a large temperature differential (approximately 375 degrees F) could exist between the CST water and the normal steam generator makeup flowstream that would result in a significant thermal shock and fatigue cycling ofthe feedwater piping and steam generator nozzles. In addition, based on the expected duration ofthe testing and the flowrate ofthe pumps (325-600 gpm), it is expected that the cooldown ofthe steam generators would induce cooldown and contraction ofthe reactor coolant system resulting in potential undesirable reactivity variations and power fluctuations. Thus, during quarterly testing ofthe AFW pumps, flowis routed through the minimum flowrecirculation line returning condensate to the Condensate Storage Tank. This recirculation flowpath is capable ofpassing,a flowrate somewhat less than 20 percent ofthat at the pump design operating point. No flowinstrumentation is installed in this recirculation piping and, furthermore, hydraulic pump test data at or near a pump's shutoff head provides little information as to the mechanical condition ofa pump.
These pumps are standby pumps and little degradation is expected with respect to hydraulic performance during plant power operations when the pumps remain idle. Thus, the alternate testing willprovide adequate monitoring ofthese pumps with respect to the applicable Code requirements to ensure continued operability and availability for accident mitigation.
NRC Generic Letter 89-04, Position 9, allows elimination ofminimum flowtest line flowrate measurements providing inservice tests are performed during cold shutdowns or refueling periods under fullor substantial flow'onditions where pump flowrate is recorded and evaluated.
The proposed alternate testing is consistent with this philosophy and the intent ofthis position."
Proposed Alternate Testing: During quarterly testing ofthe AFWpumps, the fixed-resistance mini-flowtest circuit willbe used and pump differential pressure and vibration willbe measured and compared to their respective reference values per $5.2(c). During testing performed at cold "9
shutdown, pump differential pressure, flowrate, and vibration willbe recorded and evaluated per
$5.2(b).
Testing during cold shutdowns willbe on a frequency determined by intervals between shutdowns as follows:
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For cold shutdown periods occurring at intervals of3 months or longer - each shutdown.
~,
For cold shutdown periods occurring at intervals ofless than 3 months - testing is not required unless 3 months have passed since the last cold shutdown test.
Cold shutdown pump and valve testing willnormally commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofentering cold shutdown and continue until testing ofall pumps and valves designated for cold shutdown testing during,the outage is complete or the unit is ready to return to power. For extended outages, testing need not commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided all testing ofcomponents requiring tests is completed prior to startup. If,for any reason, testing is not started within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofachieving cold shutdown, then all components requiring tests willbe tested accordingly. For those cases where pumps can be tested during power ascension and where the Technical Specification requirements for the pumps or system determine when the pump is required to operable, tests may be performed during power ascension without regard to the foregoing. Where plant conditions or other circumstances arise that preclude testing ofa pump and testing ofother pumps or valves is commenced within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofachieving cold shutdown, the unit need not be retained in cold shutdown for the sole purpose ofcompleting testing.
Evaluation:
OMa-1988 Part 6, $5.1 and 5.2 require that pressure, flowrate, and vibration be determined and compared with corresponding reference values on a quarterly basis. In Generic Letter 89-04, Position 9, the staff determined that in cases where flowcan only be established through a non-instrumented minimum flowpath during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test ofthe pump under fullor substantial flowconditions, the increased interval is an acceptable alternative to the Code requirements.
During the deferred test, pump differential pressure, flowrate, and bearing vibration measurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.
For the auxiliary feedwater (AFW) pumps, the licensee states that there are only two practical flowpaths available to perform inservice testing.
One flowpath is the primary flowpath from the Condensate Storage Tank (CST) to the main feedwater supply lines and thence to the steam generators, This flowpath is provided with flowrate measuring instrumentation.
The other flow path is the minimum flowrecirculation lines (mini-recirc and bypass test loop) from the discharge ofeach pump whichjoin together in a common recirculation line back,to the CST.
The minimum flowrecirculation lines are fixed resistance circuits with no flowinstrumentation.
10
It is impractical to perform fullor substantial flowtesting ofthese pumps during plant operation.
During AFW injection via the main feedwater supply lines at power operation, a large temperature differential could cause a significant thermal shock and fatigue cycling ofthe main feedwater piping and steam generator nozzles.
For the quarterly testing ofthe AFW pumps, the licensee proposes to route the pump discharge flowthrough the minimum fiowrecirculation lines which return flowback to the CST. No flow instrumentation is installed on these recirculation flowpaths.
Since these are fixed resistance flowpaths, the pumps'ifferential pressure and vibration willbe measured and compared to their respective reference values as required by Part 6, $5.2(c). During testing at cold shutdown, the fullfiowtest paths to the steam generators willbe used to record and evaluate AFWpump flowrate, differential pressure, and vibration in accordance with Part 6, $5.2(b). The licensee's proposed alternative testing is consistent withNRC Generic Letter 89-04, Position 9.
With respect to the frequency oftesting, the licensee has proposed applying to pumps the requirements in the Code for valves tested on a cold shutdown frequency, i.e., such as is found in Part 10, $4.2.1.2. For intervals between cold shutdowns of3 months or longer, testing willbe performed at each shutdown. For intervals less than 3 months, testing willnot be performed unless 3 months have passed since the. last cold shutdown test.
In addition, cold shutdown pump and valve testing willnormally commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of entering cold shutdown and continue until testing ofall pumps and valves designated for cold shutdown testing during the outage is complete or the unit is ready to return to power. For outages lasting greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the licensee willcomplete all testing ofcomponents requiring tests prior to startup, even though testing is not commenced within48 hours ofentering cold shutdown. Ifthe technical specifications specify when the pumps or system are required to be operable, and the pumps can be tested during power ascension, the tests may be performed during power ascension and therefore not during the cold shutdown phase.
Where plant conditions or other circumstances arise that preclude commencing testing ofthe AFW pumps and testing ofother pumps or valves within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofachieving cold shutdown, the licensee will not necessarily retain the unit in cold shutdown for the sole purpose ofcompleting testing.
The staff, in NUREG-1482, $3.1.1.1, has determined that, for inservice testing ofvalves, plant startup need not be delayed to complete the inservice testing because ifthe licensee were required to complete all cold shutdown testing before restarting the plant, this may impose an unnecessary burden by extending cold shutdown outages solely to complete surveillance testing.
This argument can also be applied to testing ofpumps during cold shutdowns.
Additionally, it should be noted that in the 1994 Addenda ofth'e OM Code, which is included in the current rulemaking without any limitation or modification (Ref. 17), the fullflowtest with vibration, differential pressure and flowrate measured is only required to be performed biennially for standby pumps. No cold shutdown pump testing is required.
Therefore, it is recommended that reliefbe granted in accordance with 10 CFR 50.55a(f)(6)(i), based on the impracticality of performing the testing in accordance with the Code requirements and that the licensee's proposed 11
alternative testing is consistent withNRC Generic Letter 89-04. The licensee should, however, make reasonable efforts in scheduling and performing the tests.
2.2.2 Relief Request No. PR-03, Boric Acid Makeup (BAM)Pumps ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988, Part 6,
$5.1 and 5.2, which requires flowrate to be determined and compared to its reference value quarterly for the boric acid makeup (BAM)pumps 1A and 1B, and 2A and 2B.
Licensee 's Basis For Relief: "There are three available flowpaths for performing inservice testing ofthe BAMpumps. These include the primary flowpath to the charging pump suction header, a recirculation line leading back to the Refueling Water Tank (RWT), and the BAMtank recirculation line. None ofthese flowpaths is acceptable with respect to'Code compliance for the followingreasons:
- 1. Operating the BAMpumps discharging into the charging pump suction header requires the introduction ofhighly concentrated boric acid solution from the boric acid makeup tanks to the suction ofthe charging pumps. This would result in the addition ofexcess boron to the RCS.
This rapid insertion ofnegative reactivity would result in RCS cooldown and de-pressurization.
A large enough boron addition could result in an unscheduled plant trip and a possible safety injection system initiation. During cold shutdown, the. introduction ofexcess quantities ofboric acid into the RCS via this flowpath is undesirable from the aspect ofmaintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent startup due to over-boration ofthe RCS. In addition, the waste management system would be overburdened by the large amounts ofRCS coolant that would require processing to reduce boron concentration.
- 2. The second circuit recirculates water to the Refueling Water Tank (RWT) or the Volume Control Tank (VCT). During normal plant power operation it is undesirable to pump to the RWT and deplete the BAMtank inventory. One ofthe tw'o BAMtanks must be maintained at the Technical Specification level while the other is used as required for plant operation and boron shim. The Tech Spec limits provide only a narrow acceptable band (100-200 gallons), thus even a small reduction in tank inventory would be unacceptable. Also, the operational BAMtank's level typically varies from test to test by as much as 15 to 20 feet. This variance in pump suction pressure willhave a direct effect on pump head and flowsuch that test repeatability would be questionable.
- 3. The BAMtank recirculation flowpath are fixed resistance circuits (one-inch NPS pipe) containing a flowlimitingorifice. There is no flowrate measuring instrumentation installed in these lines. Pumping boric acid from tank to tank could be possible but flowrates would be small restricting pump operation to the high head portion ofthe pump curve. Also, as described above, one ofthe two BAMtanks must be maintained at Technical Specification level and the Technical Specification limits provide only a narrow acceptable band (100-200 gallons), thus a small 12
reduction in tank inventory is unacceptable. The other BAMtank's level willvary from test to test by as much as 15 to 20 feet. Similarly, this variance in pump suction pressure willhave a direct effect on pump head and flowsuch that test repeatability would be questionable.
NRC Generic Letter 89-04, Position 9, allows elimination ofminimum flowtest line flowrate measurements providing inservice tests are performed during cold shutdowns or refueling periods under fullor substantial flowconditions where pump flowrate is recorded and evaluated.
The proposed alternate testing is consistent with this philosophy and the intent ofPosition 9."
Proposed Alternate Testing: During quarterly testing ofthe BAMpumps, the fixed-resistance BAMtank recirculation line willbe used. Pump differential pressure and vibration willbe measured and compared to their respective reference values per $5.2(c). During testing performed at refueling, pump differential pressure, flowrate, and vibration willbe recorded and evaluated per $5.2(b).
Evaluation:
OMa-1988 Part 6, $5.1 and 5.2 require that pressure, flowrate, and vibration be determined and compared with corresponding reference values on a quarterly basis. In Generic Letter 89-04, Position 9, the staff determined that in cases where flowcan only be established through a non-instrumented minimum flowpath during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test ofthe pump under fullor substantial flowconditions, the increased interval is an acceptable alternative to the Code requirements.
During the deferred test, pump differential pressure, flowrate, and bearing vibration measurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.
The BAMpumps normally take suction from the BAMtanks which contain highly concentrated boric acid. The licensee states that there are three available flowpaths to test the BAMpumps.
One is the primary flowpath to the charging pump suction header.
This flowpath contains flow instrumentation.
However, during normal plant operation, it is impractical to pump highly concentrated boric acid solution from the boric acid makeup tanks to the suction ofthe charging pumps since this would result in the addition ofexcess boron to the reactor coolant system.
The rapid insertion ofnegative reactivity would cause RCS cooldown and depressurization.
In sufficient quantities, boron addition could cause a reactor trip and a safety injection actuation.
During cold shutdown, the introduction ofexcess quantities ofboric acid into the RCS through this flowpath could delay plant startup, which is impractical.
The second flowpath takes suction from the BAMtanks and recirculates water from the discharge ofthe BAMpumps to the refueling water tank (RWT) or the volume control tank (VCT). According to flowdiagrams 8770-G-078, Sheet 121A, and 2998-G-078, Sheet 121A, these flowpaths do not contain fiowinstrumentation.
The licensee states that during normal plant operation, one ofthe two BAMtanks must be maintained at the required technical specification level while the other is used as required for plant operation and boron shim. The technical specification limits the variation in the BAMtank levels to only 100 to 200 gallons, so 13
that even a small reduction in tank inventory is unacceptable.
Also, the level ofthe BAMtank which is in operation typically varies from test to test by as much as 15 to 20 feet. This variance in pump suction pressure willhave a direct effect on pump head and flowsuch that test repeatability would be questionable.
Therefore, using this test configuration to perform pump testing is impractical to perform quarterly or at cold shutdowns.
The third flowpath is the BAMpump discharge recirculation flowpath back to the BAMtank for each ofthe two trains. The licensee states that the BAMtank recirculation flowpaths are fixed resistance circuits (one-inch NPS pipe) containing a flowlimitingorifice. Referring to fiowdiagram 2998-G-078, Sheet 121B, it appears that the recirculation flowpaths are two-inch lines g-2-CH-561 and I-2-CH-942) which reduce down to one-inch pipe only at the interfaces with the control valves, V2650 and V2651, on each path. There do not appear to be any flow orifices. However, there is no flowrate instrumentation installed in these lines.
The licensee proposes to measure BAMpump differential pressure and vibration quarterly through the fixed-resistance BAMtank recirculation lines. The differential pressure and vibration willbe measured and compared to their respective reference values per Part 6, $5.2(c).
During testing performed at refueling, the primary flowpath to the charging pump suction header willbe used to record and evaluate BAMpump differential pressure, flowrate, and vibration per Part 6, $5.2(b).
The licensee's proposed alternative testing is consistent withNRC Generic Letter 89-04, Position
- 9. Generic Letter 89-04 authorizes the alternative testing delineated in Positions 1, 2, 6, 7, 9 and 10 pursuant to 10CFR50:55a (g, now f) (6)(i). However, based on subsequent NRC guidance provided in Ref. 11, Question Group 105, which states that the installation ofinstrumentation is not considered impractical, it is recommended that the proposed alternative be authorized in accordance with 10 CFR 50.55a(a)(3)(i).
2.2.3 Relief Request No. PR-04, Containment Spray (CS) Pumps ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988, Part 6, tt5.1 and 5.2, which requires flowrate to be determined and compared to its reference value quarterly for the containment spray (CS) pumps 1A and 1B, and 2A and 2B.
Licensee 's Basis For Relief: "There are two practical flowpaths available for performing inservice testing ofthe containment spray pumps. These include one that directs borated water from the RWT to the RCS via the low-pressure injection header. The other is minimum flow recirculation (mini-recirc and bypass test loop) which recirculates to the Refueling Water Tank (RWT).
The first would require modifying the shutdown cooling lineup while in cold shutdown; however, even then the shutdown cooling system cannot provide sufficient letdown flowto the RWT to accommodate full design flowfrom the RWT while maintaining the necessary core 14
cooling function. Thus, the only practical opportunity for testing these pumps via this flowpath is during refueling outages when water from the RWT is used to fillthe refueling cavity.
The minimum-flowrecirculation flowpath is a fixed resistance circuit containing a flowlimiting orifice with no flowrate measuring instrumentation installed. Furthermore, hydraulic pump test data at or near a pump's shuto'ff hea provides little information as to the mechanical condition of a pump.
These pumps are standby pumps that remain idle during most plant operation except for testing periods, thus, service-related degradation with 'respect to hydraulic performance between testing periods is unlikely. Consequently, the alternate testing willprovide adequate monitoring ofthese pumps with respect to the applicable Code requirements to ensure continued operability and availability for accident mitigation.
NRC Generic Letter 89-04, Position 9, allows elimination ofminimum flowtest line flowrate measurements providing inservice tests are performed during cold shutdowns or refueling under fullor substantial flowconditions where pump flowrate is recorded and evaluated. The proposed alternate testing is consistent with this philosophy and the intent ofthis position."
Proposed Alternate Testing: During quarterly testing ofthe containment spray pumps, the fixed-resistance mini-flowtest circuit willbe used and pump differential pressure and vibration willbe measured and compared to their respective reference values per $5.2(c). During testing performed during reactor refueling, pump differential pressure, flowrate, and vibration willbe recorded and evaluated per Part 6, $5.2(b).
Evaluation:
OMa-1988 Part 6, $5.1 and 5.2 require that pressure, flowrate, and vibration be determined and compared with corresponding reference values on a quarterly basis. In Generic Letter 89-04, Position 9, the staff determined that in cases where flowcan only be established through a non-instrumented minimum flowpath during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test ofthe pump under fullor substantial flowconditions, the increased interval is an acceptable alternative to the Code requirements.
During the deferred test, pump differential pressure, flowrate, and bearing vibration measurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.
The licensee states that there are two flowpaths for inservice testing ofthe containment spray pumps. In one flowpath, borated water from the refueling water tank (RWT) is injected into the reactor coolant system (RCS) via the low-pressure injection header.
Since during normal plant operation, the reactor coolant system pressure exceeds the shutoff head ofthe containment spray pumps, this flowpath could only be used during cold shutdown by modifying the shutdown cooling lineup. The licensee states that even ifthe lineup is modified, it is impractical to use this flowpath since the shutdown cooling system cannot provide sufficient letdown flowto the RWT 15
to accommodate full design flowfrom the RWT while maintaining the shutdown core cooling function.
The other flowpath is a minimum flowrecirculation and bypass test loop which recirculates water from the containment spray pump discharge to the RWT. This flowpath is a fixed resistance circuit containing a flowlimitingorifice with no flowrate measuring instrumentation installed.
For quarterly testing ofthe containment spray pumps, the licensee proposes to route the pump discharge flowthrough the minimum fiowrecirculation line back to the RWT. Since these are fixed resistance flowpaths, with no flowrate instrumentation installed, the pumps'ifferential pressure and vibration willbe measured and compared to their respective reference values as required by Part 6, $5.2(c). During refueling outages, the flowpath through which borated water from the refueling water tank (RWT) is injected into the reactor coolant system (RCS) via the low-pressure injection header willbe used to measure containment spray pump flowrate, pump differential pressure and vibration. Pump flowrate, differential pressure, and vibration willbe measured and compared to their respective reference values as required by OM 6, $5.2(b).
The licensee's proposed alternative testing is consistent withNRC Generic Letter 89-04, Position 9, and it is recommended that the alternative be authorized in accordance with 10 CFR 50.55a(a)(3)(i).
2.2.4 Relief Request No. PR-05, High Pressure Safety Injection (HPSI) Pumps ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988, Part 6,
$5.1 and 5.2, which requires flowrate to be determined and compared to its reference value quarterly for the high pressure safety injection (HPSI) pumps 1A and 1B, and 2A and 2B.
Licensee 's Basis For Relief: "During quarterly testing ofthe HPSI pumps, the pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) pressure and allow flowthrough the safety injection headers. Thus, during quarterly testing ofthe HPSI pumps, flowis routed through a minimum flowrecirculation line returning boric acid solution to the refueling water tanks. The minimum-flowrecirculation flowpath is a fixed resistance circuit containing a flowlimitingorifice capable ofpassing a flowrate somewhat less than 10 percent of that at the pump design operating point with no flowrate measuring instrumentation installed.
Note that hydraulic pump test data at or near a pump's shutoff head provides little information as to the mechanical condition ofa pump.
During cold shutdown conditions, fullflowoperation ofthe HPSI pumps to the RCS is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the Technical Specifications (LTOP).
16
These pumps are standby pumps and little degradation is expected with respect to hydraulic performance during operational periods when the pumps are idle. Thus, the alternate testing will provide adequate monitoring ofthese pumps with respect to the applicable Code requirements to ensure continued operability and availability for accident mitigation.
'K NRC Generic Letter 89-04, Position 9, allows elimination ofminimum flowtest line flowrate measurements provided that inservice tests are performed during cold shutdowns or refueling periods under full or substantial flowconditions where pump flowrate is recorded and evaluated.
The proposed alternate testing is consistent with this philosophy and the intent ofthis position."
Proposed Alternate Testing: During quarterly testing ofthe HPSI pumps, the fixed-resistance (mini-flow)test circuit willbe used and pump differential pressure and vibration willbe measured, Pump differential pressure and vibration measurements willbe compared to their respective reference values per $5.2(c). During testing performed during reactor refueling, pump differential pressure, flowrate, and vibration willbe recorded and evaluated per Part 6, $5.2(b).
Evaluation:
OMa-1988 Part 6, $5.1 and 5.2 require that pressure, flowrate, and vibration be determined and compared with corresponding reference values on a quarterly basis. In Generic Letter 89-04, Position 9, the staff determined that in cases where flowcan only be established through a non-instrumented minimum flowpath during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test ofthe pump under fullor substantial flowconditions, the increased interval is an acceptable alternative to the Code requirements.
During the deferred test, pump differential pressure, flowrate, and bearing vibration measurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.
The HPSI pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) pressure and'allow flowthrough the safety injection headers.
'Therefore, quarterly testing during normal plant operation through these flowpaths is impractical.
It is impractical to cause fullflowoperation ofthe HPSI pumps to the RCS during cold shutdowns.
RCS pressure transients could result in exceeding the pressure-temperature limits specified in the technical specifications for low temperature overpressure (LTOP).
For quarterly testing, HPSI pump flowis routed through a minimum flowrecirculation line returning boric acid solution to the refueling water tanks (RWT). The minimum flow recirculation flowpath is a fixed resistance circuit containing a flowlimitingdevice capable of passing a flowrate somewhat less than 10 percent ofthat at the pump design operating point.
Pump differential pressure and vibration measurements willbe measured and compared to their respective reference values in accordance with Part 6, $5.2(c). During refueling outages, HPSI pump differential pressure, flowrate, and vibration willbe recorded and evaluated in accordance with Part 6, $5.2(b).
17
The licensee's proposed alternative testing is consistent with NRC Generic Letter 89-04, Position 9, and it is recommended that the alternative be authorized in accordance with 10 CFR 50.55a(a)(3)(i).
2.2.5 Relief Request No. PR-06, Low Pressure Safety Injection (LPSI) Pumps ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988, Part 6,
$5.1 and 5.2, which requires fiowrate to be determined and compared to its reference value quarterly for the low pressure safety injection (LPSI) pumps 1A and 1B, and 2A and 2B.
Licensee 's Basis For Relief: "During quarterly testing ofthe LPSI pumps, the pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) pressure and allow flowthrough the safety injection headers. Thus, during quarterly testing ofthe LPSI pumps, flowis routed through a minimum flow'recirculation line returning boric acid solution to the refueling water tanks. The minimum-flowrecirculation flowpath is a fixed resistance circuit containing a flowlimitingorifice capable ofpassing a flowrate somewhat less than 10 percent of that at the pump design operating point with no flowrate measuring instrumentation installed.'ote that hydraulic pump test data at or near a pump's shutoff head provides little information as to the mechanical condition ofa pump.
Except for briefperiods when these pumps are used for shutdown cooling, they are standby punips and little degradation is expected with respect to hydraulic performance during operational periods when the pumps remain idle. Thus, the alternate testing willprovide adequate monitoring ofthese pumps with respect to the applicable Code requirements to ensure continued operability and availability for accident mitigation.
NRC Generic Letter 89-04, Position 9, allows elimination ofminimum fiowtest line flowrate measurements providing inservice tests are performed during cold shutdowns or refueling under fullor substantial flowconditions where pump flowrate is recorded and evaluated. The proposed alternate testing is consistent with this philosophy and the intent ofthis position."
Proposed Alternate Testing: During quarterly testing ofthe LPSI pumps, the fixed-resistance mini-flowtest circuit willbe used and pump differential pressure and vibration willbe measured.
Pump differential pressure and vibration measurements taken during this testing willbe compared to their respective reference values per Part 6, $5.2(c).
During testing performed at cold shutdown and refueling, pump differential pressure, fiowrate, and vibration willbe recorded and evaluated per Part 6, $5.2(b).
Testing during cold shutdowns willbe on a frequency determined by intervals between shutdowns as follows:
For cold shutdown periods occurring at intervals of3 months or longer - each shutdown.
18
~
'or cold.shutdown periods occurring at intervals ofless than 3 months - testing is not required unless 3 months have passed since the last cold shutdown test.
Cold shutdown pump and valve testing willnormally commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofentering cold shutdown and continue until testing ofall pumps and valves designated for cold shutdown testing during the outage is complete or the unit is ready to return to power. For extended outages, testing need not commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided all testing ofcomponents requiring tests is completed prior to startup. If, for any reason, testing is not started within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofachieving cold shutdown, then all components requiring tests willbe tested accordingly. For those cases where pumps can be tested during power ascension and where the Technical Specification requirements for the pumps or system determine when the pump is required to be operable, tests may be performed during power ascension without regard to the foregoing. Where plant conditions or other circumstances arise that preclude testing ofa pump and testing ofother pumps or valves is commenced within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofachieving cold shutdown, the unit need not be retained in cold shutdown for the sole purpose ofcompleting testing.
Evaluation:
OMa-1988 Part 6, $5.1 and 5.2 require that pressure, flowrate, and vibration be determined and compared with corresponding reference values on a quarterly basis. In Generic Letter 89-04, Position 9, the staff determined that in cases where flowcan only be established through a non-instrumented minimum flowpath during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test ofthe pump under fullor substantial flowconditions, t;'.e increased interval is an acceptable alternative to the Code requirements.
During the deferred test, pump differential pressure, flowrate, and bearing vibration measurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.
The LPSI pumps cannot develop sufficient discharge pressure to overcome reactor coolant system (RCS) operating pressure and allow flowthrough the safety injection headers.
Therefore, quarterly testing during normal plant operation through these flowpaths is impractical.
During quarterly testing ofthe LPSI pumps, flowis routed through a minimum flowrecirculation line returning boric acid solution to the refueling water tank (RWT). The minimum flow recirculation flowpath is a fixed resistance circuit containing a flowlimitingorifice capable of passing a flowrate somewhat less than 10 percent ofthat at the pump design operating point with no flowrate measuring instrumentation installed. LPSI.pump differential pressure and vibration measurements willbe measured and compared to their respective reference values in accordance with Part 6, $5.2(c).
During testing performed at cold shutdown and refueling, LPSI pump flow is directed to the RCS. Pump flowrate, differential pressure, and vibration willbe measured and compared to reference values in accordance with Part 6, $5.2(b). The licensee's proposed alternative testing is consistent with NRC Generic Letter 89-04, Position 9.
19
With respect to the frequency oftesting, the licensee has proposed applying to pumps the requirements in the Code for valves tested on a cold shutdown frequency, i.e., such as is found in Part 10, $4.2.1.2. For intervals between cold shutdowns of3 months or longer, testing willbe performed at each shutdown. For intervals less than 3 months, testing willnot be performed unless 3 months have passed since the last cold shutdown test.
In addition, cold shutdown pump and valve testing willnormally commence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of entering cold shutdown and continue until testing ofall pumps and valves designated for cold shutdown testing during the outage is complete or the unit is ready to return to power. For outages lasting greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the licensee willcomplete all testing ofcomponents requiring tests prior to startup, even though testing is not commenced within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofentering cold shutdown. Ifthe technical specifications specify when the pumps or system are required to be operable, and the pumps can be tested during power ascension, the tests may be performed during power ascension and therefore not during the cold shutdown phase.
Where plant conditions or other circumstances arise that preclude commencing testing ofthe LPSI pumps and testing ofother pumps or valves within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofachieving cold shutdown, the licensee will not necessarily retain the unit in cold shutdown for the sole purpose ofcompleting testing.
The staff, in NUREG-1482, $3.1.1.1, has determined that, for inservice testing ofvalves, plant startup need not be delayed to complete the inservice testing because ifthe licensee were required to complete all cold shutdown testing before restarting the plant, this may impose an unnecessary burden by extend'ng cold shutdown outages solely to complete surveillance testing.
This argument can also be applied to testing ofpumps during cold shutdowns.
Additionally, it should be noted that in the 1994 Addenda ofthe OM code, which is included in the current rulemaking without any limitation or modification, the full flowtest with vibration, differential pressure, and flowrate measured is only required to be performed biennially for standby pumps.
No cold shutdown pump testing is required.
Therefore, it is recommended that reliefbe granted in accordance with 10 CFR 50.55a(f)(6)(i),
based on the impracticality ofperforming the testing in accordance with the Code requirements and that the licensee's proposed alternative testing is consistent with NRC Generic Letter 89-04.
However, the licensee should make reasonable efforts in scheduling and performing the tests.
2.2.6 Relief Request No. PR-09, Hydrazine Pumps ReliefRequest:. The licensee has requested relieffrom the requirements ofOMa-1988, Part 6,
$5.1 and 5.2, which requires flowrate to be determined and compared to its reference value quarterly for the hydrazine pumps 2A and 2B.
Licensee 's Basis For Relief: "The hydrazine pumps are reciprocating positive displacement pumps with variable speed control. They are classified as metering pumps and are designed to accurately displace a predetermined volume ofliquid in a specific period oftime. The pump has 20
a single plunger and makes only one suction and one discharge stroke during each cycle (shaft rotation).
The pumps operate at a very slow speed (as low as 37 cpm) to supply the technical specification required hydrazine flowrate of,0.71 to 0.82 gpm. Due to this simplified design ofthese pumps, instantaneous flowis continuously accelerating and decelerating - followingan oscillating waveform. Each cycle ofthe pump is approximately 1.6 seconds in duration with no flow produced during the pumps 0.8 second suction stroke. The installed flowrate instrumentation utilizes a differential pressure orifice located in the suction line common to both pumps.
Due to the characteristic oscillating flowrate, flowthrough this orifice pulsates sharply with each pump stroke resulting in erratic flowrate readings.
The floworifice also senses pressure feedback during each jump stroke cycle as a result ofechoes ofthe pressure pulsation produced by the pump stroke which are reflected back to the flowelement by the system piping and valves. The characteristic oscillating flowrate also makes it impractical to dampen using standard dampening devices.
These flowcharacteristics and the design limitation ofthe installed flow instrumentation make it impractical and inadequate for inservice testing purposes.
Previous testing has demonstrated that techniques for determining flowrate by averaging the indicated flowrate readings are inconsistent and inaccurate when compared to actual flow. For this reason, trending the flowrate using the installed instrumentation is impractical due to the inherent inaccuracies and instability in measuring the pump fiowas described above.
These pumps are standby pumps that remain idle during most plant operation except for testing periods, thus, service-related degradation with respect to hydraulic performance between testing periods is unlikely. Consequently, the alternate testing willprovide adequate monitoring ofthese pumps with respect to the applicable Code requirements to ensure continued operability and availability for accident mitigation, The flowrates ofthe pumps can be determined by collecting the pumps'utput in a container of known volume over a measured period oftime and thereby calculating the flowrate. A correlation between pump speed and average flowrate has been developed and.confirmed based on piston displacement.
Although not physically impractical, frequent performance ofthe above described flowtesting is undesirable based on the personnel hazards associated with testing. Hydrazine is a hazardous, highly flammable liquid with cumulative toxic effects when absorbed through the skin, inhaled or ingested. It has also been identified as a known carcinogen. For this reason, it is proposed to perform this testing only during refueling outages. Measuring flowrate as described above during each refueling outage is appropriate and adequate for detecting any significant pump degradation and ensuring the continued operability and reliabilityofthese pumps.
Note that this alternate testing plan is consistent with the intent ofthat provided in Generic Letter 89-04, Position 9."
21
Proposed Alternate Testing per the Request:
During the quarterly pump tests, each pump will be operated at nominal rated speed and pump discharge pressure, speed, and vibration willbe measured.
During each refueling outage at least one test willbe performed for each pump measuring actual pump flowrate to verify proper performance. Pump discharge pressure, speed, and vibration will also be measured.
Evaluation:
OMa-1988 Part 6, $5.1 and 5.2 require that pressure, flowrate, and vibration be determined and compared with corresponding reference values on a quarterly basis. In Generic Letter 89-04, Position 9, the staff determined that in cases where flowcan only be established through a non-instrumented minimum flowpath during quarterly pump testing and a path exists at cold shutdowns or refueling outages to perform a test ofthe pump under fullor substantial flowconditions, the increased interval is an acceptable alternative to the Code requirements.
During the deferred test, pump differential pressure, flowrate, and bearing vibration measurements must be taken and during the quarterly testing at least pump differential pressure and vibration must be measured.
The hydrazine pumps have installed instrumentation, however based on the oscillating flowrate ofthese positive displacement reciprocating pumps, the flowrate measurements are erratic. The licensee states that this oscillating flowrate makes it impractical to dampen using standard dampening devices.
Therefore, it is impractical to use the installed flow instrumentation for inservice testing purposes.
Compliance with the Code would require a major piping modification or pump replacement which is burdensome.
The licensee measures flowrate by collecting the pumps'utput in a container ofknown volume over a measured period oftime and calculating the flowrate.
Since hydrazine is a hazardous, highly flammable, carcinogenic liquid, the licensee proposes to perform this flowrate testing only during refueling outages.
During the quarterly pump tests, the licensee proposes in the request to measure pump discharge
- pressure, speed, and vibration with each pump operated at nominal rated speed.
During each refueling outage, at least one test willbe performed for each pump and the actual pump fiowrate willbe measured as described above.
The request states that pump discharge pressure, speed, and vibration willalso be measured.
Relief Request PR-08, concerning relieffor these pumps from the Code vibration requirements, has been revised subsequent to the issuance ofthis request.
Request PR-08 no longer proposes that vibration be measured, therefore the proposed alternate in this request is no longer consistent with the alternate discussed in Generic Letter 89-.
04, Position 9. Additionally, the licensee's Procedure ADM-29.01, Table 1 Unit 2 Pump Table, indicates that the licensee willnot measure the pump differential pressure and references this reliefrequest.
OMa-1988, Part 6, Table 3b, requires that pump discharge pressure be measured for positive displacement pumps.
22
Testing using the installed instrumentation is impractical, as is physically collecting the hydrazine quarterly or at cold shutdowns.
Assuming that the licensee is measuring pump discharge pressure quarterly and during each refueling outage, as stated in the Alternate Testing section ofthis reliefrequest, and considering the Preventative Maintenance Program committed to in reliefrequest PR-08, the increased test interval for the measurement offlowrate provides reasonable assurance ofthe pumps'perational readiness.
Therefore, it is recommended that reliefbe granted in accordance with 10 CFR 50.55a(f)(6)(i), based on the impracticality of performing the testing in accordance with the Code requirements.
The licensee should revise Table I-Unit2 Pump Table to properly indicate that pump discharge pressure is being measured quarterly and during refueling outages, and revise this request to be consistent with the new PR-08.
2.3 Relief from Corrective Action Requirements 2.3.1 Relief Request No. PR-II, Use ofAnalysis in Lieu ofCorrective Action ReliefRequest: The licensee has requested generic relieffrom the requirements ofOMa-1988, Part 6, $6.1, which requires ifdeviations fall within the alert range ofTable 3, the frequency of testing specified in $5.1, be doubled until the cause ofthe deviation is determined and the condition corrected. Ifdeviations fall within the required action range ofTable 3, the pump is required to be declared inoperable until the cause ofthe deviation has been determined and the condition corrected.
Licensee 's Basis For Relief: "The 1995 Edition ofASME OM-Code provides an alternate concept ofcorrective action should a pump's performance enter the action required range.
Specifically, paragraph ISTB 6.2.2 permits an analysis ofthe pump and establishment ofnew reference values. This can avoid premature maintenance ofa pump that is subject to expected continual and gradual deterioration over time while operating at a level where it is fullycapable ofreliably performing its designated safety function.
By using the test requirements ofthe 1995 Code edition, St. Lucie plant can reduce the frequency ofunnecessary pump maintenance with essentially no adverse effect on plant safety since it can be assumed that the new Code requirements are equivalent to (or better than) the 1988 addenda.
In addition, by expanding this capability to pumps that are in the alert range, frequent and unnecessary testing can be avoided. Note that, in most cases, more frequent testing ofpumps is itself a degrading mechanism.
This also is required to avoid unnecessary plant shutdown for pumps that are tested at cold shutdown should a pump enter the alert range during such testing."
Proposed Alternate Testing: In cases where a pump's test parameters fall within either the alert or required action range and the pump's continued use at the changed values is supported by an analysis, a new set ofreference values may be established.
The accompanying analysis will 23
include verification ofthe pump's operational readiness and an evaluation oftest data that verifies that the subject pump is not expected to fall below the minimum required performance level in the periods between testing. The analysis willinclude both pump and system level operational readiness evaluations, description ofthe cause ofthe change in pump performance, and an evaluation ofall trends indicated by the available test and maintenance data. The results ofthis analysis willbe documented in the record oftests.
Evaluation:
OMa-1988, Part 6, $6.1, "Acceptance Criteria," specifies actions required to be taken ifany ofthe measured pump parameters fall within the alert or required action ranges.
For test results in the alert range, the test frequency is required to be doubled until the cause ofthe deviation is determined and the condition is corrected.
For test results in the required action range, the pump shall be declared inoperable until.the cause ofthe deviation has been determined and the condition corrected.
In ASME OM Code-1995, which is not currently referenced in 10 CFR 50.55a, but is included in the current rulemaking without modification or limitation, ISTB 4.6, "New Reference Values,"
allows that "[i]ncases where the pump's test parameters are either within the alert or required action ranges ofISTB 5.2.1.1, Table ISTB 5.2.1-2, Table ISTB 5.2.2-1, or Table ISTB 5.2.3-1, and the pump's continued use at the changed values is supported by an analysis, a new set of reference values may be established." This paragraph clarifies that, ifa pump can be shown to be capable ofperforming its safety function, itmay be returned to service with adjusted reference values. This reflects that there are pumps that have a significant margin over the sa."ty requirements that might degrade from their initialperformance, but still are capable ofmeeting their safety function.'umps which do not have margin would not be returned to service without repair or replacement.
Paragraph ISTB 4.6 also states that the analysis shall include both a pump level and a system level verification ofpump operational, readiness, the cause ofthe change in pump performance, and an evaluation ofall trends indicated by available data.
Paragraph ISTB 6.2.1, which provides acceptance criteria for the alert range, does not currently allow an analysis for pumps,.unlike ISTB 6.2.2, for pumps in the required action range, which does explicitlystate that an analysis may be performed and directly references ISTB 4.6.
The ASME code committees are considering a change to ISTB 6.2.1 to include the option ofan analysis and to reference ISTB 4.6. This proposal also states that for vibration in the alert range, the engineering evaluation shall include a comparison ofthe current vibration spectrum with the baseline spectrum (i.e., one developed when the pump was operating acceptably), an evaluation ofthe trend ofavailable overall vibration amplitudes and spectra, and a determination ofthe need for corrective action (ASME Action Item ROM 98-05). This proposal has not been approved by the ASME consensus committee at this time and is subject to change.
In NRC Generic Letter 91-18 (Ref. 18), which concerns resolution ofdegraded and nonconforming conditions and operability, $6.11, "Technical Specification Operability vs.
ASME Code, Section XIOperative Criteria," the NRC indicates that in cases where the required action range limitis more conservative than its corresponding technical specification limit,the 24
0 corrective action may not be limited to replacement or repair. The corrective action may consist ofan analysis to demonstrate that the specific pump performance degradation does not impair operability and that the pump or valve willstill fulfillits function, such as delivering the required flow. A new required action range may be established after such an analysis which would then allow a new determination ofoperability. Approval has been authorized by the NRC to allow licensees to use the OM Code-1995, $6.2.2 for pumps in the required action range because licensees are already allowed to perform an analysis in accordance with Generic Letter 91-18.
With regards to pumps operating in the alert range, Generic Letter 91-18 does not address this situation, only that in which pumps are operating in the required action range. However, when pumps are in the alert range, the Code simply requires decreasing the test interval &om quarterly to twice quarterly, allowing possible degradation to the required action range where an analysis is allowed. No evaluation ofthe cause ofthe degradation or trending is required. By performing a detailed engineering analysis when the pump enters the alert range an acceptable level of quality and safety would be achieved.
The analysis should at least include a comparison ofthe current measurements for the particular parameter, i.e., flowrate, vibration, discharge pressure or differential pressure, to the baseline measurements, an evaluation ofthe trend ofavailable data for the parameter, and a determination ofthe cause and the need for corrective action. Alternate available methods, such as vibration spectral analysis, are expected to be used to support the analysis. Any analysis performed is subject to NRC inspection and must provide reasonable assurance that the degradation mechanism willnot cause further degradation such that, before the next pump test or before repairs can be performed, the pump would fail. Additionally,it should be noted that changes to the vibration reference values would affect only the vibration relative alert and required action limits, and not the absolute limits specified by the Code. Ifthe absolute limits are exceeded (i.e.,
0.325 ips or 10,5 mils for the alert range and 0.7 ips or 22 mils for the required action range), the licensee would be required to increase the test frequency or declare the pump inoperable in accordance with the Code.
=
The use ofthis analysis is expected to be a rare occurrence.
This analysis should be used cautiously, as it is not intended to be used regularly to evaluate the operability ofall pumps that fall into the alert or required action range in order to declare the pump operable and define new reference values where significant degradation has occurred.
Repeated application ofanalysis could lead to stair stepping the Code alert and required action range limits downward to the safety limits ofthe pump. The licensee should have an understanding ofthe margin ofeach pump above its design-basis requirements.
Therefore, given the licensee willperform an analysis in accordance with gSTB 4.6 ofthe 1995 OM Code, it is recommended that the licensee's proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i), based on the acceptable level ofquality and safety that willbe provided by the proposed alternative for both the alert'and required action range.
25
2.3.2 Relief Request No. PR-12, LPSI Pumps ReliefRequest: The licensee has requested relief&om the requirements ofOMa-1988, Part 6,
$6.1, which requires ifdeviations fall within the alert range ofTable 3, the frequency oftesting specified in $ 5.1 be doubled until the cause ofthe deviation is determined and the condition corrected, for the Unit 1 low pressure safety injection (LPSI) pumps during the quarterly test run through the mini-recirculation line.
0 Licensee 's Basis For Relief:
"These pumps are tested quarterly under minimum flowconditions (less than 2 percent ofnominal flow)using the minimum flowrecirculation piping and, during each refueling, at nominal design fiowrate. Note, the flowrate experienced during quarterly testing is considerably less than that expected during accident or normal operational conditions.
During the process ofestablishing new reference values for the quarterly tests related to implementation ofthe OM Code, it was discovered that the reference values for vibration for these pumps are near or exceed the absolute alert level of0.325 in/sec. Set forth in Table 3.
Using the IRD Model 810 w/Model 970 Accelerometer Probe, the vibration levels at the pump bearings range between 0,28 and 0.38 in/sec.
Because ofthis, these pumps willperpetually remain in "alert" since when operating at low flowat least one ofthese readings typically exceeds the alert limitestablished by Table 3 (0.325 in/sec). During the cold shutdown testing (substantial flow), vibration measurements are expected to be acceptable and well below the absolute alert limits ofTable 3.
Due to the inherent design ofthe pumps, at low flows increased levels ofvibration are induced as a consequence ofenergy dissipation and internal recirculation.
Spectral analyses and pump vibration signatures confirm that the increased levels ofvibration experienced at low flows are in the frequency range offive times rotational frequency, and thus, are a function ofimpeller design. In addition, there are significant levels ofbroad band vibration that is attributable to hydraulic instability. For this reason, it is clear that the increased vibration levels observed during low flow.operation are, for the most part, unrelated to pump condition (degradation);
-- -- =
0 ASME OM Code-1995 and later revisions allow the classification ofpumps into two groups, A and B, where the Group B pumps are those used for standby service, ofwhich these pumps qualify. Recognizing that pump degradation that would manifest itselfin increased vibration levels are not expected while a pump is in a standby mode, the code committee discontinued the requirement for quarterly vibration monitoring. This also reflects the growing concern of regulators and the members ofthe code committee that extended operation ofpumps under minimum flowconditions has a deleterious effect on pump components. Thus it is apparent that vibration monitoring in this case is insignificant and certainly does not warrant any increased frequency oftesting as required by the Code.
The proposed alternate testing is adequate and appropriate, and is capable ofproperly monitoring pump operability as intended by the Code. It should be noted that more frequent testing ofthese 26
pumps under minimum flowconditions for no justifiable reason does not add to plant safety and could have a significant negative impact on pump and system operability and reliability."
Additionally, the licensee in their October 9, 1998 letter (Ref. 19) provided this supporting information:
P "As discussed in NUREGICP-0152, Code Absolute Vibration Requirements, there are four key components that the staQ'considers in evaluating alternative requests:
- 1) vibration history, 2) consultation with pump manufacturer or vibration expert, 3) attempts to lower the vibration through modification, and 4) performance ofspectral analysis ofthe pump-driver system.
V~ib i
Hi These pumps are included in the plant "condition monitoring" program, therefore, several years ofspectral analysis by the plant predictive maintenance group test results were available for review. From the spectral patterns it can be seen that, at minimum flowconditions, both pumps generate increased vibration levels. At low flow, vibration velocity levels at five and ten times running speed frequencies (SX/10X) are significantly increased due to elevated vane pass vibration since the velocity vector is not striking the volute at an optimal angle. The increased vibration at the 2X frequency is a result ofan abnormal pressure distribution in the volute that acts to load the impeller asymmetrically. Also contributing [to] the overall vibration increase is hydraulic broadband "spectral floor" energy generated by shock energy due to increased turbulence and internal recirculation flow.
Note that an anomaly occurred on April21, 1997, when relatively high vibration was experienced by the 1B LPSI pump at the 1X frequency in the horizontal direction. Based on a review ofthe data, it was determined that this resulted from a structural condition related to operation at elevated temperature.
The most likely cause was postulated to be piping and support system stiffness and natural frequency changes resulting from elevated temperatures.
Subsequent runs under similar conditions at non-elevated temperatures resulted in lower vibration.
~E*
Oil The spectral vibration data ofthese pumps was collected by plant predictive maintenance personnel experienced and trained in the performance monitoring ofpumps and other rotating equipment.
The spectral data along with the historical pump displacement and velocity data obtained to comply with IST'requirements has been reviewed and evaluated by our onsite equipment vibration specialist. In addition, operation ofthe pump in low flowconditions has been discussed with the original equipment manufacturer.
The FPL predictive maintenance
- -"- "-- vibration specialist's conclusion based on the historical data, spectral analysis, and hands on data gathering, is that there is no evidence ofpump deterioration or mechanical anomalies detrimental to pump performance and that the LPSI pumps are operating satisfactorily.
27
. ~
Corrective Action As discussed above, the pump vibration history data has been reviewed to ensure that no maintenance related anomalies were evident that could be corrected to improve performance.
The pump-piping configuration was also reviewed, however, changes to the pump/piping arrangement, including modification ofpump internals and installation ofa fullflowtest recirculation line, would be costly and generally impractical. Based on the data, the unacceptable levels ofvibration experienced during low flowconditions are a result offlownoise and pump dynamics that are not a function ofpump degradation.
The elevated levels ofvibration are not evident at design fiows, and therefore do not detract &om pump availability or reliabilityat design flows. Also, the LPSI pumps meet the ASME vibration criteria during outage conditions (substantial flowconditions). Accordingly, the need for [a] substantial plant modification to install fullflowrecirculation lines for quarterly surveillance is considered impractical.
AAAIAA I i
The results derived from spectral analysis are provided [as an attachment to the October 9, 1998 letter]."
Proposed Alternate Testing: In conjunction with the quarterly testing ofthese pumps, vibration data willbe recorded per OM Code, Paragraphs 4.6.4 and 5.2. Test results willbe evaluated, and the acceptance criteria ofTable 3 applied with the exception that the minimum allowable vibration level defining the alert range willbe 0.500 inches/second (ips). Should measured vibration exceed 0.500 ips or 2.5V the subject pump willbe placed in "alert" status and the frequency oftesting doubled until the cause ofthe deviation is determined and the condition corrected.
Should measured vibration exceed 0.700 ips or 6V the subject pump willbe declared inoperable until the cause ofthe deviation is determined and the condition corrected.
When these pumps are tested at substantial flowconditions (plant shutdown), the vibration acceptance criteria as shown in Table 3 willbe applied unconditionally.-
Evaluation:
OMa-1988, Part 6, $6.1, "Acceptance Criteria," specifies actions required to be taken ifany ofthe measured pump parameters fall within the alert or required action ranges.
For test results in the alert range, the test &equency is required to be doubled until the cause ofthe deviation is determined and the condition is corrected.
For test results in the required action range, the pump shall be declared inoperable until the cause ofthe deviation has been determined and the condition corrected. In Part 6, there are both absolute and relative vibration limits. In previous editions and addenda ofSection XI,the vibration limits were based on additives or multipliers to the reference value established when the pump was known to be operating acceptably. No absolute limitsexisted.
As discussed in Mr. J. Colaccino's paper "Nuclear Power Plant Safety Related Pump Issues" in NUREG/CP-0152 (Ref. 20), when updating to the 1989 Edition ofSection XI,pumps that were previously acceptable per the earlier Code, may now exceed the absolute'limits, as is the case with the Unit 1 LPSI pumps at St, Lucie. Mr. Colaccino's paper provided guidance on four 28
elements that are necessary when requesting relief, i.e., the request should contain the pump's vibration history, a determination by the pump manufacturer or vibration expert that pump operation at the higher level ofvibration is acceptable, results ofattempts to reduce the vibration levels through modifications, and results ofspectral analysis.
The licensee has addressed each of these elements.
The vibration spectral history &om August 1995 to March 1998 for each pump at five locations was reviewed by the licensee and the data was provided as an attachment to FP&L's October 9, 1998 letter. Data was taken on eleven occasions.
Additionally, the licensee's vibration specialist reviewed the Code historic velocity and displacement data (which was not provided to the reviewer), as well as the spectral analysis and determined that the pumps are operating acceptably.
Other than the anomaly noted by the licensee on April27, 1997, the data appears consistent over the period the data was taken with no degrading trends. The licensee's analysis indicates that the cause ofthe increased vibration is operation at less than 2%
nominal fiow, and that it does not represent pump mechanical degradation.
This analysis is consistent with the data, as the peaks are only reached during minimum flowoperation. As discussed by the licensee, in order to reduce these vibration levels, installation ofa full-flowtest loop would be required, which is impractical.
The licensee has requested relief&om only the alert range absolute vibration limits forthe quarterly tests when the pump is operated using the mini-recirculation line. The licensee has proposed to expand the limitfrom 0.325 ips to 0.50 ips. During this quarterly test, the Code's alert range relative limits, and required action absolute (i.e., 0.70 ips) and relative limits willbe complied with, Additionally, during the shutdown tests, with the pump operated at substantial flow, the Code's vibration limits willbe used.
Compliance with the Code requirements would require either a major pump or system modification which would be impractical, or having the pumps perpetually in the alert range, possibly resulting in accelerated pump wear and degradation due to increased operation in a reduced flowlineup. Decreasing the test interval for a pump that is in good operating condition would be a hardship to the licensee without a compensating increase in the level ofquality and safety. Increasing the absolute alert limitto 0.50 ips should be adequate to detect degradation that requires monitoring through the use ofincreased test frequencies.
The proposed alternate provides reasonable assurance ofthe pumps'perational readiness considering that the licensee has determined that operation ofthe pump at the higher vibration levels during the quarterly test is acceptable, that the higher vibration does not represent pump degradation given the historical data, that the spectral analysis has not indicated pump degradation, and finally,that the Code required action limitswillbe complied with quarterly, and that during the shutdown substantial flowtest, all the Code vibration limitswillbe complied with. Therefore, it is recommended that alternate be authorized in accordance with 10CFR50.55a(a)(3)(ii).
~ ~ ~
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PA ~'
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29
3.0 VALVEIST PROGRAM RELIEF REQUESTS In accordance with $50.55a, Florida Power &Light has submitted 18 valve relief'requests for specific and generic valves at St. Lucie Plant Unit 1 and 2 that are subject to inservice testing under the requirements ofASME Section XI. These reliefrequests have been reviewed to verify their technical basis and determine their acceptability. The reliefrequests are summarized below, along with the technical evaluation by BNL. In addition, the IST Program includes two valve reliefrequests (VR-13,and 18) for information only that address non-ASME Code Class valves.
Relief Requests VR-08 and 09 were deleted per the licensee's September 21, 1998 submittal (Ref. 3). No evaluation ofthese requests was performed.
3.1 Relief Valves 3.1.1 Relief Request No. VR-01, Temperature Stability ReliefRequest:
The licensee requests generic relieffrom the requirements ofthe OM-1987, Part 1, $8.1.3.4 which requires that the test method be such that the temperature ofthe valve body be known and stabilized before commencing set pressure testing, with no change in measured temperature ofmore than 10 degree-F in 30 minutes.
Proposed Alternate Testing: The licensee has proposed not to perform verification ofthermal equilibrium for valves that are tested at ambient conditions using a test medium at ambient conditions. The valve body temperature willbe measured and recorded prior to each series of tests (which may consist ofmultiple liAs).
Licensee's Basis for Relief:
"For valves tested under normal prevailing ambient (shop) conditions with the test medium at approximately the same temperature, the requirement for verifying temperature stability is inappropriate.and ofno value. Thereis littleor.no consequence ofminor variations in ambient temperature.
This has been identified by the OM-1 Code Working Group and the ASME Code Committees and is reflected in the latest version ofthe Code (OM Code-1996) paragraphs I 8.1.2(d) and I 8.1.3(d)."
Evaluation: As discussed inNUIT-1482, Section 4.3.9, the clarification provided in the 1994 Addenda to the 1990 OM Code concerning the requirement for thermal equilibrium for valves tested at ambient temperature using a test medium at ambient temperature, may be used without NRC approval; reliefis not required. The 1996 Code, as referenced by the licensee, contains the same wording ing 8.1.2(d) and I 8.1.3(d), as the 1994 Addenda. Although reliefis not required, the licensee should, however, continue to reference the use ofthis position (i,e., NUREG-1482, Section 4.3.9) in the IST Program.
30
3.1.2 Relief Request No. VR-02, Alternate Ambient Temperature ReliefRequest:
The licensee requests generic relieffrom the requirements ofthe OM-1987, Part 1, $8.1.1.5, 8.1.2.5 and 8.1.3.5, which require safety and reliefvalves to be tested with the ambient temperature ofthe operating environment simulated during the test. Alternate ambient temperatures may be used provided the requirements of$8,3 are met.
Proposed Alternate Testing: The licensee has proposed to test these valves "in accordance with Part 1 with the exception that where temperature correlations and correction factors are appropriate, the manufacturer's published correction factors willbe used. The results ofthe tests performed to verify the adequacy ofthe alternate media correlation may not be documented,"
Licensee's Basis for Relief:
"The pertinent valve manufacturers have stated that test results supporting their published temperature correlation guidance is not available.
There are no testing facilities at the St. Lucie plant site that are capable ofperforming the tests necessary for developing correlation data for each valve installed at the St. Lucie plant and development ofsuch a facilitywould be an unreasonable burden on the plant staff Since, in the case ofClass 2 and 3 non-steam service valves, the temperature differences are not large (typically 200-250 deg-F), the temperature correlation data provided by the manufacturers is considered to be adequate. Note also that, for these systems and temperatures, the margin of safety from the safety/relief valve setpoint to the pressure retaining capability ofthe system components is considerably greater than the potential error associated with the manufactures published correction factors."
Evaluation:
The licensee has requested generic relieffor valves that are "tested under ambient conditions using a test medium at ambient conditions," OM-1987, Part 1, $8.1.1.5, 8.1,2.5 and 8.1.3;5; require the ambient temperature ofthe operating environment surrounding the valve at its installed plant location during the phase ofplant operation for which the device is required for overpressure protection be simulated during the set pressure test. Alternate ambient temperatures may be used, but the requirements of$8.3.2 and 8.3.3 must be met. Part 1, $8.1.1.1 require steam valves to be tested with steam.
Alternate compressible'fluids may be used provided the requirements of$8.3 are met. $8.1.2.1 and 8.1.3.1 require valves to be tested with their normal system operating fluidand temperature for which they are designed.
Alternate media may be used, provided the requirements of$8.3 are met. Part 1, $8.3 requires the establishment ofa correlation and certification ofthe correlation procedure.
The certification requires actual test data. Itwould appear that the licensee is requesting relief&om $8.1.1.1, 8.1.2.1 and 8.1.3.1, as well as'$8.1:1.5, 8.1.2.5 and 8.1.3.5 identified in the request.
<<"~am~Aa'.%ts~c" p
This issue has been subject ofa recent Code in'terpretation that was published with the 1998 addenda (Interpretation 98-9). The code committee determined that the requirements of ANSI/ASMEOM-1987 Part 1 $4.3 (or 8.3), Alternate Test Media, are not met ifthe cold 31
differential test pressure, as marked on the nameplate provided by the manufacturer, is used as an alternate test pressure as permitted by $4.1 (or 8.1), and no other qualification exists.
Additionally, the committee clarified that the requirements ofANSI/ASMEOM-1987 Part 1 $4.3 (or 8.3), Alternate Test Media, are met ifthe documentation required by $4.3.2 (8.3.2) and the written p'rocedure required by $4,3.3 (8.3.3) are prepared by the valve manufacturer and accepted/certified by the Owner.
The licensee's basis for requesting reliefis that the manufacturers test results supporting their published correlation criteria is not available. However, without certification and documentation ofthe correlation procedure including specific requirements for instrumentation, assist equipment (ifany), test operating conditions, test parameters and a description ofthe test setup, and the tests required to support the correlation; the correlation previously performed may not be valid.
t The NRC has provided some guidance on this issue in their minutes to the 1997 IST workshops (Ref. 15) and in J. Colaccino's paper, "General Inservice Testing Issues," in NUREG/CP-0152, Volume 2 (Ref. 21). As discussed in the reply to Question 2.4.7 in the workshop minutes, ifthe licensee does not have a correlation performed in accordance with the Code, the licensee should contact the valve vendor to determine ifa correlation is available. As discussed in the basis, the licensee has contacted the vendor and the correlation is unavailable.
As an alternative, the response suggests that the licensee develop the correlation or evaluate sending valves to a test lab in order to comply with the Code. The basis states that the licensee is unable to perform the testing, however, it does not discuss the option ofusing an outside test lab to develop the correlation. Ifthe licensee has determined that testing in accordance with the Code is impracticable, the licensee should revise the reliefrequest to include, as a minimum, a discussion ofthe safety significance ofthe valves, the test and design process and ambient temperatures, the valve specific margin ofsafety, discussions with the valve vendor, and why the valve cannot be bench tested at design conditions or why a correlation cannot be developed by the licensee or outside test lab. Generic relief&om these requirements would not be appropriate.
In conclusion, reliefcannot be recommended.
The licensee should comply with the Code requirements or resubmit the request providing specific information discussed above for each valve.
3.1.3 Relief Request No. VR-03, Test Accumulators ReliefRequest:
The licensee requests generic relieffrom the requirements ofthe OM-1987, Part 1, $8.1.2.2 which requires that a minimum accumulator volume be used for set pressure testing various safety and reliefvalves used for compressible fluidservice, other than steam, and specifies the formula to calculate this minimum volume for Class 2 and 3 valves.
32
Proposed Alternate Testing:
The licensee has proposed to use the requirements in the 1996 Addenda ofthe OM Code, g 8.1.2(b) which requires the volume ofthe accumulator drum and the pressure source flowrate be sufficient to determine the valve set pressure.
Licensee's Basis forRelief:
The accumulator volume requirement is not required for simple determination ofthe valve set pressure. This was recognized by the Code Committee and corrected in more recent versions ofthe OM Code."
Evaluation:
OM-1987, Part 1, $8.1.2.2 requires the set point test accumulator have a minimum volume equal to the valve capacity (cubic feet/second) multiplied by the time open (seconds),
divided by 10. Unlike ASME Section III,the OM Code and Part 1 do not require the verification ofvalve capacity, only the set pressure.
Based on an interpretation submitted to the ASME OM Committee concerning the requirements ofPart 1, the committee reviewed the requirements of
$8.1.2.2 and its basis.
The Code Committee considered the requirements to be overly conservative and unnecessarily prescriptive. The Code was revised in the 1994 Addenda (OMc) to delete the prescriptive requirements and to require that the volume and the pressure source flowrate be sufficient to determine the valve set-pressure, This change in the 1994 Addenda is also contained in the 1996 Addenda, as requested by the licensee.
Although, not currently referenced in 10CFR50.55a(b), the 1996 OM Code is part ofthe current rule change.
The NRC has not imposed any limitations or modifications regarding Appendix I. Compliance with the Part 1 requirements would require a calculation for each valve and possibly requiring resizing the accumulator drum. The use ofthe OM Code, 1996 Addenda, +8.1.2(b) provides an acceptable means ofperforming set pressure tests.
There are no related requirements.
Therefore, it is recommended that the licensee's alternative be authorized in accordance with 10CFR50.55a(a)(3)(i).
3.1A Relief Request No. VR-19, Containment Vacuum Breakers ReliefRequest: The licensee has requested relieffrom the requirements ofOM-1987 Part 1,'=-
'Ill.3.4.3, which requires within every 6 month period, operability tests ofprimary containment vacuum reliefvalves be performed unless historical data indicates a requirement for more frequent testing. Additionally, leak tests shall be performed every 2 years unless historical data indicates a requirement for more &equent testing. This request applies to containment vacuum breakers V-25-20 and 21 ~
Licensee 's Basis for Relief: "These check valves are tested in such a way that immediate access to each valve is required.
Since these valves are located inside the primary containment building, routine access during power operation is considered to be impractical. Thus ope'rational testing
. can only be performed during cold shutdown conditions.-
r Leakrate testing ofthese valves is performed in accordance with the St. Lucie Containment Leakage Rate Testing Program (Technical Specification, Paragraph 6.8.4 h,). This Program allows extension ofleakrate testing beyond the 2-year interval based on 10 CFR 50 Appendix J, 33
,Option B. There is no overriding justification nor engineering issue that demands more frequent testing than that required by Appendix J and the St. Lucie Containment Leakrate Testing Program."
Proposed Alternate Testing: "Each ofthese valves willbe subjected to an operability test (opene'd and closed) during plant cold shutdown periods.
Testing during cold shutdowns willbe on a &equency determined by intervals between shutdowns as follows:
For cold shutdown periods occurring at intervals of6 months or longer - each
'hutdown.'or cold shutdown periods occurring at intervals ofless than 6 months testing is not required unless 6 months have passed since the last cold shutdown test.
P. alp Cold shutdown testing ofpumps and valves willcommence within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ofentering cold shutdown and 'continue until testing ofall pumps and valves designated for cold shutdown testing during the outage is complete or the unit is ready to return to power.'or extended outages, testing need not be commenced within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> provided all required testing is completed prior to startup. Ifpump and valve testing is not begun within the 48-hour period then both ofthese valves willbe tested prior to startup.
Where plant conditions or other circumstances arise that preclude testing ofa valve, a unit willnot be retained in Mode 3 for the sole purpose of completing testing.
Leakrate testing willbe performed on a schedule as set forth in the St. Lucie Containment Isolation Valve Leakrate Testing Program."
I Evaluation: These valves open as required to limitcontainment internal vacuum and close for containment isolation. Although the licensee refers to these valves as check valves, valves that are capacity certified, as are most containment vacuum reliefvalves, are required to be tested in accordance with OM-1987 Part 1. OM-1987, Part 1, $1.3.4.3, requires within every 6 month period, operability tests ofprimary containment vacuum reliefvalves be performed unless historical data indicates a requirement for more frequent testing. Additionally, leak tests shall be performed every 2 years unless historical data indicates a requirement for more frequent testing.
l'he ASME Code Committee recently approved an action to revise paragraph I 1.3.7 (b) ofthe OM Code to clarify that leak test frequency is in accordance with Table 1 ( i.e., leakage test requirements for Category A valves are in accordance with$4.2.2)(ROM 97-10). Paragraph 4.2.2 requires containment isolation valves to be tested in accordance with Appendix J. No additional leak tests are required,'ince these valves are not reactor coolant system pre'ssure isolation valves, nor have a leakage requirement based on other functions. There are no other '
"=--
related requirements.
This change willbe included in the 1999 Addenda ofthe OM Code. The guidance in NUREG-1482, Section 4.3.9, states that the use ofcode clarifications may be used without further NRC approval ifthey are determined to be clarifications only and are 34
documented in the IST program. Therefore, the proposal to test in accordance with Appendix J is acceptable.
The licensee should continue to document the use ofthis clarification in the IST Program.
The OM Code was also revise'd, iiiOMc-1994, to require the primary containment vacuum relief valve operability tests at each RFO or every 2 years whichever is sooner, unless historic data requires more frequent testing. Although NUREG-1482, Section 4.3.9, allows the use ofcode clarifications without relief, this is a technical change which requires NRC approval to use. The 1994 Addenda has not yet been referenced for use in the regulations, i.e., 10CFR50.55a(b).
The current Code requires an operability test within every six months.
The licensee states that it is impractical to test these valves during power operation based on their location inside
~
containment and the need for local access.
There is not sufficient information to support the basis ofimpracticality. The licensee should provide additional information on why entering the containment and gaining local access to the valves is impractical and resubmit the request.
3.1.5 Relief Request No. VR-20, Sodium Hydroxide and Hydrazine Storage Tanks' Vacuum Breakers ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.1, which requires safety and reliefvalves to meet the inservice test requirements ofPart 1,'or the sodium hydroxide and hydrazine storage tanks'acuum breakers, V07231 and V07232.
Licensee 's Basis for Relief: "These are standard check valves use to displace the liquid volume in the associated tank with air as the tank contents are pumped to the associated system.
In so doing, they ensure the tanks'ontents can be removed by the pumps and provide vacuum relief protection thus protecting the tank from collapse due to a reversed differential pressure on the shell.
The design ofthe valves is such that the normal operation ofthe seat moving from the disc causes air to enter the tank. The simplicity ofthe design does not allow for adjustment ofthe differential pressure needed for valve opening.
The context ofPart 1 is directed toward testing conventional pressure reliefdevices and not simple check valves, and therefore the requirements set forth therein are not applicable to testing ofsimple check valves.
The functional requirement ofa vacuum breaker is only relevant in the open direction. The closure characteristics including seat leakage are irrelevant so long as the valve remains closed under operating conditions to satisfy operational concerns.
Thus, there is no concern related to premature opening or seat leakage (e.g., inventory loss).
The proposed alternative testing willensure that these valves are fullyoperational with respect to their capability ofperforming their safety functions."
35
Proposed Alternate Testing:
Each ofthese valves willbe exercised quarterly per Part 10, $4.3.2.
During this quarterly testing the valve discs willbe verified to move from the seat below a maximum differential pressure related to the function ofthe valves to protect the tank integrity and to provide vacuum relieffor system operation. No additional testing per Part 1 willbe performed.
Evaluation: OMa-1988 Part 10, Table 1 identifies two subcategories for Category C (i.e.,
Category C (safety and relief) and Category C (check)). Note 2 ofthat table states that "When more than one distinguishing category characteristic is applicable all requirements ofeach ofthe individual categories are applicable although duplication or repetition ofcommon testing is not necessary." Simple check valves that serve an "overpressure protection" function (e.g., some vacuum reliefvalves) could be categorized as both Category C (safety and relief) and Category C (check), and therefore would be required to be tested in accordance with Part 10, 4.3.1 (which references Part 1) and 4.3.2. This issue is discussed in NUREG-1482, Section 4.3.8. As discussed in the 1997 NRC IST Workshop Meeting Minutes (Ref. 15), the code committees are considering a proposal to clarify that these valves are not required to be tested in accordance with both the check valve and reliefvalve requirements.
In this proposal: ifthe check valve is a capacity certified valve, then it shall be classified as a pressure or vacuum reliefdevice and tested in accordance with Appendix I; ifthe check valve is not a capacity certified valve, it shall be classified as a check valve and tested in accordance with ISTC. This proposal is currently under consideration and has not been approved by the Code committees (ROM 96-18). However, use ofthis clarification is acceptable as stated in Question 2.4.11 ofthe IST Workshop Minutes (Ref.
15).
The licensee has stated that the subject valves are "simple" check valves. Provided that they are not capacity certified in accordance with Section IIIor the construction code, as discussed above, use ofthe clarification provided in the code committee's proposal is acceptable and reliefis not required. The licensee should continue to document this approach in the IST program.
3.1.6 Relief Request No. VR-22, CVCS Regenerative Heat Exchanger Thermal Relief Valve
, ReliefRequest:
The licensee requests relieffrom the requirements ofthe OM-1987, Part 1 for the CVCS regenerative heat exchanger thermal reliefvalve, V2435.
Proposed Alternate Testing:
The licensee has proposed to exercise the valve quarterly to demonstrate that the valve willopen with a differential pressure not to exceed 500 psig.
Licensee 's Basis For Relief: "These are spring-loaded check valves, that are designed to open with a differential pressure of250 psid while the "liAing"differential needed to protect the charging injection piping is 500 psid. The opening set point (differential pressure) ofthese valves is a function ofthe valve design and construction, and is not readily adjustable, thus they 36
are not considered true reliefvalves even though they serve that purpose.
Furthermore, they are welded in place in the system and cannot be removed for bench testing.
Performing the inspections and leakage testing, as described in Part 1, is not practical while the valves remain installed in the system, Also, since these valves are not adjustable and accessible, the liftpressur'e cannot be accurately verified or set per Part 1 - only functional adequacy can be confirmed. The proposed functional adequacy test willprovide assurance the valves will satisfactory perform their intended function."
Evaluation: OMa-1988 Part 10, Table 1 identifies two subcategories for Category C (i.e.,
Category C (safety and relief) and Category C (check)). Note 2 ofthat table states that "When more than one distinguishing category characteristic is applicable all requirements ofeach ofthe individual categories are applicable although duplication or repetition ofcommon testing is not necessary." Simple check valves that serve an."overpressure protection" function (e.g., some vacuum reliefvalves) could be categorized as both Category C (safety and relief) and Category C (check), and therefore would be required to be tested in accordance with Part 10, 4.3.1 (which references Part 1) and 4.3.2. This issue is discussed in NUREG-1482, Section 4.3.8. As discussed in the 1997 NRC IST Workshop Meeting Minutes (Ref. 15), the code committees are considering a proposal to clarify that these valves are not required to be tested in accordance with both the check valve and reliefvalve requirements.
In this proposal: ifthe check valve is a capacity certified valve, then it shall be classified as a pressure or vacuum reliefdevice and tested in accordance with Appendix I; ifthe check valve is not a capacity certified valve, it shall be classified as a check valve and tested in accordance with ISTC. This proposal is currently under consideration and has not been approved by the Code committees (ROM 96-18). However, use ofthis clarification is acceptable as stated in Question 2.1.11 ofthe IST Workshop Minutes (Ref.
15)..
Per a October 6, 1998 teleconference with the licensee, these check valves are not "capacity certified," therefore, exercising the valves quarterly is in compliance with the Code requirements for check valves, and relief is not required. The licensee should continue to document this approach in the IST Program.
3.2 Safety Injection System 3.2.1 Relief Request No. VR-04, PIV Test Frequency ReliefRequest: The licensee has requested relieffrom OMa-1988 Part 10, $4.3.2 which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5. Valves full-stroke exercised at shutdowns shall be exercised during each shutdown, except as specified in $4.3.2.2(g). Such exercise is not required ifthe time period since the previous full-stroke exercise is less than 3 months. This request applies to the followingsafety injection pressure isolation valves (PIVs) in the closed direction:
37
Unit 1: V3113, V3123, V3133, V3143 (HPSI Header), V3114, V3124, V3134, V3144 (LPSI Header), V3215, V3225, V3235, V3245 (SIT Discharge), V3217, V3227, V3237, V3247 (SIT and LPSI Discharge).
Unit 2: V3215, V3225, V3235, V3245 (SIT discharge), V3217, V3227, V3237, V3247 (SIT and LPSI Discharge), V3258, V3259, V3260, V3261 (LPSI Header), V3524, V3525, V3526, V3527 (HPSI to hot leg).
Licensee 's Basis For Relief:
These are simple check valves with no external means of exercising nor for determining disc position, thus the only practical means ofverifying closure is by performing a leakage or backflow test.
Performing backflow or leakage tests ofthese valves typically involves a considerable effort with the test connections and valves required for the test alignment in radiation areas with inconvenient access provisions.
Allassociated lines connected to the reactor coolant system are provided with high pressure alarms that would alert operation's personnel to any significant failure ofthe inboard valves that could endanger low pressure systems.
Leak testing to verify the closure capability ofthese valves is primarily for the purpose of confirming their capability ofpreventing over-pressurization and catastrophic failure ofthe safety injection piping and components. In this regard, The St. Lucie Technical Specification 4.4.6.2 addresses the valve test frequency in the manner appropriate for these valves. Performing the leak testing as prescribed in the Technical Specifications is adequate to ensure proper and reliable operation ofthese valves.
Note that, in Unit 1, SIT Outlet Check Valves V3215, V3225, V3235, and V3245 are not
'pecifically listed in the Technical Specifications as pressure isolation valves; however, as a result ofa plant commitment, they are treated as pressure isolation valves with administrative testing requirements equivalent to those ofthe Technical Specifications."
Proposed Alternate Testing: "The closure capability ofthese check valves shall be demonstrated per the applicable Technical Specification by verifying leakage to be within its limits during cold shutdown outages only when any ofthe followingconditions are met:
- 1. At least once per 18 months (Unit 2 only).
- 2. Prior to entering MODE 2 after refueling (Unit 1 only).
- 3. Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 7 days or more and ifleakage testing has not been performed in the previous 9 months.
38
- 4. Prior to returning the valve to service followingmaintenance, repair or replacement work on the valve.
- 5. Following valve actuation due to flowthrough a valve (Unit 2 only).".
1 Evaluation:
The Code requires check valves to be exercised to the position(s) in which the valves perform their safety function(s). These check valves open to provide a flowpath from the safety injection tanks, LPSI, and HPSI headers to the RCS, and close to isolate the systems from the high pressure ofthe reactor coolant system.
These valves are partially exercised open at cold shutdown and full-stroke exercised at refueling, except for the LPSI discharge check valves, which are full-stroke exercised at cold shutdowns.
With respect to exercising the valve closed, verification that a valve is in the closed position can be done by visual observation, by an electrical signal initiated by a position-indicating device, by observation ofappropriate pressure indication in the system, by leak testing, or by other positive means.
These are simple check valves which are not provided with instrumentation, and the only means oftesting these valves closed is by leak testing, Backflow leakage testing is performed under the licensee's program for Pressure Isolation Valves, as described above.
The valves are all exercised with flowat cold shutdowns (either partial-or full-stroke exercised), except for the Unit 1 HPSI header check valves that are exercised open only when the SITs are filled per RFJ-8.
Per the Technical Specifications, the Unit 2 valves willall be verified closed at every, cold shutdown, following the partial-or full-stroke exercise.
The Unit 1 valves willbe verified closed only during some cold shutdowns, subject to the technical specifications.
As discussed in NUREG-1482, Section 4.1.4, ifno other practical means is available, it is acceptable to verify that check valves are capable ofclosing by performing leak-rate testing at each refueling outage.
The NRC has determined that the need to set up test equipment is adequate justification to defer testing. The licensee has determined that it is impractical to test these valves quarterly or during every cold shutdown because the valves and test connections are located inside containment.
Access to testing presents a personnel safety hazard due to high radiation levels. Leak testing the Unit 1 valves during every cold shutdown would be burdensome to the licensee due to the extensive test setup, which would require substantial man-hours and the potential for extending the shutdown.
OMa-1988 Part 10, $4.3.2.2 allows full-stroke exercising that is not practicable during operation or cold shutdown to be deferred to refueling outages.
Accordingly, testing the Unit 1 valves" during some cold shutdowns and Unit 2 valves every cold shutdown, in accordance with the Technical Specifications, is allowed by the Code and reliefis not required. This could be described in a cold shutdown justification.
39
3.2.2 Relief Request No. VR-05, PIV Test Frequency ReliefRequest: The license has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2 which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2,2, 4.3.2.3, 4.3.2.4, and 4.3.2.5 for the safety injection tanks (SITs) to the reactor coolant system (RCS) pressure isolation valves, V3215, V3225, V3235, and V3245 in the open direction.
Licensee 's Basis For Relief: "These are simple check valves with no external means of exercising or for determining disc position. Consequently, the only practical method for stroke testing ofthe SIT discharge check valves is to discharge the contents ofthe SIT's to the RCS.
Performing a fullflowtest ofthe SIT discharge check valves'during any plant operating mode is impractical because the maximum flowrates attained by discharging the contents ofthe SIT's to the RCS can not meet the valves'aximum required accident condition flowrate as required by Generic Letter 89-04, Position 1. The maximum flowrate achievable during a SIT discharge test is restricted by the long stroke time ofthe SIT discharge isolation valves motor-operated valves with a nominal stroke time of52 seconds and limitations on SIT pressure during testing. Under large break LOCA accident conditions, the maximum (peak) flowrate through these valves would be approximately 20,000 gpm. as compared to typical test values ofapproximately 8,000 gpm.
Although the flowrate attained during these SIT discharge tests does not qualify as "full'flow",it is sufficient to fullystroke the check valve discs to their fullyopen position and verification of this is possible using non-intrusive testing techniques.
Due to system configuration, however, full-stroke exercising ofthe SIT discharge check valves cannot be performed in any plant operating mode other than refueling when the reactor vessel head is removed.
The SIT discharge check valves are identical with respect to size and design and they are installed in essentially identical orientations exposed to the similar operating conditions. Each has been disassembled and inspected several times during previous refueling outages.
Additionally, FP8cL has reviewed the operating and maintenance history ofsimilar valves used throughout the industry under comparable conditions.
Based on these reviews and inspections, there has been no evidence ofvalve degradation with respect to their ability to open and satisfactorily pass the required flowneeded to fulfilltheir safety function. This along with the observation that the SIT flowrate and pressure drop traces obtained during the 1994 refueling outage testing are nearly identical, indicate that this baseline data was taken when each valve was in good working condition.
Since these valves are subjected to other testing and inspection requirements (other than flow testing) and related maintenance, there may be, from time to time, reason to disassemble a valve that is also scheduled for non-intrusive testing, At such times there is no added gain in performing a flowtest prior to the disassembly since the disassembly and visual inspection is adequate and in some respects superior to non-intrusive testing to confirm valve operability.
40
I Thus, the additional cost and radiation exposure associated with performing the redundant non-intrusive testing cannot be justified. Note also that Generic Letter 89-04, OM-Code, Part 10, Paragraph 4.3.2.4(c), and NUREG-1482 state that disassembly and inspection is equivalent to and an acceptable alternative to flowtesting.
Partial-stroke (open) ofthese valves requires discharging from the SIT's to either the reactor coolant system (RCS) or the SIT drain header and RWT. Flow directed to the reactor coolant system during normal plant operation is impossible since the pressure in the SIT cannot overcome RCS pressure to establish flow. Verification offlowvia the drain line to the RWT requires opening two manual containment isolation valves for Unit 1 and an outside manual containment isolation valve and an inside solenoid-operated'containment isolation valve for Unit
- 2. In both cases the potential risk ofthe loss ofcontainment integrity in the event ofan accident due to single active failure or dependence on operator action makes this unacceptable and impractical (Reference NUREG-1482, Paragraph 3.1.1):
In addition to flowtesting, each valve is confirmed to be closed under cold shutdown conditions and is subjected to periodic leakage tests. Note that, for this type ofvalve, the leakage testing is especially sensitive to internal valve degradation."
Proposed Alternate Testing:
Each SIT discharge check valve willbe partial-stroke exercised at cold shutdown and full-stroked in the open direction during refueling outage by discharging all four SIT's to the reactor vessel.
During each refueling outage, under a sampling program on a rotating schedule, at least one ofthe check valves, willbe non-intrusively tested to verify its disc fullystrokes to its backstop, or ifscheduled for disassembly for another reason (e.g., preventative maintenance) disassembled, inspected, and manually stroked to verify operability.
Should a valve under testing or inspection be found to be inoperable and incapable ofperforming its function to open, then the remaining three valves willbe inspected or non-intrusively tested during the same outage, after which the rotational inspection schedule willbe reinitiated.
Following any valve reassembly, forward flowoperation ofthe valves (partial stroke open test) willbe observed.
Each SIT discharge check valve willbe verified closed and leakrate tested in accordance with Relief Request No. VR-O4.
Evaluation:
OMa-1988 Part 10, $4.3.2 requires check valves to be exercised quarterly. Iffull-stroke exercising during plant operation or cold shutdowns is impractical, it may be limited to full-stroke during refueling outages.
The licensee has discussed why full-stroke exercising during power operation or cold shutdowns is impractical because in order to achieve the flowrates necessary to fully-open the valve, the reactor head must be removed. Additionally, partial-stroke exercising using the SIT to RCS line is impractical because the system pressure is insufficient to overcome the RCS pressure.
The 41
licensee states that partial-stroke exercising using the SIT drain header is impractical during operation due to the need to manually open SIT drain header containment isolation valves, that operator action is required to isolate the containment penetration, and given the potential risk of the loss ofcontainment makes testing impractical. The standard technical specifications allow normally locked closed containment isolation valves to be opened intermittently under administrative controls.
Based on a review ofthe P&IDand SAR Table 6.2-52, it appears that penetration 41 in Unit 2 has two solenoid operated valves located inside containment that automatically close on a containment isolation signal, therefore the containment risk argument does not appear valid. However, as discussed in Relief Request VR-04, ifthese Unit 2 pressure isolation valves were exercised open, a leak test would be required by the Technical Specifications, which would be impractical to perform quarterly. Additionally, the Unit 1 pressure isolation valves have the potential not to reseat followingthe partial-flow test, creating the potential for equipment damage due to overpressurization.
Therefore, partial-stroke exercising during operation is impractical. Relief is not required in order to defer full-stroke exercising to refueling outages and partial-stroke exercising to cold shutdowns based on the impracticality ofperforming the test at power operation and cold shutdowns.
The NRC's position is that check valves should be tested with flow,ifpractical (See discussion in Ref. 15, Question 2.3.23). As discussed in NUREG-1482, Appendix A, Question Groups 11 and 15, disassembly and inspection is an option only where fullstroke exercising cannot practically be performed by flowor by other positive means, and is not considered an equivalent method.
The ASME Code committees clarified in the OM Code, OMc-1994 Addenda that disassembly can be used only ifexercising with flowor a mechanical exerciser is impractical.
The licensee has proposed using non-intrusive testing (NIT). Relief is not required because this test method is considered an acceptable "other positive means," in accordance with Part 10,
$4.3.2.4(a).
The NITmust be repeatable and qualified, as discussed in Generic Letter 89-04, Position 1. As discussed in NUREG-1482, Section 4.1.2, check valves may be tested using NIT on a sampling basis, without relief. Allthe valves are exercised with less than the accident flow rate, and non-intrusives may be used to verify that the system pressures and flowconditions specified in the test procedures cause the check valves to fullystroke. A sample plan is allowed since ifthe system conditions are repeatable, each valve would be typically stroked.
The use of non-intrusives on at least one valve each outage is required for reverifying the test method and test conditions (including flow)have not changed.
The licensee has proposed the use ofeither sample disassembly and inspection or sample verification using NIT. It appears from the request that all four valves willbe exercised with flow each refueling outage, however, at outages where maintenance is scheduled, no non-intrusive reverification willbe performed. The use ofdisassembly and inspection interchangeably withNITis not acceptable.
Although the single'disassembled valve's operational readiness can be assessed, without non-intrusive techniques, the partial flowrate cannot be reverified to fullyopen the remaining valves. This issue is discussed in J. Colaccino's paper, "General Inservice Testing Issues," in NUREG/CP-0152, Volume 2. The licensee's 42
request to utilize sample disassembly and inspection is not authorized in accordance with Generic Letter 89-04, Position 2, unless testing with flowusing non-intrusives is impractical.
The licensee would need to document the basis for the determination that using flowor other practical means is impractical. As discussed in NUREG-1482, Section 4.1.2, the use ofnon-intrusives is not mandated, However, the NRC encourages the use ofthese techniques, where practical.
In conclusion, relief is not required to defer exercising to refueling based on impracticality.
Additionally, the use ofNITmay be used without relief. The use ofNITinterchangeably with disassembly and inspection, however, is not acceptable.
The licensee should continue to use NIT on one valve every outage or provide additional information to justify its impracticality.
The licensee should note that the ASME recently approved Appendix IIto the OM Code on check valve condition monitoring. This appendix allows licensees flexibilityin selecting test, examination, and preventative monitoring activities, and may allow the use ofboth non-intrusives techniques and disassembly and inspection. The use ofthis appendix is discussed in NUREG/CP-0152, Volume 2. The NRC has recently approved this alternate method for testing check valves at the WolfCreek Generating Station in a safety evaluation dated November 26, 1997. In the safety evaluation, the staff allows the use ofAppendix II, Check Valve Condition Monitoring'Program, included in ASME OM Code-1996 Addenda to the ASME OM Code-1995 Edition. Appendix IIwas authorized for use with a number ofconditions and limitations including: (1) where the most frequently performed appropriate measure (test, examination, or preventive maintenance) extends beyond 60 months, performance, examination, maintenance history, and test experience from previous tests shall be evaluated to justify the periodic verification interval; (2) the test or examination interval shall not exceed 120 months; (3) risk insights from other activities may be used when reviewed and approved by the staffto ensure that the testing, examination, or preventive measures taken are commensurate with each valve's safety significance; (4) check valve obturator movement willbe tested or examined in both the open and closed direction to ensure unambiguous detection offunctionality degraded check valves; (5) extensions ofIST intervals willconsider plant safety impact and be supported and justified by applicable methods oftrending to provide assurance that the valve is capable of performing its intended function over the entire interval; (6) initial IST interval extensions ofany valve must be limited to two fuel cycles or 3 years, and subsequent extended intervals must be limited to one fuel cycle per extension, up to 10 years; and (7) ifthe Condition Monitoring Program is discontinued, the testing and examination willrevert back to the original ASME Code requirements.
The staff considers that a number ofcheck valve issues can be addressed by adoption ofa check valve condition monitoring program as provided in Appendix IIofthe 1995
'SME OM Code. The licensee should consider this approach in evaluating its Code check valve testing program.
43
request to utilize sample disassembly and inspection is not authorized in accordance with Generic Letter 89-04, Position 2, unless testing with flowis impractical. The licensee would need to document the basis for the determination that using fiowor other practical means is impractical. As discussed in NUREG-1482, Section 4.1.2, the use ofnon-intrusives is not mandated.
However, the NRC encourages the use ofthese techniques, where practical.
0
'n conclusion, reliefis not required to defer exercising to refueling based on impracticality.
Additionally, the use ofNITmay be used without relief. The use ofNIT interchangeably with disassembly and inspection, however, is not acceptable.
The licensee should continue to use NIT on one valve every outage or provide additional information to justify its impracticality.
The licensee should note that the ASME recently approved Appendix IIto the OM Code on check valve condition monitoring. This appendix allows licensees flexibilityin selecting test, examination, and preventative monitoring activities, and may allow the use ofboth non-intrusives techniques and disassembly and inspection. The use ofthis appendix is discussed in NUIKG/CP-0152, Volume 2. The NRC has recently approved this alternate method for testing check valves at the WolfCreek Generating Station in a safety evaluation dated November 26, 1997. In the safety evaluation, the staff allows the use ofAppendix II, Check Valve Condition Monitoring Program, included in ASME OM Code-1996 Addenda to the ASME OM Code-1995 Edition. Appendix IIwas authorized for use with a number ofconditions and limitations including: (1) where the most frequently performed appropriate measure (test, examination, or preventive maintenance) extends beyond 60 months, performance, examination, inaintenance history, and test experience from previous tests shall be evaluated to justify the periodic verification interval; (2) the test or examination interval shall not exceed 120 months; (3) risk insights from other activities may be used when reviewed and approved by the staff to ensure that the testing, examination, or preventive measures taken are commensurate w'ith each valve's safety significance; (4) check valve obturator movement willbe tested or examined in both the open and closed direction to ensure unambiguous detection offunctionality degraded check valves; (5) extensions ofIST intervals willconsider plant safety impact and be supported and justified by applicable methods oftrending to provide assurance that the valve is capable of performing its intended function over the entire interval; (6) initial IST interval extensions of any valve must be limited to two fuel cycles or 3 years, and subsequent extended intervals must be limited to one fuel cycle per extension, up to 10 years; and (7) ifthe Condition Monitoring Program is discontinued, the testing and examination willrevert back to the original ASME Code requirements.
The staff considers that a number ofcheck valve issues can be addressed by adoption ofa check valve condition monitoring program as provided in Appendix IIofthe 1995 ASME OM Code.
The licensee should consider this approach in evaluating its Code check valve testing program.
43
3.2.3 Relief Request No. VR-06, PIV Test Frequency ReliefRequest: The license has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2 which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3;2.5 for the safety injection headers to the reactor coolant system (RCS) pressure isolation valves, V3217, V3227, V3237, and V3247 in the open direction.
Licensee 's Basis For Relief: "These are simple check valves with no external means of exercising nor for determining disc position. Consequently, the only practical method for stroke testing ofthese check valves is by injection via the safety injection pumps or discharging the contents ofthe safety injection tank (SIT) to the RCS.
During plant operations at power, partial flowexercising these valves is not practical because neither the SIT's nor the safety injection pumps are capable ofovercoming reactor coolant system pressure.
Performing a full-flowtest ofthese check valves by SIT discharge is impractical because the maximum flowrates attained by discharging the contents ofthe SIT's to the RCS do not meet the valves'aximum required accident condition flowas required by Generic Letter 89-04, Position
- 1. The maximum fiowrate achievable during a SIT discharge test is restricted by the long stroke time ofthe SIT discharge isolation valves' motor-operated valves with a nominal stroke time of 52 seconds and limitations on SIT pressure during testing.
Under large break LOCA accident conditions, the maximum (peak) flowrate through these valves would be approximately 20,000 gpm. as compared to test values ofapproximately 8,000 gpm.
Note also that normal shutdown cooling system flowis incapable offullstroking these valves based on the requirements ofGeneric Letter 89-04.
Although the flowrate attained during these SIT discharge tests does not qualify as "fullflow,"it is sufficient to fullystroke the check valve discs to the fullyopen position and verification ofthis is practical using non-intrusive testing techniques.
Due to system configuration, however, full-stroke exercising ofthe SIT discharge check valves cannot be performed in any plant mode other than refueling shutdown when the reactor vessel head is removed.
The safety injection header check valves are identical with respect to size and design and they are installed in essentially identical orientations exposed to the similar operating conditions. Each has been disassembled and inspected several times during previous refueling outages.
FP&L has additionally reviewed the operating and maintenance history ofsimilar valves used throughout the industry under comparable conditions.
Based on these reviews and inspections, there has been no evidence ofvalve degradation with respect to their ability to open and satisfactorily pass the required flowneeded to fulfilltheir safety function. This along with the observation that the SIT flowrate and pressure drop traces obtained during the 1994 refueling outage testing are 44
nearly identical, indicate that this baseline data was taken when each valve was in similar good working condition.
Since these valves are subjected to other testing and inspection requirements (other than flow testing) and related maintenance, there may be, from time to time, reason to disassemble a valve that is also scheduled for non-intrusive testing. At such times there is no added gain in performing a flowtest prior to the disassembly since the disassembly and visual inspection is adequate and in some respects superior to non-intrusive testing to confirm valve operability.
Thus, the additional cost and radiation exposure associated with performing the redundant non-intrusive testing cannot be justified..-Note also that Generic Letter 89-04, OM-Code, Part 10, Paragraph 4.3.2.4(c), and NUREG-1482 state that disassembly and inspection is equivalent to and an acceptable alternative to flowtesting.
In addition to flowtesting, each valve is confirmed to be closed under cold shutdown conditions and is subjected to periodic leakage tests. Note that, for this type ofvalve, leakage testing is especially sensitive to internal valve degradation."
Proposed Alternate Testing:
Each safety injection header check valve willbe partial-stroke exercised at cold shutdown and full-stroked in the open direction during refueling outages by discharging all four SITs to the reactor vessel.
During each refueling outage, under a sampling program on a rotating schedule, at least one ofthe check valves, willbe non-intrusively tested to verify its disc fullystrokes to its backstop, or ifscheduled for disassembly for another reason (e.g., preventative maintenance) disassembled, inspected, and manually stroked to verify operability.
Should a valve under testing or inspection be found to be inoperable and incapable ofperforming its function to open, then the remaining three valves willbe inspected or non-intrusive.
Following any valve reassembly, forward flowoperation ofthe valves (partial stroke open test) willbe observed Each safety injection header check valve be verified closed and leakrate tested in accordance with Relief Request No. VR-04.
Evaluation:
OMa-1988 Part 10, $4.3.2 requires check valves to be exercised quarterly. Iffull-stroke exercising during plant operation or cold shutdowns is impractical, it may be limited to full-stroke exercising during refueling outages.
The licensee has discussed why exercising during power operation or cold shutdowns is impractical because in order to achieve the flowrates necessary to fully-open the valve, the reactor head must be removed. Additionally, partial-stroke exercising during operations is impractical due to the system pressure being insufficient to overcome the RCS pressure.
Relief is not required in order to defer testing to refueling outages based on the impracticality ofperforming the test at power operation and cold shutdowns.
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The NRC's position is that check valves should be tested with flow,ifpractical (See discussion in Ref. 15, Question 2.3.23). As discussed in NUREG-1482, Appendix A, Question Groups 11 and 15, disassembly and inspection is an option only where fullstroke exercising cannot practically be performed by flowor by other positive means, and is not considered an equivalent method. The ASME Code committees clarified in the OMc-1994 Addenda that disassembly can be used only ifexercising with flowor a mechanical exerciser is impractical.
The licensee has proposed using non-intrusive testing (NIT). Relief is not required because this test method is considered an acceptable "other positive means," in accordance with Part 10,
$4.3.2.4(a).
The NITmust be repeatable and qualified, as discussed in Generic Letter 89-04, Position 1. As discussed in NUREG-1482, Section 4.1;2, check valves may be tested using NIT on a sampling basis, without relief. Allthe valves are exercised with less than the accident flow rate, and non-intrusives may be used to verify that the system pressures and fiowconditions specified in the test procedures cause the check valves to fullystroke. A sample plan is allowed since ifthe system conditions are repeatable, each valve would be typically stroked.
The use of non-intrusives on at least one valve each outage is required for reverifying the test method and test conditions (including flow)have not changed.
The licensee has proposed the use ofeither sample disassembly and inspection or sample verification using NIT. It appears from the request that all four valves willbe exercised with floweach refueling outage, however, at'outages where maintenance is scheduled; no non-intrusive reverification willbe performed.
The use ofdisassembly arid inspection interchangeably withNITis not acceptable, although the single disassembled valve's operational readiness can be assessed, without non-intrusive techniques the partial-fiowrate cannot be reverified to fullyopen the valves. This issue is discussed in J. Colaccino's paper, "General Inservice Testing Issues," in NUREG/CP-0152, Volume 2. The licensee's request to utilize sample disassembly and inspection is not authorized in accordance with Generic Letter 89-04, Position 2, unless testing with flowusing non-intrusives is impractical. The licensee would need to document the basis for the determination that using flowor other practical means is impractical. As discussed in NUREG-1482, Section 4.1.2, the use ofnon-intrusives is not mandated.
However, the NRC encourages the use ofthese techniques, where practical.
In conclusion, reliefis not required to defer exercising to refueling based on impracticality.
Additionally, the use ofNITmay be used in that relief. The use ofNITinterchangeably with disassembly and inspection, however, is not acceptable.
The licensee should continue to use NIT on one valve every outage or provide additional information to justify its impracticality.
The licensee is referred to TER Section 3.2.2 for guidance on the use ofthe recently approved Appendix II to the OM Code on check valve condition monitoring.
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3.2.4 Relief Request No. VR-21, HPSI to RWT Check Valves'est Frequency ReliefRequest: The license has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2 which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5 for the high pressure safety injection (HPSI) pumps minimum flowto the refueling water tank (RWT) check valves, V3102 and V3103 in the open direction.
Licensee 's Basis For Relief: "These are simple check valves with no external means of exercising nor determining obtur'ator position. Consequently, the only practical method for determining disk position (open) is by performing a pump flowrate test. Full stroke capability must be verified, per Generic Letter 89-04, Position 1, by attaining the maximum accident flow through each valve. There is no installed flowmeasuring instrument available with which this determination can be made.
Non-intrusive verification offull-stroke operation is not practical since the system is provided with permanently installed orifices that restrict flowto a quantity less than that required to fully open the valves.
The associated high pressure safety injection pumps are normally idle in standby status and are operated only during test periods, thus these valves see little service and service-related failures are unlikely.
These vaxves are identical with the same manufacturer, size, model designation, orientation, and service conditions."
Proposed Alternate Testing: During quarterly pump testing each ofthese valves willbe partial-stroke exercised via recirculation through the minimum flowtest circuits with no flow measurements.
During each reactor refueling outage, at least one ofthese valves willbe disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the other valve willbe inspected during the same outage, after which the rotational inspection schedule willbe reinitiated. Following reassembly, each valve willbe partial-flow exercised open and tested closed to verify operability.
Evaluation:
The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With respect to exercising the valves to the full-stroke open position, verification that the valve can pass the maximum required accident flowrate is acceptable.
Where fullflowtesting is impractical, other qualified techniques, such as non-intrusive testing, may be used to confirm the valve is exercised to the position required to fulfillthe valve's safety function. Additionally, the Code allows the use ofa mechanical exerciser or disassembly every 47
refueling outage.
Disassembly and inspection using a sampling program is an acceptable alternative, as discussed in Generic Letter 89-04, Position 2.
These valves open to provide flowpaths from the high pressure safety injection pump's discharge to the refueling water tank to ensure adequate pump cooling during low flowconditions. These are simple check valves with no external means for determining obturator position.
Additionally, there are no permanently installed flowinstruments to verify the flowrate through the valves and the maximum required flowrate is insufficient to fullyopen the valves, thereby making the use ofnon-intrusives impractical. Therefore, while open during the quarterly HPSI pump test, this test is considered a partial-stroke exercise.
The only practical means available to verify the full-stroke open capability ofthese valves is by disassembly and inspection. To require disassembly and inspection ofboth valves each refueling would be a hardship without a compensating increase in the level ofquality and safety. The licensee's proposal complies with the guidance provided in Generic Letter 89-04, Position 2, for a sample disassembly and inspection program. Therefore, it is recommended that the alternative be authorized in accordance with 10CFR50.55a(a)(3)(ii).
3.3 Main Steam System 3.3.1 Relief Request No. VR-07, SGs to Turbine Check Valves ReliefRequest:
The licensee has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2 which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5 for the Unit 1 steam generator to main turbine check valves, V08117 and V08148, in the closed direction.
Licensee 's Basis For Relief: "These are simple check valves with no external means of exercising nor for determining obturator position. Due to the high operational temperature ofthe valves, non-obtrusive testing is impractical. Furthermore, there is no practical means or provision for pressurizing the piping downstream ofthese valves in order to conclusively verify closure'of these valves via back leakage tests.
These are large valves (34-inch NPS) where disassembly is difficultand consumes a considerable amount ofplant resources, thus disassembly ofboth ofthese valves during each reactor refueling would pose a significant hardship and, based on plant safety considerations, is not warranted.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions."
Proposed Alternate Testing: During each reactor refueling outage at least one ofthese valves willbe disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the other valve willbe inspected during the same outage, aAer which the rotational inspection schedule willbe reinitiated. Following valve re-assembly forward flowoperation ofthe valves willbe observed during the ensuing startup.
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Evaluation: The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With respect to exercising the valves closed, verification that a valve is in the closed position can be done by visual observation, by an electrical signal initiated by a position-indicating device, by observation ofappropriate pressure indication in the system, by leak testing, or by other positive means.
Additionally, the Code allows the use ofa mechanical exerciser or disassembly every refueling outage.
Disassembly and inspection using a sampling program is an acceptable alternative, as discussed in Generic Letter 89-04, Position 2.
These valves only have a safety function in the closed direction to prevent unrestricted release of steam from an unaffected steam generator in the event ofa steam line rupture upstream of a'n MSIV. It is impractical to verify the safety function ofthese valves to close using flowsince these are simple check valves with no external means for determining obturator position. The licensee states that due to the high operational temperature ofthe valves, non-intrusive testing is impractical
~ Additionally, there is no practical means or provision for pressurizing the piping
'ownstream ofthese valves in order to verify closure ofthese valves via leak testing. The only practical means available to verify the closure capability ofthese valves is by disassembly and inspection. To require disassembly and inspection ofboth valves each refueling outage would be a hardship without a compensating increase in the level ofquality and safety. The licensee's proposal complies with the guidance provided in Generic Letter 89-04, Position 2, for a sample disassembly and inspection program. Therefore, it is recommended the alternative be authorized in accordance with 10CFR50.55a(a)(3)(ii).
3.4 Feedwater System 3.4.1 Relief Request No. VR-10, Feedwater to Steam Generator Check Valves ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2, which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5 for the Unit 1 feedwater to steam generator check valves, V09248 and V09280, in the closed direction.
Licensee 's Basis for Relief: "These are simple check valves with no external means ofexercising nor for determining disk position. Consequently, the only practical method for determining disk position (close) is by performing a differential pressure back leakage test. Due to system configuration, there is no practical way ofreliably performing such a test during any plant operational mode. Under steaming conditions at power, isolation ofthe feedwater supply piping is not possible without causing a severe plant transient.
Under shutdown conditions, backflow testing would require draining a significant portion ofthe upstream feedwater piping and attempting to seat the subject valves by injection ofwater through the associated 1-inch downstream drain valves. It is unlikely that such a test could be performed successively and conclusively."
49
Proposed Alternate Testing: During each reactor refueling outage at least one ofthese valves will be disassembled, inspected, and manually stroked to verify closure capability. Should a valve under inspection be found to be inoperable, then the other valve willbe inspected during the same outage, aAer which the rotational inspection schedule willbe reinitiated.
'4 Evaluation:
The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With respect to exercising the valves closed, verification that a valve is in the closed position can be done by visual observation, by an electrical signal initiated by a position-indicating device, by observation ofappropriate pressure indication in the system, by leak testing, or by other positive means.
Additionally, the code allows the use ofa mechanical exerciser or disassembly every refueling outage.
Disassembly and inspection using a sampling program is an acceptable alternative, as discussed in Generic Letter 89-04, Position 2.
These 20-inch valves close to isolate the respective steam generator to ensure adequate inventory ofcondensate for auxiliary feedwater pump operation.
These are simple check valves with no external means for determining obturator position. Performance ofa back leakage test is impractical since isolating feedwater during operation would result in steam generator level
'ransients and potential for plant trip. Although there are test connections available both downstream and upstream, the size ofthe test connections versus the size ofthe valves (i.e., 1-inch versus 20-inch), would make backflow testing impractical. The only practical means available to verify the closure capability ofthese valves is by disassembly and inspection. To "
require disassembly and inspection ofboth valves each refueling outage would be a hardship without a compensating increase in the level ofquality and safety. The licens'ee's proposal complies with the guidance provided in Generic Letter 89-04, Position 2, for a sample disassembly and inspection program. Therefore, it is recommended that the alternative be authorized in accordance with 10CFR50.55a(a)(3)(ii).
3.4.2 Relief Request No. VR-11, AFW Pump Min-FlowCheck Valves n
ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2, which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5 for the AFWpump min-flowcheck valves, V09303 (Unit 2 only), V09304, and V09305, in the open direction.
Licensee 's Basis for Relief: "These are simple check valves with no external means ofexercising nor for determining disk position. Consequently, the only practical method for determining disk position (open) is by performing a pump flowrate test. Full stroke capability must then be verified, per Generic Letter 89-04, Position 1, by attaining the maximum accident flowrate through each valve. There is no flowrate instrumentation available to verify valve full-stroke exercising ofthese valves as required by the Generic Letter.
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The lines in which these valves are installed are provided with permanent orifices that restrict the flowrate such that the maximum flowpossible is insufficient to fullyopen these valves. For this reason, non-intrusive testing would be ineffective and inconclusive and thus is not practical.
The associated auxiliary feedwater pumps are normally idle in standby status operated only during test periods, thus these valves see little service and service related failures are unlikely."
Proposed Alternate Testing: During quarterly pump testing each ofthese valves willbe partial-stroked exercised via recirculation through the minimum flowtest circuits with no flow measurements.
During each reactor refueling outage at least one ofthese valves willbe disassembled, inspected, and manually stroked to verify operability. Should.a valve or valves under inspection be found to be inoperable, then the. other valve or valves in that unit willbe inspected during the same outage, after which the rotational inspection schedule willbe reinitiated. Following re-assembly, each valve willbe partial-flow exercised to verify operability.
Evaluation:
The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With respect to exercising the valves to the full-stroke open position, verification that the valve can pass the maximum required accident flowrate is acceptable.
Where fullflowtesting is impractical, other qualified techniques, such as non-intrusive testing, may be used to confirm the valve is exercised to the position required to fulfillthe valve's safety function. Additionally, the Code allows the use ofa mechanical exerciser or disassembly every refueling outage.
Disassembly and inspection using a sampling program is an acceptable alternative, as discussed in Generic Letter 89-04, Position 2.
These valves open to provide flowpaths from each auxiliary feedwater pump's discharge to the condensate storage tank to ensure adequate pump cooling during low fiowconditions. They are opened quarterly during the AFWpump tests.
These are simple check valves with no external means for determining obturator position. Additionally, there are no permanently installed flow instruments to verify the flowrate through the valves, and the maximum required flowrate is insufficient to fullyopen the valves, thereby making the use ofnon-intrusives impractical. The only practical means available to verify the full-stroke open capability ofthese valves is by disassembly and inspection, as proposed by the licensee.
To require disassembly and inspection ofboth valves each refueling outage would be a hardship without a compensating increase in the level ofquality and safety. The licensee's proposal complies with the guidance provided in Generic Letter 89-04, Position 2, for a sample disassembly and inspection program. Therefore, it is recommended that the alternative be authorized in accordance with 10CFR50.55a(a)(3)(ii).
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3.5 Instrument AirSystem 3.5.1 Relief Request No. VR-12, Vacuum Breaker and MSIVAccumulator Supply Check Valves ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2.2(a), which requires each check valve to be exercised or examined in a manner which verifies obturator travel to the closed, full-open or partially open position required to fulfillits function for the vacuum breaker supply check valves in Unit 1 and 2: V18290, V18294, V18291, and V18295; and MSIVaccumulator supply check valves in Unit 1 only: V18695, V18699, V18696, and V18099.
Licensee 's Basis for Relief: 'These are simple check valves with no external means ofexercising nor for determining disk position. Consequently, the only practical method for determining disk position is by performing a back-leakage test, however, these check valves are installed with each pair in series with no provision for verification that each individual valve is closed.
For these applications only one valve need close. Both valves are designated as ISI Class 2 (Class 3 for MSIVaccumulators) and, as such, both valves in each line willbe treated with the same quality assurance requirements."
Proposed Alternate Testing:
Either ofthese valves willbe verified to close by performing a back-leakage on the series combination ofvalves. In the event that both valves fail to close, the combination willbe declared inoperable and both valves willbe repaired or replaced, as appropriate.
Evaluation: These valves close to isolate the air in the accumulators supplying the primary containment vacuum breaker valves and, for Unit 1, the MSIVs, in the event ofa loss ofpressure in the plant main instrument air headers.
The Code requires that each valve performing a safety function be stroked to the position required to perform that function. There is no practical means ofverifying the ability ofeach valve in the series to close, based on the lack ofposition indication and test connections between the valves. As discussed in NUREG-1482, Section 4.1,1, verification that a pair ofvalves is closed is acceptable ifonly one valve ofthe two valves is credited in the plant safety analysis, both valves are subject to equivalent quality assurance criteria and are included in the IST program, and ifthe closure capability ofthe pair is questionable, both valves are declared inoperable and corrective actions are taken on both valves, as necessary, before being returned to service.
The licensee's proposed testing complies with the guidance in the NUREG, and it is recommended that reliefbe granted in accordance with 10CFR50.55a(f)(6)(i).
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3.6 Containment Spray System 3.6.1 Relief Request No. VR-14, RWT Discharge Check Valves ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2, which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5 for the RWT discharge check valves, V07119 and V07120 in the open direction.
Licensee 's Basis for Relief: 'hese are simple check valves with no external means ofexercising nor determining obturator position. Full stroke exercising (open) ofthese valves would require the simultaneous operation ofone high pressure safety injection (HPSI) pump, one'low pressure safety injection (LPSI) pump, and one containment spray pump to verify that each valve can pass the maximum design accident flow. Such a test is not practical during any plant operational mode. Non-intrusive testing (NIT)ofthese valves necessarily requires that each valve undergo a fullstroke cycle induced by flowthrough the associated piping. In this case, the maximum flowrate possible in the line is approximately 4,500 gpm-the nominal design flowrate ofthe LPSI pumps. At this flowrate, taking into consideration that these 24-inch NPS valves are on the suction side ofthe pumps and not subjected to a starting pressure surge at the pump discharge, they willnot travel to the full-open position with a backstop impact when the associated LPSI pump is started or running. This precludes any meaningful, reliable, and conclusive non-intrusive testing.
These are large valves (24-inch NPS) where disassembly is difficultand consumes a considerable amount ofplant resources, thus disassembly ofboth ofthese valves during each reactor refueling would pose a significant hardship and, based on plant safety considerations, is not warranted. In addition, access for disassembly requires draining a significant portion ofthe safety injection system piping creating a sizable load on the plant's radwaste systems.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions."
Proposed Alternate Testing: During quarterly pump testing each ofthese valves willbe partial-stroke exercised via recirculation through the minimum flowtest circuits ofthe various safety injection systems.
During each reactor refueling outage at least one ofthese valves willbe disassembled, inspected, and manually stroked to verify operability. Should a valve under inspection be found to be inoperable, then the other valve willbe inspected during the same outage, afler which the rotational inspection schedule willbe reinitiated. Following reassembly, each valve willbe partial-flow exercised open and tested closed to verify operability.
53
i Evaluation:
The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With respect to exercising the valves to the full-stroke open position, verification that the valve can pass the maximum required accident flowrate is acceptable.
Additionally, the Code allows the use ofa mechanical exerciser or disassembly every refueling outage.
Disassembly and inspection'using a sampling program is an acceptable alternative, as discussed in Generic Letter 89-04, Position 2.
These valves open to provide flowpaths from the refueling water tanks (RWT's) to the containment spray and safety injection suction headers.
They close to prevent the transfer of containment sump water back to the associated RWT after a recirculation actuation signal (RAS).
These are simple check valves with no external means for determining obturator position. As stated by the licensee, non-intrusive testing is also impractical since the maximum flow obtainable is not sufficient to fullyopen the valve resulting in a backstop impact discernable by non-intrusive techniques. It appears that the licensee has considered using acoustical monitoring to determine full-opening ofthe valve. While this is the most common technique, other non-intrusive techniques methods have been used to provide indications ofobturator position, including radiography, magnetic flux, and ultrasonic testing (Ref. 22). The licensee may wish to evaluate these techniques and remain cognizant ofdevelopments with these techniques as a possible future alternative to valve disassembly and inspection.
As discussed in Generic Letter 89-04, Position 2, sample disassembly and inspection is an acceptable alternate to full-flowtesting. The only practical means available to verify full-stroke open capability ofthese valves is by disassembly and inspection. To require disassembly and inspection ofboth valves each refueling outage would be a hardship without a compensating increase in the level ofquality and safety. The licensee's proposal complies with the guidance provided in Generic Letter 89-04, Position 2, for a sample disassembly and inspection program.
Therefore, it is recommended that the alternative authorized in accordance with 10CFR50.55a(a)(3)(ii).
3.6.2 Relief Request No. VR-15, CS to Eductors Check Valves ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10, tt4.3.2, which requires check valves to be exercised nominally every 3 months, except as provided by tI4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5, for the Unit 1 containment spray to spray additive eductors check valves, V07269 and V07270 in the open direction.
Licensee 's Basis for Relief: "These are simple check valves with no external means ofexercising or determining obturator position. They cannot be fullflowexercised during normal operation since there is no flowrate instrumentation available to verify valve full-stroke exercising as required by the Generic Letter 89-04, Position 1.
Note that these valves remain closed in a benign medium under all but testing and accident conditions and see little actual operation, thus service related failure is unlikely.
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Each ofthese valves has been disassembled and inspected in the past and they have not displayed any indication ofdegradation that would impede their capability to perform their safety function to open.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions.
The St. Lucie on-site staff does not have the resources required to perform non-intrusive testing on these valves, thus whenever non-intrusive testing is required, contract services must be procured.
For this reason, testing more frequently than once per refueling outage or two years is not practical."
Proposed Alternate Testing: During each reactor refueling outage at least one every two years, each ofthese valves willbe verified to fullyopen using non-intrusives or other positive Evaluation:
The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With'respect to exercising the valves to the full-stroke open position, verification that the valve can pass the maximum required accident flowrate is acceptable.
Where fullflowtesting is impractical, other qualified techniques, such as non-intrusive testing, may be used to confirm the valve is exercised to the position required to fulfillthe valve's safety function. The Code requires exercising quarterly or, ifimpracticable, at cold shutdowns or refueling outages.
These valves open to provide flowpaths from the respective containment spray discharge headers to the spray additive eductors.
This flowthrough the eductors provides the motive force needed to inject the sodium hydroxide solution into the suction ofthe containment spray pumps.
These are simple check valves with no external means for determining obturator position. Additionally, there are no permanently installed flowinstruments to verify the flowrate through the valves.
The licensee is proposing to verify that each valve willfully-open each refueling outage using non-intrusive techniques.
The licensee has stated in the Basis that it is impractical to test these valves at a frequency other than refueling outages due to the need to acquire outside contractor services.
As discussed in NUREG-1482, Section 4.1.4 and the response to Question 2.3.19 contained in the Summary ofPublic Workshops Held in NRC Regions on Inspection Procedure 73756 (Ref. 15), the need to set up test equipment is adequate justification to defer check valve testing to a refueling outage frequency. Verifyingthe abilityofeach valve to fullyopen each refueling outage using non-intrusive techniques provides reasonable assurance ofthe valves operational readiness.
Because the Code allows deferrals to refueling outages, reliefis not required. The licensee should continue, however, to document the deferral justification in the IST Program.
In the previous submittal ofthis reliefrequest, the licensee stated that each ofthese valves would be partial-stroke exercised quarterly in conjunction with the testing ofthe containment spray pumps without measuring flowrate through the valves. This partial stroke exercising is not 55
addressed in the revised reliefrequest.
The licensee should ensure that this testing is still performed, and revise the request accordingly.
3.6.3 Relief Request No. VR-16, Containment Sump Discharge Check Valves ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10,
$4.3.2, which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5, for the containment sump discharge check valves, V07172 and V07174 in the open direction.
Licensee 's Basis for Relief: 'These are simple check valves with no external means ofexercising or determining obturator position. Exercising with system flowis not practical since there is no water inventory available in the containment sump and flooding the sump for such a test is undesirable and impractical since itwould have the potential for upsetting the'chemistry ofthe RCS by introducing contaminants into the safety injection system.
These are large valves (24-inch NPS) where disassembly is difficultand consumes a considerable amount ofplant resources, thus disassembly ofboth ofthese valves during each reactor refueling would pose a significant hardship and, based on plant safety considerations, is not warranted.
In'ddition, access for disassembly requires draining a significant portion ofthe safety injection system piping creating a sizable load on the plant's radwaste systems.
Each ofthese valves has been disassembled and inspected in the past and they have not displayed any indication ofdegradation that would impede their capability to perform their safety function to open.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions.
Note that these valves remain closed in a benign medium under all but accident conditions and see no actual operation, thus service related failure is unlikely."
'I Proposed Alternate Testing: During each reactor refueling outage at least one ofthese valves willbe disassembled, inspected, and manually exercised on a sequential and rotating schedule.
If, in the course ofthis inspection, a valve is found to be inoperable with respect to its function to fullyopen, then the other valve willbe inspected during the same outage.
Evaluation:
The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With respect to exercising the valves to the full-stroke open position, verification that the valve can pass the maximum required accident flowrate is acceptable.
Additionally, the Code allows the use ofa mechanical exerciser or disassembly every refueling outage.
Sample disassembly and inspection is an acceptable alternate, as discussed in Generic Letter 89-04, Position 2.
56
These check valves open to provide flowpaths from the containment sumps to the containment spray and safety injection pumps during post-accident recirculation cooling. It is impractical to exercise these 24 inch valves with flowduring any mode ofoperation based on the lack ofsump inventory and the potential for contaminating the RCS ifthe sump was flooded for the sole purpose oftesting.
As discussed in Generic Letter 89-04, Position 2, sample disassembly and inspection is an acceptable alternate to full-flowtesting. The only practical means available to verify the full-stroke open capability ofthese valves is by disassembly and inspections. To require disassembly and inspection ofboth valves each refueling outage could be a hardship without a compensating increase in the level ofquality and safety. The licensee's proposal complies with the guidance provided in Generic Letter 89-04, Position 2, for a sample disassembly and inspection program.
Therefore, it is recommended that the alternative be authorized in accordance with 10CFR50.55a(a)(3)(ii).
3.6.4 Relief Request No. VR-17, CS Pump Discharge Check Valves ReliefRequest: The licensee has requested relieffrom the requirements ofOMa-1988 Part 10;
$4.3.2, which requires check valves to be exercised nominally every 3 months, except as provided by $4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5, for the containment spray pump discharge check valves, V07192 and V07193 in the open direction.
Licensee 's Basis for Relief: "These are simple check valves with no external means ofexercising or determining obturator position. Exercising with system flowto the open position would require operating each containment spray pump at nominal accident flowrate. Since no recirculation flowpath exists downstream ofthese valves, the only flowpath available for such a test would result in injecting radioactive contaminated borated water into the containment spray headers and thence into the containment building via the spray nozzles.
Dousing personnel and equipment in this manner is obviously undesirable.
Partial-flow testing using compressed air is possible, but requires draining the entire containment spray discharge header and supplying air via the 3-inch test connections.
The amount ofair necessary for a meaningful test would require the temporary installation ofan additional air compressor solely for this purpose.
The value ofa partial-stroke air flowtest for determining valve operability under these conditions is at best marginal and has littleor no merit; thus the burden ofperforming such a test is not warranted based on the limited value and benefit derived.
Each ofthese valves has been disassembled and inspected in the past and they have not displayed any indication ofdegradation that would'impede their capability to perform their safety function to open.
These valves are identical with the same manufacturer, size, model designation, orientation, and service conditions.
57
Note that these valves remain closed in a benign medium under all but accident conditions and see no actual operation, thus service related failure is unlikely."
Proposed Alternate Testing: During each reactor refueling outage at least one ofthese valves willbe disassembled, inspected, and manually exercised on a sequential and rotating schedule.
If, in the course ofthis inspection a valve is found to be inope'rable with respect to its function to fullyopen, then the other valve willbe inspected during the same outage.
Evaluation:
The Code requires valves to be exercised to the position required to fulfillthe valve's safety function. With respect to exercising the valves to the full-stroke open position, veriflcation that the valve can pass the maximum required accident flowrate is acceptable.
Additionally,the Code allows the use ofa mechanical exerciser or disassembly every refueling outage.
Sample disassembly and inspection is the acceptable alternate as discussed in Generic Letter 89-04, Position 2.
These check valves open to provide flowpaths from the containment spray pumps to the containment spray headers in containment. It is impractical to full-stroke exercise these valves with flowduring any mode ofoperation, due to the potential ofequipment damage and the extensive cleanup.
As discussed in Generic Letter 89-04, Position 2, sample disassembly and inspection is an acceptable alternate to full-flowtesting. The only practical means available to verify the full-stroke open capability ofthese valves is by disassembly and inspection. As discussed in the Generic Letter, however, partial stroke exercising quarterly or during cold shutdowns, or aAer reassembly must be performed, ifpossible.
The licensee has discussed the impracticality of performing a partial-flow test using compressed air quarterly or during cold shutdowns.
However, the licensee has not demonstrated the impracticality ofperforming a partial-flow test with air followingvalve disassembly and inspection. It appears that the containment spray discharge header must be drained to perform the disassembly and'inspection.'The value of performing a partial-stroke test followingvalve disassembly and inspection itthat it provides assurance ofproper reassembly and operation ofthe valve.
To require disassembly and inspection ofboth valves each refueling outage as required by the Code would be a hardship without a compensating increase in the level ofquality and safety.
The licensee's proposal complies with the guidance provided in Generic Letter 89-04, Position 2, for a sample disassembly and inspection program. Therefore, it is recommended that the alternative be authorized in accordance with 10CFR50.55a(a)(3)(ii).
The licensee should partial-stroke exercise the valve followingdisassembly and inspection or include in the basis for requesting reliefadditional information supporting the determination ofthe impracticality. The revised request need not be resubmitted, but is subject to NRC inspection.
58
4.0 VALVETESTING DEFERRAL JUSTIFICATIONS Florida Power &Light has submitted seventy-eight justifications for deferring valve testing to cold shutdowns and nine justifications for deferring testing to refueling outages.
These justifications document the impracticality oftesting 240 valves quarterly, during power operation.
These justifications were reviewed to verifytheir technical basis, As discussed in Generic Letter 91-18 (Ref. 18), it is not the intent ofIST to cause unwarranted plant shutdowns or to unnecessarily challenge other safety systems.
Generally, those tests involving the potential for a plant trip, or damage to a system or component, or excessive personnel hazards are not considered practical. Removing one train for testing or entering a Technical Specification limitingcondition ofoperation is not sufficient basis for not performing the required tests, unless the testing renders systems'inoperable for extended periods oftime (Reference NUIKG-1482, Section 3.1.1). Other factors, such as the effect on plant safety and the difficultyofthe test, may be considered.
Valves, whose failure in a non-conservative position during exercising would cause a loss of system function, such as non-redundant valves in lines (e.g., a single line &om the RWST or accumulator discharge), or the RHR pump discharge crossover valves for plants whose licensing basis assumes that all four cold legs are being supplied by water from at least one pump, should not be exercised during conditions when the system is required to be operable.
Other valves may fall into this category under certain system configurations or plant operating modes, e.g., when one train ofa redundant ECCS system is inoperable, non-redundant valves in the remaining train should not be,.cycled because their failure would cause a total loss ofsystem function, or when one valve in a containment penetration is open and inoperable, the redundant valve should not be exercised during this system configuration.
BNL's evaluation ofeach deferral justification is provided in Appendix A. "The anomalies =----
associated with the specific justifications are provided in Section 6.0 ofthis TER.
5.0 IST SYSTEM SCOPE REVIEW The review performed for this TER did not include verification that all pumps and valves within the scope of 10 CFR 50.55a and Section XIare contained in the IST Program, and did not ensure that all applicable testing requirements have been identified. The IST Program's scope was, however, reviewed for selected systems.
The pumps and valves in the containment spray, component cooling water, and safety injection systems were reviewed against the requirements ofSection XIand the regulations.
TheLJFSAR was used.to determine ifthe specified-valve categories and valve functions were'consistent with the plant's safety analyses.
The review results showed compliance withthe Code, except forthe items discussed in Section 6.0. The '"
licensee should review these items and make changes to the IST Program, where appropriate.
Additionally,the licensee should verify that there are not similar problems with the IST Program for other systems.
59
6.0 IST PROGRAM RECOMMENDEDACTIONITEMS Inconsistencies, omissions, and required licensee actions identified during the review ofthe licensee's third interval for Unit 1 and second interval for Unit 2 Inservice Testing Program are summarized below. The licensee should resolve these items in accordance with the evaluations presented in this report.
A.
General Recommended Actions The Unit 1 third interval dates do not correspond to the date ofcommercial operation.
The basis for the interval dates should be provided in future IST program revisions and may be subject to NRC inspector reviews.
2.
Page 18 of225 ofADM29.01 states that the combined IST program willbe in effect through the end ofeach units'hird 10 year interval, This program is for the second interval for Unit 2. The procedure should be corrected.
3.
Valves V-1402 and 1404 in the Reactor Coolant System are fail closed solenoid valves.
There is no fail-safe (FS) test specified in Table 2. The licensee should review the function ofthe valves and correct the table as necessary.
B.
Recommended Actions for Relief Requests As noted in NUREG-1482, $5.5.1, when using portable instruments as proposed in PR-01, the staff recommends that the licensee include in the IST records an instrument number for tracing each instrument and a calibration data sheet for verifyingthat the instruments are accurately calibrated. Additionally,ifinstrumentation becomes commercially available which meets the Code requirements that the full-scale range of each analog"instrument shall no't be greater than three times the reference value, and the licensee is procuring replacement speed instruments, the licensee should withdraw Relief Request PR-01 and procure instruments which meet the Code requirements.
2.
It is reco'mmended that long term reliefofPR-07 be denied. An interim period ofone year has been allowed to allow the licensee either to procure new equipment that meets the Code requirements or revise an'd resubmit the reliefrequest, Ifthe reliefrequest is revised, it should address the specific hardship ofcomplying with the Code and how the-proposed alternative provides an acceptable level ofsafety. The licensee is referred to TER Section 2.1.2.
3.
The licensee has not specified in ReliefRequest PR-08 the specific inspections and maintenance proposed (other than oil analysis) for the hydrazine pumps, or their
~periodicity. The licensee would need to document these, as well as the acceptance 60
criteria and the maintenance/inspection results. This documentation would be subject to NRC inspector review.
The licensee should revise Table I-Unit2 Pump Table to properly indicate that pump discharge pressure is being measured quarterly and during refueling outages.for the hydrazine pumps, and revise Relief Request PR-09 to be consistent with the new PR-08.
The licensee should review the guidance on the contents ofan analysis provided in TER Section 2,3.1.
It is recommended that Relief Request VR-02 be denied.
See TER Section 3.1.2 for the evaluation.
The use ofnon-intrusive techniques interchangeably with disassembly and inspection has not been recommended, as requested in VR-05 and VR-06. See TER Section 3.2.2 and 3.2.3 for the evaluation.
't appears that the licensee has considered using acoustical monitoring to determine full-opening ofthe RWT discharge check valves (VR-14). While this is the most common technique, other non-intrusive techniques methods have been used to provide indications ofobturator position, including radiography, magnetic flux, and ultrasonic testing (Ref.
19). The licensee may wish to evaluate these techniques and remain cognizant of developments with these techniques as a possible future alternative to valve disassembly and inspection.
In the previous submittal ofRelief Request VR-I6, the licensee stated that each ofthe valves would be partial-stroke exercised quarterly in conjunction with the testing ofthe containment spray pumps without measuring flowrate through the valves. This partial stroke exercising is not addressed in the revised reliefrequest.
The licensee should ensure that this testing is still performed, and revise the request accordingly. In addition, ifat a later time, the licensee determines that quarterly testing using non-intrusives becomes less difficult(e.g., through the use ofpermanently installed equipment), the licensee should reevaluate and resubmit this request.
The licensee has not demonstrated in ReliefRequest VR-17 the impracticality of performing a partial-flow test with air followingvalve disassembly and inspection. It appears that the containment spray discharge header must be drained to perform the disassembly and inspection. The value ofperforming a partial-stroke test followingvalve disassembly and inspection is that itprovides assurance ofproper reassembly and operation ofthe valve. The licensee should, therefore, perform a partial-stroke exercise after reassembly or revise the request to include in the basis additional information supporting the determination ofimpracticality. The revised request need not be resubmitted, but is subject to NRC inspection.
61
The licensee has stated in VR-20 that the subject valves are "simple" check valves.
Provided that they are not capacity certified in accordance with Section IIIor the construction code, use ofthe clarification provided in the code committee's proposal is acceptable and reliefis not required. The licensee should continue to document this approach in the IST program."The licensee should revise and resubmit the request ifthe valves are capacity certified.
12.
The licensee states that it is impractical to test the containment vacuum breaker valves during power operation based on their location inside containment and the need for local access in VR-19. There is not sufficient information to support the basis of impracticality. The licensee should provide additional information on why entering the containment and gaining local access to the valves is impractical and resubmit the request.
W 4 '
~
C.
Recommended Actions for Deferral Justifications 1.
In RFJ-01 and RFJ-20, the licensee should consider establishing a schedule to account for extended cold shutdown outages when the RCPs are stopped for a sufficient length of time to allow for testing ofthe RCP seal leakoffCIVs and the RCP suction check valves.
2.
The licensee has proposed to use RWT level changes to determine fiowrate for the HPSI minimum flowcheck valves (RFJ-03) and the LPSI minimum flowcheck valves (RFJ-07). The instrument accuracy must be adequate to demonstrate that the valves are open to the position necessary for the check valves to fulfilltheir safety function.
3.
RFJ-04 refers to the HPSI pump suction check valves. However, the justification refers to the LPSI pumps.
The licensee should review this and modify the justification as
'n'ee e
4.
In RFJ-05 and 09, the licensee proposes to partial-stroke exercise the HPSI pump discharge valves during cold shutdowns.
However, the justification provided for each discusses issues which make exercising during cold shutdowns impractical. The licensee should review this and revise the justifications as necessary.
5.
In RFJ-10, the licensee has discussed the impracticality ofpartial-stroking HPSI pump PIVs V3524 and V3526. The licensee should also include an explanation for valves V3523 and V3527.
6.
In RFJ-13, the licensee discusses the impracticality offull-stroke exercising the AFW ---.-- -=
pump bearing cooling water discharge valves during operation.
However, as discussed in PR-02, the turbine driven AFWpump is minimum flowtested quarterly, and full-flow 62
tested during cold shutdowns.
The licensee should investigate why partial-stroking is not possible during the quarterly and cold shutdown testing.
7.
In RFJ-17, the licensee has not provided a justification for deferring verification of closure for the normally closed containment spray pump suction header check valves.
8.
The licensee should review Table 3 (Unit2 Valve Table) and correct the following:
- Table 3, Page 4 of44, the RFJ-02 entry for V2191 applies to the partial-stroke exercising at cold shutdowns, not the closure testing performed during operation as indicated.
9.
The cold shutdown deferral for the Unit 1 LPSI pump discharge minimum flow/recirculation line isolation valves V3659 and V3660 is based upon the potential of LPSI pump damage which could occur ifthe valves were exercised quarterly. The licensee should ensure that the same justification is not applicable to Unit 2 as well. Per the Unit 2 Valve Table, these valves are exercised quarterly.
10.
The cold shutdown deferral for the Unit2 Nitrogen gas supply CIV(valve V6792) is based upon the impracticality ofentering the containment to perform a leakage test. The licensee should include in the deferral additional information on why it is impractical to exercise this valve quarterly. The licensee should also correct the drawing reference for this deferral request in the Unit 2 Valve Table to correctly indicate drawing number 2998-G-078, Sheet 163B.
D.
Recommended Actions for System Review The Unit 2 containment fan coolers'omponent cooling water motor-operated containment isolation valves are identified in the IST Program as passive.
As
--=-
- -containment isolation valves per Table 6.2-52 in the SAR, they would appear to have an active safety function to close. The licensee should review the safety function and classification ofthese valves.
2.
Check valves V07267, 7266 (Unit 1); and V29431 and 29432 (Unit 2) in the containment spray nitrogen supply to the hydrazine storage tanks are not included in the IST program.
These valves isolate the non-safety related nitrogen supply to the hydrazine tanks. Their failure may compromise the tanks'ntegrity. The licensee should review the safety function ofthese valves.
3. --
Check valves V07133 and 7141 are the containment spray min-flowvalves back to the =--=-==-
RWT. These valves are not included in the IST Program.
The licensee should ensure that these valves do not have a safety function in the event that the containment spray valves are inadvertently isolated followingthe start ofthe pumps.
63
The Unit 2 containment isolation valve table in the SAR (Table 6.2-52) identified valve I-V-07-1553 as the inboard containment isolation valve for penetrations 34 and 35. Based on a review ofdrawing 2998-G-088, Sheet 2, it would appear that the inboard containment isolation valves are V0192 and V0193. These valves are discussed in relief request VR-14 and are only identified with an open safety function. Ifthese are containment isolation valves, the licensee should review their closed safety function.
The HPSI pump suction and min-flowline discharge check valves and LPSI pump discharge and suction check valves are not exercised closed. Additionally, the sump discharge check valves, are only exercised open. The licensee should evaluate whether these valves have a safety function to close in order to prevent draining the RWT to the sump.
64
7.0 REFERENCES
J. Stall, FPL, to USNRC, "ThirdTen-Year Interval In-Service-Test Program, Revision 0,"
L-98-5, January 12, 1998.
2.
Administrative Procedure ADM-29.01, Revision 0, "Inservice Testing /ST Program for Pumps and Valves," December 12, 1997.
3.'. Stall, FPL, to USNRC, "Inservice Testing Program, Request for Additional Information," L-98-243, September 21, 1998.
4.
Title 10, Code ofFederal Regulations, Section 50.55a, Codes and Standards.
5.
ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, 1989 Edition.
6.
ASME/ANSIOM-1987, Part 1, "Requirements for Inservice Performance Testing of Nuclear Power Plant Pressure Relief Devices."
- 7. 'SME/ANSI OMa-1988, Part 6, "Inservice Testing ofPumps in Light-Water Reactor Power Plants."
8.
ASME/ANSIOMa-1988, Part 10, "Inservice Testing ofValves in Light-Water Reactor Power Plants."
9.
Standard Review Plan, NUREG 0800, Section 3.9.6, Inservice Testing ofPumps and Valves, Rev. 2, July 1981.
10.
NRC Generic Letter 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," April3, 1989.
11.
Minutes ofthe Public Meetings on Generic Letter 89-04, October 25, 1989.
12.
Supplement to the Minutes ofthe Public Meetings on Generic Letter 89-04, September 26, 1991.
13.
NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants," April 1995.
14.
NUREG/CR-6396, "Examples, Clarifications, and Guidance on Preparing Requests for Relief from Pump and Valve Inservice Testing Requirements," February 1996.
65
15.
Memo to File, "Summary ofPublic Workshops held in NRC Regions on Inspection
~
~
~
~
~
Procedure 73756, 'Inservice Testing ofPumps and Valves,'nd Answers to Panel Questions on Inservice Testing Issues," from J. Colaccino, NRC, July 18, 1997.
16.
Pump Handbook, I.J. Karassik, McGraw HillBook Company, 1'976.
17.
Federal Register, Volume 62, Number 232, Page 63892, "Proposed Rule on Industry Codes and Standards," December 3, 1997.
18.
NRC Generic Letter 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution ofDegraded and Nonconforming Conditions and on Operability," November 7, 1991.
~
19.
J. Stall, FPL, to USNRC, "Inservice Test Program, Relief Request PR-12 Supplement,"
L-98-264, October 9, 1998.
20.
NUREG/CP-0152, Volume 1, "Proceedings ofthe Fourth NRC/ASME Symposium on Valve and Pump Testing," June 1996.
21.
NUREG/CP-0152, Volume 2, "Proceedings ofthe FifthNRC/ASME Symposium on Valve and Pump Testing," July 1998.
22.
NUREG/CP-0123, "Proceeding ofthe Second NRC/ASME Symposium on Pump and Valve Testing," June 1992.
66
Appendix A-Evaluation ofSt. Lucie's Valve Testing Deferral Justifications Item Number Valve Identification Drawing No.
Liccnscc's Justification for Dcfemng Valve Exercising Proposed Altcmatc Testing Evaluation ofLiccnsec's Justification RFl41 Unit I:
SE4141 V2505 Unit2:
V2505 V2524 RCP Seal LcakoffCIVs 2998<478 Sll 2 IA 87706478 Sli 12IA Chemical and Volume Control System "Closing either ofthcsc valves when any ofthe reactor coolant pumps (RCPs) arc in operation would interrupt flowfrom thc RCP seals and result in damage to the pumps'eals.
Thus testing these valves would require the unnecessary shutdown ofall ofthe reactor coolant pumps or installation ofelaborate means to ensure seal leakage is maintained while these valves are closed."
During each rcfucling outage these valves willbe cxcrcised and fail-safc tested closed.
It is impractical to exercise these valves closed quarterly during operation due to thc possibility of damaging thc RCP seals. It is also impractical to test thcsc valves during cold shutdowns because it would require shutting offthe RCPs which could cxtcnd thc cold shutdown period.
Thc altemativc provides for exercising the valves closed and faille testing during refueling outages in accordance with OM Part 10 $4.2.1.2(e).
The licensee should consider establishing a schedule to account for extended cold shutdowns when the RCPs are stopped for a suflicient length of time as discussed in NUREG-1482 Section 3.1.1.4.
Item Number Valve IdentiTication Units I 8c 2:
V2177 V2190 V2191 V2443 V2444 Unit 2 only:
V2526 Boric Acid Makeup Pump Discharge Check Valves (V2177, V2443, and V2444)
Boric Acid Makeup Tank Discharge Check Valve(V2190 and V2526)
RWT Discharge Check Valve (V2191)
Drawing No.
877(46478 SIL 121 A tkB 2998%478 Sh. 121 A 8'r, 121 B Chemical Sc Volume Control System Licensee's Justification for Dcfcrring Valve Exercising "These arc simple check valves with no cxtemal means of exercising or for determining obturator position. Thus, t<<sting these valves in the open direction rcquircs systcin flow. Since there is no convcnicnt recirculation flowpath capable offull-flow(120 gpm) thc only practical flowpath is into thc RCS via thrcc charging pumps. Injection into the RCS results in thc introduction ofhighly concentrated boric acid solution from thc boric acid makeup tanks to thc suction ofthc charging pumps and thence to thc RCS. This would result in the addition ofexcess boron to thc RCS.
Thc rapid insertion ofnegative reactivity would result in a RCS cooldown and de-pressurization which, given a large
<<nough boron additioii, could result in an unscheduled plant trip and a possible safety injection system initiation.
Except for BAMPump Discharge Check Valves, V2443 and V2444, partialctroke exercising prcscnts thc same problems with rcspcct to bomn injection as de full-stroke exercising. V2443 and V2444 can be cxerciscd by recirculating to the BAMtanks, however, there is no flow instrumentation availablc to verify full-strokingofthese valves.
During cold shutdown, thc introduction ofcxccss quantitics ofboric acid into the RCS is undesirable from the aspect of maintaining proper plant chemistry and the inherent difliculties that may be cncountcrcd during thc subsequent startup duc to over-boration ofthc RCS. The waste management system would also bc overburdened by the large amounts ofRCS coolant that would require processing to decrease the boron concentration at startup. Since the boron concentration is normally increased to a limited extent forshutdown margin prior to reaching cold shutdown, a part stroke cxcrcisc ofthcsc valves could bc performed at that time."
Proposed Alternate Testing Each ofthese check valves, except for V2443 and V2444, willbc partial stroke exercised during each cold shutdown.
Valves V2443 and V2444 willbc partial stroke exercised quarterly.
Each ofthese check valves willbc full-stroke exercised during each refueling outage.
Evaluation ofLicensee's Justification It is impractical to fullctroke exercise these check valves (or partial-stroke exercise valves V2177, 2190, 2191 and 2526) open quarterly during operation because itwould result in the addition of highly concentrated boric acid solution to the RCS which could result in a reactor shutdown and a safety injection actuation. It is also impractical to full-stroke thcsc valves during cold shutdowns because thc addition ofboric acid to thc RCS could delay plant staitup.
The altcrnativc provides for partial-stroke exercising quarterly (valves V2443 and V2444) and durin'g cold shutdowns (valves V2177, V2190, V2191, and V2526) and full-stroke exercising all thc valves during rcfucling outagcs in accordance with OM Part 10 $43.2.2(d).
. A-2
Item Number RFJ43 Valve Identification Unit I only:
V3101 Unit2 only:
V3102 Units I &2:
V3103 HPSI Pumps to RWT Minimum Flow Check Valves Drawing No.
8770%478 Sh 130A 2998%478 Sll 130A Safety Injection System Liccnsec's Justification for Defemng Valve Exercising "These arc simple check valves with no external means of cxcrcising or for dctcrmining obtumtor position. Thus, testing thcsc valves in the open direction rcquircs system flow. There is no flowrate instrumentation availablc in the respective lines to verify valve fullstroke cxcrcising as defined by the Generic Letter 8944, Position l.
During refueling, these valves can bc full flowtested and the flowratcs determined.
The flowpath for this test is from the refueling cavity to the RWT via the HPSI pump mini-flowrecirculation linc. Thc flowratc can be calculated by determining thc increase in RWT volume over a measured period oftime. Since this test procedure rcduccs RCS inventory it can only be performed during refueling outagcs with thc reactor head removed, permitting rcfucling cavity water inventory to be pumped to the RWT."
Proposed Altcmate Testing During quarterly pump testing each ofthcsc valves willbe partial-stroke cxcrciscd via recirculation through thc minimum flowtest circuits with no flowmeasurements.
During each refueling outage each ofthcsc valves willbc full-flow tested.
Evaluation ofLicenscc's Justification It is impractical to full-stroke excrcisc thcsc valves quarterly because they arc installed in thc minimum flowlinc from thc HPSI pumps to thc RWTs. Thcrc is no flowinstrumentation installed on these lines. These check valves are partial stroked open quarterly during HPSI pump operation.
The alternative provides for partial-stroke open quarterly and full-flow tested during refueling outages in accordance with OM Part 10
$4.3.2.2(c).
Thc use oflcvcl changes over a period oftime is acceptable, as discussed in NUREG-1482, Section 4.1.2. The instnimcnt adequacy must be adcquatc to demonstrate the valve is open to thc position ncccssary to fulfillits safety function.
Thc test method willbc subject to NRC inspectors'cvicws.
A-3
Item Number Valve Identification Drawing No.
Liccnsce's Justiflcation for Defemng Valve Exercising Proposed Altcmate Testing Evaluation ofLicensee's Justification Units I &2:
V3401 V3410 HPSI Pump Suction Check Valvcs 2998%478 Sll 130A 8770%478 Sll 130A Safety Injection System "These are simple check valves with no cxtcmal means of exercising or for dctcrmining obturator position. Thus, testing these valves in the open direction requires system flow. Thc only flowpath available during normal power operation is recirculating RWT water via the LPSI mini-flowline that results in only partial stroke exercising. Full stroke exercising ofthcsc valves to the open position requires injection into thc RCS via the LPSI pumps.
During plant operation this is precluded because thc LPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. Atcold shutdown, thcrc are several issues that make exercising impractical, including:
I. Thcrc is no available reservoir in the reactor coolant system to accept the injected water and thc shutdown cooling system cannot provide suflibient letdown flow back to thc RWT to accommodate full design flowfrom the RWT while maintaining the necessary core cooling function;
- 2. The excessive quantities ofboric acid injected during such testing would seriously hamper thc ensuing startup; and
- 3. During cold shutdown conditions, operation ofthe HPSI pumps is restricted to preclude RCS system prcssure transients that could result in exceeding the prcssurc-temperature limits specified in the St. Lucie Technical Specifications, Section 3.4.9.
These: valves willbc partial-flow cxcrciscd during quarterly testing of the HPSI pumps via the minimum flowcircuit and full-flowcxcrciscd during each refueling outage.
It is impractical to full-stroke exercise thcsc valves to the open position during operation because this would necessitate operation of thc HPSI pumps which cannot overcome the primary system prcssure to operate. Operation during cold shutdowns is also impractical because it would result in thc addition ofhigh quantities of boric acid into the RCS delaying restart.
The altcmative provides for partial stroke exercising quarterly, and full-flowexercising during refueling outages in accordance with OM Part 10 0 4.3.2.2(d).
Thc subject valves arc associated with the HPSI pumps. However, thc justification refers to thc LPSI pumps. The liccnscc should review thc justification, and revise it as necdcd.
Therefore, thc only practical opportunity for full-flow testing these valves is during refueling outagcs when water from the RWT is used to fillthc refueling cavity."
Item Number Valve Identification Drawing No.
Licensee's Justification for Dcfcrring Valve Exercising Proposed Alternate Testing Evaluation ofLicensee's Justification RFJ45 Units I dc 2:
V34I4 V3427 HPSI Pump Discharge Check Valves 2998%478 Sli I30A 877&6-078 Sli 130A Safety Injection System "These are simple check valves with no cxtcmal means of exercising or for dctcrmining obturator position. Thus, testing these valves in the open direction requires system flow. Full stroke exercising ofthese valves to thc open position requires injection into the RCS via the HPSI pumps. During plant operation this is precluded bccausc the HPSI pumps cannot dcvclop suflicient discharge prcssure to overcome primary system prcssure. Atcold shutdown, there are scvcral issues that make exercising impractical, including:
I.There is no available reservoir in the reactor coolant system to accept thc injected water and the shutdown cooling system cannot provide sufficient letdown flowback to thc RWT to accomrnodatc fulldesign flowfrom thc RWT while maintaining the necessary core cooling function; 2.The excessive quantities ofboric acid injected during such testing would seriously hamper thc ensuing startup; and 3.During cold shutdown conditions, operation ofthe HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding thc pressurc-temperaturc limits (LTOP) specified in the St. Lucie Tcchnical Specifications, Section 3.4.9.
Partial flowexercising ofthcsc valves is performed whenever its associated HPSI pump is used to relilla SIT.
Thc acceptable SIT Icvcl and pressure bands specilicd by thc Technical Specifications arc very narrow and the SIT's arc only refilled on an as-needed basis; therefore, the partial flowtest cannot readily bc incorporated into a periodic test.
Alternate flowpaths for partial flowtests arc limited by the design prcssure ofthe associated piping."
These valves willbc partwtrokc exercised open while rcfillinga SIT.
Thc SIT tanks willonly be refilled as rcquircd to maintain them within thc Tcchnical Specification limits.
ASIT willnot ncccssarily bc filled for the sole purpose ofpartctroke exercising any one ofthese check valves.
Each ofthese valves willbc verified closed quarterly, part-stroke cxcrcised during cold shutdowns and full-stroke exercised open during each refueling outage.
It is impractical to cxcrcise these valves quarterly during operation because it would require operation ofthe HPSI pumps which cannot ovcrcomc thc primary system pressure.
Exercising during cold shutdowns is also impractical bccausc operation ofthc HPSI pumps would result in the injection ofconcentrated boric acid to thc RCS which could delay plant operation. In addition thc operation ofthc HPSI pumps arc restricted to preclude plant LTOP limits.
Thc liccnscc states in the Altcma!c Testing Section ofthe justification, howcvcr, that the valves willbc partial-stroke exercised each cold shutdown. In addition, thcsc valves are also partialwtroked open during refillinga safety injection tank as needed during operation.
The licenscc should review the Justification which states that exercising these valves is impractical during cold shutdowns and thc proposed alternate testing to partial stroke thcsc valves during cold shutdowns, and revise as necessary.
A-5
Item Number Valve Identification Drawing No.
Licensee's Justification for Deferring Valve Exercising Proposed Altcmatc Testing Evaluation ofLiccnsec's Justification RFJ46 Units I 8'c 2:
V07000 V07001 LPSI Pumps Suction Check Valves 2998%478 Sli 130B 8770%478 SII 130B Safety Injection System "These are simple check valves with no cxtcmal means of exercising or for determining obturator position. Thus, testing these valves in the open direction rcquircs system flow. The only flowpath available during normal power operation is recirculating RWT water via thc LPSI mini-flowline that results in only partial stroke exercising. Full stroke exercising ofthcsc valves to the open position requires injection into the RCS via the LPSI pumps.
During plant operation this is prccludcd bccausc the LPSI pumps cannot dcvclop suflicicnt discharge prcssure to overcome primary system pressure. Atcold shutdown, thcrc is no available reservoir in thc reactor coolant system to accept the injected water and thc shutdown cooling system cannot provide suflicicnt letdown flowback to the RWT to accommodate full design flowfrom the RWT.
while maintaining the ncccssary core cooling function.
Also, the excessive quantities ofboric acid injected during such testing would seriously hamper thc ensuing startup.
Therefore, the only practical opportunity for full-flow testing thcsc valves is during refueling outagcs when water fmm the RWT is used to fillthc refueling cavity."
These valves willbc partial-flow exercised during quarterly testing of the LPSI pumps via the minimum flowcircuit and full-flowexercised during each refueling outage.
lt is impractical to full-stroke exercise these valves open during operation because itwould rcquirc thc operation ofthe LPSI pumps and injection into thc RCS. During plant operation thc LPSI pumps cannot develop sufficien discharge pressure rcquircd to discharge to thc RCS. Operation during cold shutdowns is also impractical since it would result in the injection of concentrated boric acid into the RCS which could delay plant startup.
~
Thc alternative provides for partial
. stroke exercising quarterly and full-stroke open testing during refueling outagcs in accordance with OM Part 10 $4.3.2.2(d).
A-6
Item Number Valve Identification Drawing No.
Liccnscc's Justification for Deferring Valve Exercising Proposed Alternate Testing Evaluation ofLicenscc's Justification RFJ47 Units I Ec 2:
V3104 V3105 LPSI Pumps Discharge Minimum Flow Check Valves 2998%478 Sli 130B 8770%478 Sll 130B Safety Injection System "These are simple check valves with no cxtemal means of cxcrcising or for determining obturator position. Thus, testing these valves in thc open direction rcquircs system flow. There is no flowrate instrumentation available in the rcspcctivc minimum flowlines to verifyvalve fullstroke cxcrcising as dclincd by thc Gcncric Letter 8944, Position
- l. Due to thc installation offloworifices in these lines, thc maximum flowvelocity achievable is approximately 10 ft/sec. which is considerably less than thc 32.8 ftlscc.
needed to fullyopen thc valves. For this reason thc usc of non-intrusive techniques for verifyingvalve operability is impractical.
During rcfucling these valves can be full-flowtested and the flowratcs determined. Thc flowpath for this test is from thc refueling cavity to the RWT via the LPSI pump mini-flow recirculation line. The flowrate can be calculated by determining the increase in RWT volume over a measured period oftime. Since this test procedure reduces RCS inventory it can only bc performed during refueling outages-with the reactor head removed, permitting refueling cavity water inventory to be pumped to the RWT."
During quarterly pump testing each ofthcsc valves willbc partialetroke cxcrcised via recirculation through the minimum flowtest circuits with no flowmeasuremcnts.
During each rcfucling outage each ofthese valves willbc full-flow tcstcd.
It is impractical to fullctrokc exercise these valves open quarterly during both operation and cold shutdowns because there is no flow instrumentation installed on thcsc minimum flow lines from the LPSI pumps to thc RWTs.
Thc altemativc provides for partial-stroking these valves open quarterly during LPSI minimum flowtesting and fullwtroketesting during refueling outagcs in accordance withOM Part 10'$4.3.2.2(d).
Thc usc oflevel changes over a period oftime is acceptable as discussed in NUREG-1482, Section 4.1.2. The instnuncnt accuracy must be adequate to demonstrate the valve is open to the position necessary forthc check valve to fulfillits safety function. Thc test method willbc subject to NRC inspectors'cvicws.
A-7
Item Number Valve Identification Drawing No.
Licensee's Justification for Deferring Valve Exercising Proposed Altcmate Testing Evaluation ofLicensee's Justification RFJ4}8 Units I A2:
V3113 V3133 V3143 Unit I only:
V3123 Unit2 only:
V3766 Pressure Isolation Check Valves 2998-G 478 Sh 131 8770%478 S}i 13 IA Safety Injection System "These arc simple check valves with no cxtcmal means of cxcrcising or for determining obturator position, thus, testing these valves in the open direction requires system flow. Full stroke cxcrcising ofth<<sc valves to the open position requires injection into the RCS via thc HPSI pumps. During plant operation this is precluded because thc HPSI pumps cannot dcvclop suflicicnt discharge pressure to ovcrcomc primary system prcssure. Atcold shutdown, thcrc are several issues that make exercising impractical, including:
I. There is no available reservoir in the reactor coolant system to accept the injected water and the shutdown cooling system cannot provide suflicient letdown flowback to the RWT to accommodate full design flowfrom thc RWT while maintaining thc necessary core cooling function;
- 2. The excessive quantitics ofboric acid injected during such testing would seriously hamper thc ensuing startup; and These valves willbc part-stroke excrciscd open while rcfillinga SIT.
The SIT tanks willonly bc refilled as rcquircd to maintain them within thc Tcchnical Specification limits.
No SIT willbe filledfor thc sole purpose ofpartwtroke cxcrcising any one ofthese check valves.
Each ofthese valves willbe full-strokc cxcrciscd (open) during each refueling outage.
It is impractical to full-stroke cxcrcise thcsc valves open quarterly because it would require thc operation ofthe HPSI pumps, which can not overcome system pressure to operate.
Full-stroke exercising during cold shutdowns is also impractical because itwould result in thc addition ofconcentrated boric acid to thc RCS, possible delaying plant restart.
Thc alternative provides for partial-stroke exercising the valves open when thc SITs arc refilled, and full-strokc exercising during refueling outages in accordances with OM Part 10 $4.3.2.2(c).
- 3. During cold shutdown conditions, operation ofthe HPSI pumps is rcstrictcd to preclude RCS system prcssure transients that could result in excccding the pressurc-tcmpcraturc limits (LTOP) specified in thc St. Lucic Technical Specifications, Section 3.4-9.
Partial flowexercising ofthcsc valves is performed whenever its associated HPSI pump is used to refilla SIT.
The acccptablc SIT level and prcssure bands specified by thc Tcchnical Specifications arc very nanow and the SIT's are only refilled on an as-necdcd basis; therefore, the partial flowtest cannot readily be incorporated into a periodic test. Altcmate flow paths for partial flowtests arc limited by thc design prcssure ofthe associated piping."
A-8
Item Number Valve Identification Drawing No.
Licensee's Justilication for Dcfcrring Valve Exercising Proposed Alternate Testing Evaluation ofLiccnsec's Justification RFJ49 Unit2 only:
V3522 V3547 HPSI Pumps Discharge Check Valves 2998%478 SII 130A Safety Injection system "Thcsc arc simple check valves with no cxtemal means of exercising or for determining obturator position. Thus, testing thcsc valves in the open direction requires system flow. Full stroke exercising ofthcsc valves to thc open position rcquircs injection into the RCS via thc HPSI'umps.
During plant operation this is precluded because the HPSI pumps can develop suflicient discharge prcssure to overcome primary system prcssure. Atcold shutdown, there are several issues that make exercising impractical, including:
I. There is no available reservoir in thc reactor coolant system to accept the injected water and the shutdown cooling system cannot provide suflicient letdown flowback to the RWT to accommodate full design flowfrom the RWT while maintaining thc necessary core cooling function;
- 2. Thc excessive quantitics ofboric acid injected during such testing would seriously hamper thc ensuing startup; and Each ofthese check valves willbe partial-stroke exercised during each cold shutdown and full-stroke cxerciscd during each refueling outage.
It is impractical to fullctrokc and partialetroke exercise these valves open during operation because it would require flowfrom HPSI pumps 2A and B, which cannot dcvclop sufflcient discharge pressure to ovcrcomc system prcssure.
Thc liccnsec has stated that full-stroke exercising during cold shutdowns is also impractical because itwould result in thc addition ofconcentrated boric acid to the RCS possibly delaying restart The liccnsce has stated in thc Altematc Testing Section ofthc justification, however, that these valves willbc partial stroke cxerciscd during each cold shutdown.
- 3. During cold shutdown conditions, operation ofthe HPSI puinps is restricted to preclude RCS system prcssure transients that could result in cxcceding thc prcssurc-tcmpcrature limits (LTOP) specified in the St. Lucic Technical Specifications, Section 3.4-9."
Thc lieenscc should rcvicw the Dcfcrral Justification which describes several issues which make cold shutdown excrcrsmg impractical, and revise as necessary.
A-9
Item Number Valve Identifleation Drawing No.
Licensee's Justiflcation for Dcfcrring Valve Exercising Proposed Alternate Testing Evaluation ofLicensee's Justification RFJ-10 Unit2 only:
V3524 V3525 V3526 V3527 HPSI Pump PIVs 2998%478 Sh 131 Safety injection System "These are simple cheek valves with no cxtcmal means of exercising or for determining obturator position, thus, testing these valves in thc open direction requires system flow. Full stroke cxcrcising ofthese valves would require operating a high prcssure safety injection (HPSI) pump at nominal accident flowrate and injecting into the reactor coolant system. Atpower operation this is not possible because thc HPSI pumps cannot develop suflicicnt discharge prcssure to overcome reactor coolant systein prcssure.
During cold shutdown conditions, fullflow operation ofthc HPSI pumps is restricted to prccludc RCS system pressure transients that could result in cxcccding thc pressure temperature limitsspecified in the Tcchnical Specifications, Section 3.4.9.
Partial-stroke exercising ofcheck valves V3524 and V3526 quarterly can not be performed by using the SIT to RWT drain line. This method requires that the containmcnt isolation valves, one ofthem a manual valve, bc opened to complctc thc flowpath. This would constitute a brcach of containment integrity, as defined in Technical Specifications 3.6. I - I, and therefore usc ofthis flowpath is prccludcd in Modes I, 2, 3 and 4."
Each ofthese check valves willbc" partial-stroke cxcrciscd during each cold shutdown and full-stroke cxerciscd during each refueling oiitagc.
It is impractical to full-stroke cxcrcisc thcsc valves open quarterly bccausc itwould rcquirc operation ofthe HPSI pumps which cannot develop suflicient discharge pressure to overcome the RCS pressure. It is also impractical to cxcrcisc these valves during cold shutdowns duc to the possibility of prcssure transients which could excccd plant LTOP limits and result in equipment damage.
Thc altemativc to partial stroke open thcsc valves during cold shutdowns, and to full-stroke open during refueling outages is in accordance withOM Part IO $
4.3.2.2(d).
Thc liccnscc has explained why valves V3524 and V3526 cannot be partial stroked open quarterly. Thc licensee should also include an explanation for valves V3525 and V3527.
RFJ-I I Unit I only:
V09303 AFW Pump Discharge Check Valve 8770%480 S}l4 Condensate and Feed water System "This is a simple check valve with no external means of exercising or for determining obturator position, thus, testing it in the open direction requires system flow. Thcrc is no flowrate instrumentation available to verify valve full-stroke exercising ofthis valve as required by thc Generic Letter 8944, Position I.
Note that this valve is significantly different from the other two pump recirculation valves and, thus, it is called out for individual inspection and not included in the other group of valves."
During each refueling outage this valve willbe disassembled, inspected, and manually stroked to verifyoperability, It is impractical to exercise this valve open with flowbecause it is installed on thc stcam driven AFW pump IC minimum flowlinc with no flowinstrumentation or position indication.
Thc altemativc is in accordance with OM Part IO $ 4.3.2.4(c).
A-10
Item Number Valve Identification Drawing No.
Liccnsec's Justification for Deferring Valve Exercising Proposed Altcmatc Testing Evaluation ofLiccnsec's Justification RFJ-12 RFJ-13 RFJ-14 Unit2 only:
V12806 Unit I AFW Pump Suction Check Valve Unit I only:
VI2507 AFW Pump Bearing Cooling Water Discharge Check Valve Units 1852:
VI5328 Primary Water Supply CIV 2998%480 SII 2B Feed water and Con densatc Systems 877M'80 Sll 4 Fccdwater and Condcnsatc Systems 2998%484 Sll I 8770%484 Sll IC Domestic and Makc-Up Water Systems "This is a simple check valve with no cxtcmal means of exercising or for determining obturator position, thus, testing it in thc open direction requires system flow.
Cycling this valve is unacceptablc during plant operation as itwouldjeopardize the Unit I and Unit2 Auxiliary Fcedwater Pumps when performing a flowtest. To pass flowthrough this valve rcquircs aligning thc pumps'uction piping to thc nonwlasscd and non-seismic cross connect piping and components.
Thus, a crcdiblc single failure of the nonwlasscd piping could disable all (both units) auxiliary fccdwater pumps. Cycling ofthis valve during Unit2 shutdowns is not practicable since it would require Unit I also bc shutdown to perform thc testing."
"This is a simple check valves with no external means of exercising or for dctcrmining obturator position, thus, testing it in the open direction requires system flow. There is no flowratc instrumentation availablc to verifyvalve full-stroke exercising ofthis valve as rcquircd by the Generic Letter 8944, Position I."
"This is a simple check valve with no cxtemal means of exercising or for dctennining obturator position, thus the only practical means ofverifyingclosure is by performing a leaktcst or backflow test. This would require a considerable.
effort, including entry into the containment building. Due to access this is impractical during plant operation and would bc an unreasonable burden on the plant staff to perform during cold shutdowns."
During each Unit I refueling outage this valve willbc full-stroke exercised.
Dunng each rcfuchng outage this valve willbe disassembled, inspected, and manually stroked to verifyoperability.
During each refueling outage this.
valve willbe verified to close.
It is impractical to fullcuoke or partialctrokc cxcrcisc this valve open quarterly during operation bccausc it would interrupt flowto both units'FW pumps.
Thc altemativc provides for full-strokc exercising the valve open during Unit I refueling outagcs in accordance with OM Part 10 $
4.3.2.2(c).
It is impractical to full-stroke exercise this valve open with flow because there is no instrumentation installed.
Thc altcmativc is in accordance with OM Part 10 $ 43.2.4(c).
However, as discussed in PR42, the turbine driven AFW pump is minimum fiowtested quarterly and full flowtested during cold shutdowns.
The licenscc should invcstigatc why partial stroking is not possible during the quarterly and cold shutdown testing.
It is impractical to cxercisc these valves closed quarterly or during cold shutdowns duc to thc need to set up test equipment The altemativc is m accordance with OM Part 10 $ 4.3.2.2(c).
Item Number Valve Idcntilication Drawing No.
Licensee's Justification for Dcfcrring Valve Exercising Proposed Alternate Testing Evaluation ofLiccnscc's Justiiflication RFJ-15 RFJ-I6 Units I dr, 2:
VI8195 Instrument AirCIV Units I 8'c 2:
V07129 V07 143 Containment Spray Pump Discharge Check Valves 2998%485 S}i2A 8770%485 Sli 2A Instrument AirSystem 2998%488 Sh I
$77(Hi488 Sh I Contain-mcnt Spray System "This is a simple check valve with no external means of exercising or for determining obturator position, thus the only practical means ofverifying closure is by performing a Icaktcst or backflow test. This would require a considcrablc effort, including entry into the containmcnt building and securing all instrument air to thc containmenL Due to access limitations and the undesirability ofisolating the air supply for critical cquipmcnt, this is impractical during plant operation and would be an unreasonable burden on the plant staff to perform during cold shutdowns."
"These arc simple check valves with no cxtemal means of exercising or for determining obturator position. Thus, testing these valves in the open direction rcquircs system flow. Fullwtroke exercising ofthcsc valves would require operating each containment spray pump at nominal accident flowrate. Since exercising thcsc valves through th>>
normal containment spray flowpath would result in spraying down the containment, thc only practical flowpath available forsuch a test rcquircs pumping water from the refueling water tank (RWT) to the RCS via the shutdown cooling loops. Atcold shutdown, the shutdown cooling system cannot provide suflicient letdown flowto thc RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function."
During each refueling outage this valve willbc verified to close.
Each ofthcsc valves willbc partial-stroke cxcrcised quarterly in conjunction with testing ofthe containinent spray pumps via the minimum flowtest linc.
During each refueling outage, each valve willbc cxereiscd at least once to demonstrated full-stroke capability.
It is impractical to cxercisc these valves closed quart<<rly or during cold shutdowns duc to thc need to sct up test equipment.
Thc alternative is in accordance with OM Part 10 $ 4.3.2.2(c).
It is impractical to fullwtroke exercise these valves open quarterly or during cold shutdowns bccausc it would result in spraying the containment building resulting in equipment damage and operational transients.
The altcmative provides for partial stroking quarterly and fullctrokc exercising during refueling outages in accordance withOM Part 10 $
4.3.2.2(d).
A-12
Item Number RFJ-17 RFJ-18 Valve Identification Unit I only:
V07256 V07258 Containment Spray Pump Suction Header Check Valves Unit2 Only:
V07256 V07258 Hydrazine Pumps Discharge Check Valves Drawing No.
877~488 Sll I Contain-ment Spray 299W3488 Sh I Contain-ment Spray Licensee's Justilication for Deferring Valve Exercising "These arc simple check valves with no cxtcmal means of exercising or for dctcrmining obturator position, thus, testing these valves in the open direction requires system flow. Testing these valves during normal plant operation in conjunction with testing ofthe containment spray pumps would contaminate the containment spray piping with sodium hydroxide. The only practical means oftesting these valves requires connection ofa source of demincralizcd water at the tank discharge then directing water into thc containmcnt spray piping. This places both containmcnt spray trains out ofservice and would entail a somewhat complex procedure and system re-alignment that is considered outside the scope ofwork that is typically performed during operations or a routine cold shutdown period, thus, such a test is impractical during periods other than reactor rcfucling outages."
"These are simple check valves with no cxtcmal means of exercising or for determining obturator position, thus, testing thcsc valves in the open direction rcquircs system flow. Testing thcsc valves during normal plant power operation in conjunction with testing ofthc hydrazine pumps would contaminate the containment spray piping with hydrazine. In addition, any mode oftesting requires draining signilicant portions ofthe containment spray system. This entails a somewhat coinplex procedure and system re-aligninent that is considered outside the scope of work that is typically performed during operations or a routine cold shutdown period, thus, such a test is impractical during periods other than reactor refueling outagcs.
In addition to the physical system constraints, frequent perforinance ofthe above mentioned testing is undesirable based on the personnel hazards associated with testing.
Hydrazine is a dangerous, highly flammable liquid with cumulative toxic cffccts when absorbed through thc skin, inhaled or ingested. It has also been identified as a known carcinogen.
For this reason, it is proposed to perform this testing only during refuel outages."
Proposed Alternate Testing During each refueling outage both ofthese valves willbc full-stroke exercised (open and closed).
During each refueling outage both ofthese valves willbc full-stroke exercised (open).
Evaluation ofLicensee's Justilication It is impractical to cxcrcise these valves open quarterly during operation or at cold shutdowns since itwould require pumping NaOH through the containmcnt spray piping thereby contaminating thc system. It is also impractical to use demineralized water due to the rcquircd test sct up.
The altemativc to full-stroke these valves to thc open position during rcfucling outages is in accordance with OM Part 10 $ 4.3.2.2(c).
Thc licensee has not, however, provided a justification for dcfcrring verification ofclosure for thcsc normally closed valves.
It is impractical to exercise these valves open quarterly during operation bccausc itwould require pumping hydrazine through the containment spray piping. It is also impractical to test thcsc valves during cold shutdowns because of thc need to drain the containmcnt spray piping and system realignment which could delay plant operation.
The alternative to exercise thc valves open during refueling outages is m accordance with OM Part 10 $ 4.3.2.2(e).
Item Number Valve Identilication Drawing No.
Liccnscc's Justification for Defcmng Valve Exercising Proposed Altcmate Testing Evaluation ofLiccnsce's Justification RFJ-19 RFJ-20 Units I dr,2:
V271 01 V27102 Sampling System CIVs Units I dt,2 V2118 VCTto Reactor Coolant Pump Suction Check Valve 2998%492 Sll I 877(hG492 Sli I Miscellane-ous Sampling System 2998%478 Sli 121A 8770-G 478 SII 12 IA Chemical and Volume Control System "Thcsc arc simple check valves with no external means of exercising or for determining obturator position, thus the only practical means ofverifying closure is by performing a leaktest or backflow test. This would rcquirc a considcrablc effort, including entry into the containmcnt building and breaking the sampling linc connections. This is impractical during plant operation and would bc an unreasonable burden on the plant staff to perform at cold shutdown."
"These arc simple check valves with no external means of verifying closure, thus closure testing ofthese valves rcquircs a backflow test. Performance ofsuch test involves isolation ofthe normal charging flowpath and pressurization ofthc charging pump suction header using thc boric acid pumps. Valve closure is verified by confirming no significant transfer ofwater from thc BAM tank(s) to thc VCT. To make this test meaningful and.
conclusive all sources ofwater into the VCT must bc isolated, including the RCP seal Icakofflinc. This, in turn, requires securing the RCPs or providing extraordinary means ofaccommodating seal leakoffwhich must be maintained whenever a reactor coolant pump is in operation."
During each refueling outage these valves willbe vcrificd to close.
During each refueling outage these valves willbc exercised closed.
It is impractical to exercise these valves closed quarterly or during cold shutdowns due to the nccd to sct up test equipment.
The altemativc is in accordance with OM Patt 10 $ 4.3.2.2(e).
It is impractical to cxcrcisc thcsc valves closed quarterly during operation duc to thc possibility of damaging thc RCP seals. It is also impractical to test these valves during cold shutdowns because it would require shutting offthc RCPs which could extend the cold shutdown period.
Thc alternative provides for exercising the valves closed during refueling outages in accordance with OM Part 10 $4.3.2.2(c).
The liccnscc should consider establishing a schedule to account for extended cold shutdown outages when thc RCPs arc stopped for a sufficient length oftime as discussed in NUREG-1482 Section 3.1.1.4.
A-14
Item Number Valve Drawing Liccnscc's Justification for Deferring Valve Exercising Proposed Altematc Testing Identification No.
COLDSHUTDOJYHJUST/FICA 7'IONS Evaluation ofLicensee's Justification REACTOR COOLANTSYSTEM CSJ-Ul-RC41 CSJ-U I-RC42 (CSJ-U2-RC41)
Unit I only:
PCV-I IOOE PCV-1100F-Pressurizer Spray Control Valves Unit I:
V1402 8!ld V1404 Unit2:
V-1474 and V-1475 PORVs 8770%478 Sh 110A Reactor Coolant System 87704-078, Sll I IOA 2998%478 Sh 108 Reactor Coolant System
'During normal power operations, these two valves are used to control RCS prcssure by automatically throttling thc spray flowinto the pressurizer.
Fully opening these valves, in preparation for timing thc stroke closed test, would have an immediate negative effect on RCS pressure.
The increased spray flowwould condense part ofthe steam bubble inside the pressurizer, causing pressurizer prcssure, and therefore RCS prcssure, to dmp rapidly.
"Duc to the potential impact ofthe resulting transient should one ofthese valves open prematurely or stick in the open position, it is considered imprudent to cycle them during plant operation with thc reactor coolant system at fulloperating pressure."
Per thc Unit I Valve Table, these valves arc exercised closed and tested to their fail-safe position during cold shutdowns.
Pcr the Unit I and Unit 2 Valve Tables, these valves are exercised open during cold shutdowns.
It is impractical to partial-stroke or full-stroke cxcrcisc these valves open or test thc valves to the fail-closcd position quarterly because of thc resulting RCS transients.
The altcmativc provides full-stroke cxcrcising to thc closed position in accordance with OM Part 10, $
42.1.2(c).
As discussed in Generic Letter 90-06, testing ofthe PORVs should not be performed during power operation due to the risk associated with challenging these valves in this condition. Therefore, it is impractical to exercise these valves open quarterly.
Thc altcmativc provides full-stroke cxcrcising during cold shutdowns in accordance with OM Part 10 $
42.1.2(c).
A-15
Item Number Valve Identification Drawing No.
Licenscc's Justification for Dcfcrring Valve Exercising Proposed Alternate Testing Evaluation ofLiccnsec's Justilication CS1-U I-RC43 (CS1-U2-RC42)
Unit I:
V1441 thru VI446 and VI449 Unit 2:
V-1460 thru V-1466 Reactor Coolant System Vents 877&6478 Sh IIOA 2998%478 Sli 107 Reactor Coolant System Units I and 2: "These valves arc administratively controlled in thc kcylockcd closed position with the power supply disconnected to prcvcnt inadvcrtcnt operation. Since thcsc are reactor coolant system boundary valves, failure ofa valve to close or significant leakage followingclosure can result in loss ofcoolant in excess ofthe limits imposed by thc Tcchnical Specification leading to a plant shutdown.
Furthermore, ifa valve were to fail open or valve indication to fail to show the valve returned to the fullyclosed position followingcxcrcising, prudent plant operation would likelyresult in a plant shutdown."
Unit I only: "Note also that Technical Specification 3.4.10
.requires thcsc valves to be closed during operation.
Thisjustification agrees with the guidelines provided in NUREG-I482, Paragraph 3.1.1."
Pcr thc Unit I and 2 Valve Tables, thcsc valves arc cxerciscd open during cold shutdowns.
It is impractical to cxcrcisc thcsc valves open quarterly bccausc testing during power operation could jeopardize the integrity ofthe RCS pressure boundary.
Thc alternative provides fuilctroke exercising to the open position during cold shutdowns in accordance with OM Part 10, $
4.2.1.2(c).
OLUMECONTR CHEMICALANDV OL SYSTEM CSJ-U l<H41 (CSJ-U2CH4l)
Unit I:
V2515 aild V2516 Unit2:
V2522 Letdown Linc Containment Isolation Valves 8770%478 Sll 120B 2998%478 Sli 120 Chemical dr, Volume Control System "Closing this valve during operation isolates thc letdown linc from the RCS and would result in undesirablc pressurizer level transients with the potential for a plant trip. Ifa valve failed to reopen, then an cxpeditcd plant shutdown would bc required."
Pcr thc Unit I and Unit2 Valve Tables, these valves are exercised closed and tcstcd to thc faille position during cold shutdowns.
It is impractical to partial-stroke or full-stroke exercise these valves closed or test to the failwloscd position quarterly because ofthe resulting RCS transients and potential for a plant trip.
Thc alternative provides full-stroke exercising to thc closed position during cold shutdowns in accordance with OM Part 10, $
4.2.1.2(c).
CSJ-U I<H42 (CSJ-U24H42)
Units I and 2:
SE4243and SE4244 Auxiliary Pressurizer Spray Valves 8770%478 Sh 120B 2998%-078 Sll 122 Chemical dr, Volume'ontrol System "Opening either ofthese valves (or failure in the open position) during plant operation would cause an RCS prcssure transient that could potentially adversely affect plant safety and lead to a plant trip. In addition, the prcssurizcr spray piping and nozzle would be subjected to undcsirablc thermal shock."
Pcr thc Unit I and Unit 2 Valve Tables, these valves arc cxcrcised open and closed and tested to their fail-safe position during cold shutdowns.
It is impractical to exercise thcsc valves quarterly bccausc ofthe resulting RCS pressure transient and thc potential for a plant trip.
Thc alternative provides full-stoke exercising to the open and closed positions at cold shutdowns in accordance with OM Part 10, $
4.2.1.2(c).
Item Number CSJ-Ul&H43 (CSJ-U2%H43)
CSJ-UIXH44 (CSJ-U2CH44)
CSJ-U2%H45 Valve Identification Units I and 2:
V243I Auxiliary Pressurizer Spray Check Valve Units I and 2:
V2501 Volume Control Tank Outlet Valve Unit 2 only:
V2523 Charging Line Isolation Valve Drawing No.
8770%478 Sh 1208 29984-078, Sh 122, Rcv.
I6 Chemical tk Volume Control System 8770%478 Sh 121 A 2998~78 Sh 121A Chemical dr, Voluine Control System 2998%478 Sh 122 Chemical 4 Volume Control System Licensee's Justilication for Deferring Valve Exercising "In order to test this valve, either SE4243 or SE4244 must be opened.
Opening cithcr ofthcsc valves (or failure in thc open position) during plant operation would cause an RCS prcssure transient that could potentially adversely alfcct plant safety and lead to a plant trip. In addition, thc prcssurizcr spray piping and nozzle would be subjected to undcsirablc thermal shock."
"Closing this valve during operation ofa charging pump would isolate the VCT from the charging pump suctiori header with the potential for damaging any operating.
charging pump. This would cffectivcly intenupt the liowof charging water flowto the RCS with the potential ofan RCS transient and plant trip."
"Closing this valve during operation isolates the charging pumps from thc RCS and would result in undcsirablc pressurizer Icvcl transients with the potential for a plant trip and potential damage to the charging pumps. Ifthe valve failed to reopen, then an expcditcd plant shutdown would be required."
Proposed Altcmatc Testing Pcr the Unit I and Unit 2 Valve Tables, this check valve is full-stroke cxcrciscd open during cold shutdowns.
Pcr the Unit I and Unit 2 Valve Tables, this valve is exercised open and closed during cold shutdowns.
Pcr the Unit 2 Valve Table, this valve is cxcrcised closed during cold shutdowns.
Evaluation ofLiccnscc's Justilication It is impractical to partial-stroke or fullwtrokeexercise this valve to the open position quarterly bccausc of the resulting RCS pressure transient and the potential for a plant trip.
The altemativc provides fuil<troke exercising to thc open position at cold shutdowns in accordance with OM Part 10, $ 4.3.2.2(c).
It is impractical to exercise this valve quarterly because ofpotential damage to the charging pumps.
The altcmativc provides full-stroke cxcrcising to both the open and closed positions during cold shutdowns in accordance with OM Part 10, $ 42.1.2(c).
It is impractical to cxcrcisc this valve quarterly bccausc ofthc resulting pressurizer transients and thc potential for a plant trip and damage to thc charging pumps.
Thc altcmativc provides fullctroke
. exercising to the open position during cold shutdowns in accordance with OM Part 10, $
4.2.12(c).
A-17
Item Number Valve Drawing Licensee's Justification forDeferring Va!vc Exercising Proposed Alternate Testing Identification No.
Evaluation ofLiccnsec's Justification SAFETY INJECTION/ RESIDUALHEATREMOVALSYSTEM CSJ-U2-SI41 CSJ-UI4141 (CSJ>>U24142)
Unit2 only:
V3101 Safety Injection Supply to Volume Control Tank Check Yalvc Units I and 2:
Y3106 and V3107 LPSI Pump Discharge Check Yalves 2998%478 Sli 130B Safety Injection 877(hG478 Sh 130B 2998%478 SIL 130B Safety Injection This is a simple check valve with no cxtemal means of exercising nor for determining disc position, thus the only practical way ofverifying opening is by means ofa forward flowtest. Such a test requires partial draining ofa SIT to the YCT. During such a test, ifthe isolation valves were to fail open for any reason, thc SIT svould bc drained below the Technical Specification limits and thc reactor coolant system over-borated to the extent that a plant shutdown would result."
During normal plant operation, the LPSI Pumps cannot dcvclop sufficient discharge pressure to pump through thcsc valves to the RCS and exercise them in the open direction."
Additionallyfor Unit 1: " The only other test flowpath available is through the shutdown cooling line recirculating to the RWT. This would require opening valves HCY-3657, V3460, and Y3459. With these valves open, both trains ofthe LPSI subsystem would be considered to be inoperable, therefore this testing scheme is unacceptable.
Per thc Unit2 Valve Table, this valve is exercised to the open position during cold shutdowns.
Pcr the Unit I and Unit2 Yalvc Tables, these check valves are exercised opcn during cold shutdowns.
It is impractical to partia}-stroke or full-stroke exercise this valve open quarterly because ofa possible plant shutdown ifthe isolation valves were to fail open during such a test.
The a!temative provides full-stroke exercising to thc open position during cold shutdowns in accordance vvithOMPatt 10 $
4.32.2(c).
It is impractical to full-stroke exercise the valves open quarterly due to insufficient pump discharge head.
The alternative provides for full-stroke exercising to the open position during cold shutdowns in accordance withOM Part 10, g 4.3.2.2(b).
A-18
Item Number Valve Identification Drawing No.
Licensee's Justification forDcfcmng Valve Exercising Proposed Alternate Testing Evaluation ofLicensee's Justification CSJ-Ul-SI-02 Unit I only:
Y3659 and V3660 LPSI Pump Discharge Minimum Flow/Recirc-ulation Line Isolation Valves 8770%478 Sl) 130B Safety Injection "Failure ofeither ofthese valves in the closed position during testing willrender all safety injection pumps inoperable due to the high probability ofdamage should these pumps be started and operated without suflicicnt flow for cooling ofpump internal components."
Per the Unit I Valve Table, these valves are exercised closed during cold shutdowns.
It is impractical to exercise these valves closed quarterly duc to potential damage to thc LPSI pumps should thc LPSI pumps be required to operate.
The alternative provides full-stroke exercising to the closed position during cold shutdowns in accordance OM Part 10 $ 4.2.1.2(c).
Per PR4, the LPSI pumps are full-flowtested during cold shutdowns.
It is unclear how valves V3659 and Y3660 can bc excrciscd quarterly as specified in the Unit2 Valve table.
The licensee should review this and submit a cold shutdown justification for Unit2 ifneeded.
Item Number Valve ldentilication Drawing No.
Liccnsec's Justification for Dcfcrring Valve Exercising Proposed Altcmate Testing Evaluation ofLicensee's Justiiflication CS J-U 14143 (CSJ-U2-SI43)
Units I and 2:
- V3114, V3124, V3134, and V3144 LPSI Cold Lcg Injection Check Valves 8770%478 Sh 131 A 2998%-078 Sll 130B Safety Injection System "These arc simple check valves with no cxtcrnal means of exercising or lor dctcnnining obturator position. Thus, testing thcsc valves in the open direction rcquircs system flow. Since no fullflowrecirculation path exists, full stroke exercising ofthese valves would require operating a low pressure safety injection (LPSI) pump at nominal accident flowratc and injecting into the reactor coolant system. Atpower operation this is not possible bccausc the LPSI puinps do not dcvclop suflicient discharge pressure to ovcrcomc reactor coolant system pressure.
Partial flow testing is similarly not practical since itwould require isolating the associated safety injection tank which is not permitted during plant operation.
In addition, for Unit2: "Vcrilicationofclosure can be done by operating a HPSI pump with the associated IIPSI header isolation valve open and determining check valve backllow. This, however, would unseat thc associated downstream header check valve and require leakage testing ofthis valve pcr St. Lucie Tcchnical Specification 4.4.6.2, Although not impractical, such quarterly leakage testing would bc an undue burden on thc plant staff. Note that valves V3114, V3124, V3134, and V3144 remain closed during power operation.'er the Unit I and Unit 2 valve tables, these valves are excrciscd open during cold shutdowns.
Pcr thc Unit I Valve Table, these valves arc exercised closed per VR44, while the Unit2 valves are-cxcrcised closed during cold shutdowns.
It is impractical to fulletroke cxercisc these valves open quarterly because the LPSI pumps cannot develop suflicicnt discharge prcssure to achicvc fullopening.
lt is impractical to partialwtroke exercise these valves open quarterly because this requires the associated SI Tank to be isolated during plant operation.
For Umt 2, it is impractical to exercise the valves closed quarterly.
Tcchnical Specification 4.4.6.2 requires additional leakage testing followingPIV operation. As discussed in NUREG-1482, Section 4.1.4, the need to sct-up test equipmcnt during operation is adequate justification for deferral of testing to cold shutdowns.
Thc alternative provides full-stroke excrciYing to thc open position (and closed position for the Unit2 valves) during cold shutdowns in accordance with OM Part 10, $
4.32.2(c).
CSJ-U14144 (CSJ-U2$ 144)
Units I and 2:
- V3480, V3481, V3651, and V3652 Shutdown Cooling RCS Isolation Valves 87706478 Sll 13 IA 2998%478 S}I 131 Safety Injection System "These valves arc provided with electrical interlocks that prevent opening during reactor power operation. In addition, during operation it is likelythat these valves will experience a large pressure diffcrcntial (in cxccss of2000 psid). Atthis differential prcssure thc valve operators arc incapable ofopening the valves. Furthermore, ifthey could bc opened operation at high diffcrcntial prcssure could result in damage to their seating surfaces.
Foi these reasons exercising these valves in any plant condition other than cold shutdown is impractical."
Pcr the Unit I and Unit2 Valve Tables, these valves are cxerciscd open arid closed during cold shutdowns.
It is impractical to exercise these valves open quarterly because, to prcvcnt an interfacing systems LOCA, these valves arc provided with electrical interlocks that prevent opening during operation.
Thc alternative provides full-stroke exercising during cold shutdowns in accordance with OM Part 10, $
4.2.1.2(c).
A-20
Item Number Valve Identification Drawing No.
Licensee's Justification for Dcfcrring Valve Exercising Proposed Alternate Testing Evaluation ofLiccnscc's Justification CSJ-U24145 Unit2 only:
- V03002, V3003, V3004 and V03005 Safety Injection Tank (SIT)
Drain Line Check Valves 2998%478 SII 132 Safety Injection System
'Exercising these valves requires draining ofeach ofthe SIT's. This is not considered to bc an appropriate nor prudent activity to perform during plant operation duc to the obvious safety issues related to SIT inventory and chemistry control.
Pcr the Unit2 Valve Table, these valves are exercised open during cold shutdowns.
It is impractical to partial-stroke or fullctrokccxcrcisc these valves open quarterly because this would require draining the SITs and restoring their Icvcl which is governed by thc Tcchnical Specifications.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OM Part 10, $
4.3.2.2(c).
CSJ-U24146 Unit 2 only:
- V3258, V3259, V3260and V3261 Safety Injection Header Check Valves (29984-078 Sli 132 Safety Injection "These valves open to provide flow paths from thc high/low pressure safety injection headers to the RCS and close to isolate the headers from thc high pressure ofthc reactor coolant system.
Since no full flowrecirculation path exists, fullstroke exercising ofthese valves would require operating a low pressure safety injection (LPSI) pump at nominal accident flow'rate and injecting into thc reactor coolant system. At power operation this is not possible because the LPSI pumps do not dcvclop sufficien discharge pressure to ovcrcomc reactor coolant system prcssure.
Partial flowexercising ofthese valves is pcrfonned when ever its associated SIT is refilled. The acceptable SIT level band specified by the Technical Specification is very narrow. The SIT's are only refilled on an as needed basis; therefore, thc partial fiowtest cannot readily be incorporated into a quarterly test."
Per the Unit 2 Valve Table, these valves arc cxcrciscd open during cold shutdowns.
It is impractical to full-stroke exercise thcsc valves open quarterly because the LPSI pumps cannot develop suflicicnt discharge pressure to achieve fullopening.
The altemativc provides full-stroke exercising to the open position during cold shutdowns in accordance with OM Part 10 $
4.3.2.2(c).
In addition, these valves arc also partialwtroked open during the rcfillingofthc safety injection tank as needed during operation.
A-21
Item Number Valve Identification Drawing No.
Licenscc's Justification for Deferring Valve Exercising Proposed Alternate Testing Evaluation ofLiccnscc's Justification CSJ-U1$ 145 (CSJ-U2$ 147)
CSJ-U24I-08 Units I and 2:
- V3614, V3624, V3634, aNI V3644 SIT Discharge Isolation Valves Unit2 only:
- V3733, V3734,
- V3735, V3736,
- V3738, V3739 and V3740 SIT Vent Valves 877(hG478 Sh I3I B 2998%478 Sh 132 Safety Injection System 2998%478 Sll 132 Safety Injection System "During normal plant operation, these valves arc administratively controlled to bc locked open with their brcakcrs racked out to <<nsurc they remain in thc open position with no chance ofmisalignment. These valves are also interlocked such that they willautomatically go open ifRCS pressure is grcatcr then 350 psia (500 psia for Unit 2). Thcrcfore, the valves can only bc cycled closed during Modes 4 (<350 psia or <500 psia for Unit2)), 5 and 6."
"Cycling any ofthcsc valves during normal plant operation with thc SIT's pressurized is undesirable since ifa valve werc to fail to reclose thc result would be a de-prcssurization ofthc affected SIT and a plant shutdown.
Even controlled venting could rcducc SIT prcssure below the Tcchnical Specification limits requiring unnecessary recharging ofthc SIT."
Pcr thc Unit I and Unit2 Valve Tables, thcsc valves are exercised closed during cold shutdowns.
Per the Unit2 Valve Table, these valves arc exercised closed and
<<xerciscd open and tested to their fail-safe closed position during cold shutdowns.
It is impractical to exercise these valves closed quarterly because they are locked open with their breakers removed, and they arc only closed during a normal plant shutdown to prcvcnt injection ofthe SIT inventory into thc RCS.
The alternative provides fullwtroke exercising to thc closed position at cold shutdowns in accordance with OM Part 10, $ 4.2.1.2(c).
It is impractical to exercise these valves quarterly because they are locked closed during normal plant operation to maintain pressurization ofthe SIT and a failure during testing would rcquirc a plant shutdown.
The altemativc provides full-stroke exercising to thc open and closed position and testing to thc failmfc position during cold shutdowns in accordance with OM Part 10, $
4.2.1.2(c).
A-22
Item Number Valve Drawing Liccnsce's Justilication for Deferring Valve Exercising Proposed Alternate Testing Identification No.
Evaluation ofLiccnsec's Justification WASTE MANAGEMENTSYSTEM CSJ-U I-WM41 Unit I only:
V6779 Nitrogen Header Containment Isolation Check Valve 8770%478 Sll 163B Waste Manage-ment "This is a simple check valve with no cxtcmal means of cxcrcising nor for determining disc position, thus the only practical way ofverifying closure is by means ofa backflow test. Backflow testing ofthis valve requires that thc downstream side ofthe valve bc pressurized and thc upstream side vcntcd. To vent thc upstream side ofthc valve, a bhnk flangc must bc removed and the drain valve, V6340, opened.
With thc drain valve open, check valve V6779 becomes the sole containment isolation valve for this penetration.
In this configuration, containment integrity requirements could unknowingly bc violated.
Note that the test connection valve is not leak tested and manual closure ofV6340 under accident conditions is questionable.
Therefore, backflow testing should only bc performed when containmcnt integrity is not required (Modes 5 or 6)."
Pcr thc Unit I Valve Table, this valve is excrciscd closed during cold shutdowns.
It is impractical to partial-stoke or fullwtrokccxercisc this valve closed quarterly because failure ofthis valve to close during the test would result in a loss ofcontainment integrity.
The altemativc provides fullctrokc exercising to the closed position in accordance withOM Part 10 $
432.2(c).
CSI-U2-WM41 Unit 2 only:
V6792 Nitrogen Gas Supply Containment Isolation Check Valve 2998%478 Sli 163B Waste Manage-ment "This is a simple check valve with no external means of position indication, thus thc only practical means of verifying closure is to perform a back Icakagc test.
Performing such a test requires entry into the containment building and thus is impractical to do during plant power operation."
Pcr thc Unit 2 Valve Table, this valve is exercised closed during cold shutdowns.
Thc liccnsec states that it is impractical to exercise this valve closed quarterly because this requires entry into the containment during plant operation to perform a backleakagc test. This is not an adequate justification for deferring the testing. NUREG-1482, Section 4.1.4 provides additional information on impracticality of testing check valves during operation. Thc licenscc should provide additional information on why it is impractical to test during operation (e.g., need to set up tnt equipment), and revise this deferral rcqucst.
Thc licensee should also correct thc drawing rcfcrcnce for this deferral to correctly indicate drawing number 2998%478, Sh 163B.
0 Item Number Valve Drawing Licenscc's Justification for Deferring Valve Exercising Proposed Alternate Testing Identification No.
Evaluation ofLiccnsec's Justification MAINSTEAM SYSTEM CSJ-U I-MS41 (CSJ-U2-MS41)
Units I and 2:
HCV48-I AkB Main Steam Isolation Valves 877lhG479 Sli I 2998%479 SII I Main Steam System "Closing either ofthese valves isolates thc associated steam hcadcr. During power operation isolation ofa header would require a significant power reduction and could result in unacceptable steam generator level and reactor power transients with the potential for a plant trip." Additionally, for Unit2: "NUREG-1432, Vol I, Rcv. I, 'STANDARD TECHNICALSPECIFICATIONS Combustion Enginccring Plants Specifications", states that MSIVs should not bc tcstcd (fullor partial stroke) at power and they are cxcmpt from thc requirements ofthe ASME Code, Section XIwhile operating in Modes I or 2."
Per thc Unit I Valve Table, these airwperatcd stop check valves are partially exercised closed quarterly and full-stroke cxcrciscd closed during cold shutdowns.
Per the Unit 2 Valve Table, thcsc pistonwperated globe valves arc fullctrokc exercised closed and tested to their fail safe position during cold shutdowns.
For Unit I, it is impractical to full-strokc exercise these valves closed quarterly because this would cause a plant transient.
The alternative provides partial-stroke exercising to the closed position quarterly and full-stroke exercising to the closed position at cold shutdowns in accordance with OM Part 10, $ 4.2.1.2(b).
For Unit2, it is impractical to partial-stroke or full-stroke cxercisc thcsc valves closed quarterly duc to thc risk ofvalve closure as discussed in NUREG-1432, Vol. I, Rev. I, "Standard Technical Specifications - Combustion Engineering Plants." The alternative provides full-stroke exercising and fail-safe testing to the as-is position during cold shutdowns in accordance with OM Part 10, $ 4.2.1.2(c).
CSJ-U I-MS42 (CSJ-U2-MS42)
Units I and 2:
V08130 aild V08163 Stcam-Driven AFW Pump Steam Supply Check Valves 877(hG479 S}l I 2998%479 Sll I Main Steam System "Full-stroke cxcrcising ofthese valves would require operation ofAuxiliaryFecdwatcr Pump IC (2C (Unit2))
and injection ofcold water (85 dcg F) into hot (450 deg F) fccdwatcr supply piping. This, in turn, would result in unacceptable thermal stress on thc fcedwater system piping components.
These valves willbe partial stroke tcstcd during quarterly testing via the minimum flowrecirculation lines."
Pcr thc Unit I and Unit2 Valvc-Tablcs, thcsc valves are partially excrciscd open quarterly and a}ter disassembly and inspection, and full-stroke cxcrcised open during cold shutdowns.
It is impractical to full-stroke exercise these valves open quarterly because ofthe potential of equipment damage due to thermal stress.
The alternative provides partial-stroke exercising to the open position quarterly and fullwtroke exercising to the open position at cold shutdowns in accordance with OM Part 10, $ 43.2.2(b).
Item Number CSJ-Ul-MS43 (CSJ-U2-MS43)
Valve Identification Unit I:
SE48-IAI, through IA4, and SE48-IBI through IB4 Unit2:
V2Athrough VSA, V19A, V20A, V2B through VSB, V19B and V20B Drawing No.
8770%479 Sll 7 2998-1014 Main Steam System Unit 2:
MSIV Pneumatic Control System Liccnscc's Justification for Deferring Valve Exercising "Thc pneumatic control systems for each ofthc MSIVs are dcsigncd such that the operation ofthcsc pilot valves can bc verified and tcstcd while the plant is operating at power and thc associated MSIVis open; however, there is conccm that a failure ofa blocking valve or procedural mishap could inadvertently cause an MSIVto close. Closure ofonc of thcsc valves at power would subject the plant to a signilicant and traumatic transient with a plant trip likely."
Proposed Altcmatc Testing Pcr thc Unit I Valve Table, thc IAI, IA2, I8l and IB2 valves arc cxcrcised closed during cold shutdowns.
Thc IA3, IA4, IB3 and IB4 valves are exercised open during cold shutdowns.
Per thc Unit2 Valve Table, these valves are cxerciscd closed and tested to their failleposition during cold shutdowns.
Evaluation ofLioenscc's Justification Pcr the Unit I and Unit2 Valve Tables, these valves are not ASME Code Class. No evaluation was performed.
Main Steam, Isolation Valve (MSIV)
AirPilot Valves FEEDWATER ANDCONDENSATE SYSTEM (INCLUDES AUXILIARYFEEDWATER SYSTEM)
CSJ-Ul-BF41 Unit I only:
MV4941 MV4942 Main Fecdwater Pump Isolation Valves.
8770%480 Sli 3 Fcedwatcr di Condensate Systems "During plant power operation, closure ofeither ofthese valves is not practical as itwould require a significant decrease ofplant power and possibly securing a main fccdwatcr pump in addition to upsetting thc stcam plant static operating condition.
NUREG-1432, Vol I, Rev. I, STANDARDTECHNICAL SPECIFICATIONS Combustion Enginccring Plants Spccilications, states that MFIVsshould not bc tested (full or partial stroke) at power and they are exempt from thc requirements ofthc ASME Code, Section XIwhile operating in Modes I or 2. Based on this recommendation, these valves should not be partial stroke tested."
Pcr thc Unit I Valve Table, these valves arc cxcrcised closed during cold shutdowns.
Per the Unit I Valve Table, these valves arc not ASME Code Class.
No evaluation was performed.
Item Number CSJ-U2-BF41 CSJ-Ul-BF42 (CSJ-U2-B F42)
Valve Identification Unit 2 only:
CHKVIV-I A&Band CHKVLV-2 A&B Main Fcedwa! er Air Supply Check Valves Unit I:
MV4947 MV-0948 Unit2:
HCV49-I A&Band HCV49-2 A&B Main Feed water Isolation Valves Drawing No.
2998%480 Sll 2A Feedwater Condensate Systems 8770%-080 SII 3 2998%480 Sll 2A Feedwater Condensate Systems Licensee's Justification for Dcfcrring Valve Exercising "These arc simple check valves with no extcmal means of determining disc position; thcreforc, verification ofclosure can only be accomplished by performing a backflow or back-leakage test. Since the system was not provided with a convcnicnt testing means, this test requires isolation of the air supply to thc subject MFIVand disassembly of portions ofthe air supply piping. It is not practical to perform such activities routinely on a quarterly basis with the plant operating at power. Thc risks associated with the degree ofundesirability ofsystem disassembly and thc potential ofintroducing foreign materials into the pneumatic operating system outweigh any benefits gained from quarterly testing."
During plant power operation, closure ofeither ofthese valves is not practical as it would require isolating a steam generator which would result in a scvcrc transient on thc steam and reactor systems and a possible plant trip.
NUREG-1432, Vol I, Rev. I, "STANDARDTECHNICAL SPECIFICATIONS Combustion Engineering Plants Specifications, states that MFIVsshould not bc tested (fullor partial stroke) at power and they arc cxcmpt from the rcquircments ofthc ASME Code, Section XIwhile operating in Modes I or 2. Based on this recommendation, thcsc valves should not bc partial stroke tcstcd as well."
Proposed Altematc Testing Per thc Unit2 Valve Table, these valves arc full-stroke exercised to the closed position during cold shutdowns.
Pcr thc Unit I and Unit 2 Valve Tables, thcsc valves arc cxerciscd closed during cold shutdowns.
Evaluation ofLiecnsec's Justilication The subject valves are not shown on thc rcfercnccd drawing. Pcr the Unit2 Valve Table, these valves are not ASME Code Class. No evaluation was performed.
It is impractical to exercise these valves to thc closed position quarterly bccausc this could cause a transient and plant trip.
Thc alternative provides full-stroke exercising to the closed position at cold shutdowns in accordance with OM Part 10, $ 4.2.1.2(c).
A-26
Item Number CSJ-Ul-OFT (CSJ-U2-BF43)
Valve IdentiTication Unit I:
- V09107, 09123, and 09139 Urrit2:
- V09107, V09123, and V09139 Auxiliary Feedwatcr Pump Discharge Check Valves Units I and 2:
- V09119, 09135, 09151, and 09157 Auxiliary Feed water Header and Supply Cheek Valves Drawing No.
8770%480 Sh4 2998%480 Sh 2B "Feedwatcr Condensate Systems 8770%480 Sh4 2998%480 Sh 2B Feed water Condcnsatc Systems Licensee's Justilication for Deferring Valve Exercising Full-stroke exercising ofthcsc valves would require operation ofa related auxiliary fccdwatcr pump and injection ofcold water (85 dcg-F) into the hot (450 deg-F) fcedwatcr supply piping. This, in turn, would result in unacocptablc themlal stress on thc feedwatcr system piping components.'Full-stroke exercising ofthese valves wou'Id require operation ofa related auxiliary fccdwatcr pump and injection ofcold water (85 dcg F) into thc hot (450 deg F) fccdwater supply piping. This (in turn) would result in unacceptablc thermal stresses on the fccdwater system pip Iflg coinpotlcilts.
Proposed Alternate Testing Pcr the Unit I and Unit 2 Valve Tables, these check valves arc exercised open during cold shutdowns.
Pcr the Unit I and Unit2 Valve Tables, these valves are exercised open during cold shutdowns.
Evaluation ofLiccnscc's Justification These check valves arc located downstream ofthe AFW pump test recirculation lines to thc Condcnsatc Storage Tank (CST). These valves do not open during the periodic AFW pump testing.
It is impractical to partialwtrokc or full-stroke open these valves quarterly due to the potential for equipment damage duc to thermal stresses.
Thc altcmative provides full-stroke exercising to thc open position during cold shutdowns in accordance with OM Part 10, $
4.3.2.2(c).
It is impractical to partial-stroke or full-stroke exercise these valves open quarterly duc to thc potential for equipment damage due to thermal stresses.
Thc alternative provides fullctroke exercising to the open position during cold shutdowns in accordance with OM Part 10, $
432.2(c).
CSJ-U I-BF45 Unit I only:
V12174 and VI2176 Auxiliary Feedwatcr Pump Suction Check Valves 8770%480 Sh4 Fccd water Condensate Systems "Full-stroke exercising ofthese valves would require operation ofa related auxiliary fecdwatcr pump and injection ofcold water (85 dcg F) into thc hot (450 deg F) feedwater supply piping. This would result in unacceptable thermal stresses on the fccdwater system piping components, These valves willbe partial stroke tested during, quarterly testing via the minimum IIowrecirculation lines."
Pcr the Unit I Valve Table, these check valves are full-stroke exercised open during cold shutdowns and partial-stroke exercised open quarterly.
It is impractical to fullatroke exercise these valves open quarterly due to the potential for cquipmcnt damage due to thermal stresses.
The alternative provides partial-strokc exercising quarterly and full-stroke exercising open during cold shutdowns in accordance with OM Part 10, $ 4.3.22(b).
A-27
Item Number CSJ-UI-BF46 Valve Identification Unit I only:
V12177 Unit2
'ondensatc Storage Tank to IAand IB Auxiliary Fc<<dwater Pump Suction Isolation Valve Drawing No.
87764480 Sll 4 Fccdwater Condensate Systems Licensee's Justification forDeferring Valve Exercising "This manual valve is opened when cross connecting thc IAand IBAuxiliaryFeedwater Pump suction to thc Unit2 CST. This function is required in the event that a missi!e ruptures the Unit I CST which is not missile-protected vertically. Opening this valve during plant power operation is unacceptable as itwouldjeopardize the operability ofIA and IB AuxiliaryFeedwater Pumps by connecting'their common suction piping to nonwlassed and non-seismic piping. Thus a credible single failure ofthc nonwlassed piping without timely operator action could disable both auxiliary feedwater pumps."
Proposed Altematc Testing Pcr the Unit I Valve Table, this manual valve is exercised during cold shutdowns to verify proper operation and stroking with no stroke time measurements.
Evaluation ofLicensee's Justification It is impractical to exercise this valve open quarterly as this would rcquirc connecting both ofthe Unit I motor-driven AFW pumps IAand IB to non-code class and non-seismic piping.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OM Part 10, $
42.1.2{c).
CSJ-UI-BF47 CSJ-U2-BF45 Unit I only:
VI2497 Unit I Condensate Storage Tank Outlet to IA/IB Auxi)iary Feedwater Pump Suction Isolation Valve Unit2 only:
V12802 and VI2803 Unit2 Condensate Storage Tank to Unit I Auxiliary Fecdwater Pump Suction Isolation Valves 877lHi480 Sh4 Feed water Condensate Systems 2998%480 Sh 2B Feed water Condensatc System "This manual valve is closed to isolate the Unit I CST when cross connecting the IAand IB AuxiliaryFeedwater pump suction to the Unit2 CST. This is required ifa missile ruptures the Unit I CST which is not missile-protected vertically. Closing this valve during plant operation is unacceptablc as itwould render both the IA and IB AuxiliaryFcedwater Pumps inoperable."
These manual valves are opened when cross tieing the Unit 2CST to the Unit I CST. This is required ifa missile ruptures thc Unit I CST which is not protected from vertical missiles. Opening these valves during plant operation is unacceptable as itwould jeopardize the Unit2 AuxiliaryFeedwater Pumps by connecting their suction piping to nonelasscd and non-seismic piping. Thus, a credible single failure ofthc nonwlassed piping could disable all the auxiliary feedwater pumps."
Pcr the Unit I Valve Table, this manual valve is exercised during cold shutdowns to verify proper operation and stroking vvith no stroke time measurements.
Per the Unit2 Valve Table, these valves are exercised during cold shutdowns to verifyproper operation and stmking with no stroke time measurements.
It is impractical to exercise this valve closed quarterly as this would render both ofthe motor4riven AFWpumps inoperable.
The alternative provides full-stroke exercising to the closed position during cold shutdowns in accordance with OM Part 10, $
4.2.1.2{c).
It is impractical to cxcrcisc thcsc valves open quarterly as this would require connecting both ofthc Unit 2 motor4riven AFW pumps 2A and 2B to nonce class and non-seismic plpliig.
The alternative provides full-stroke exercising to the open position during cold shutdowns in accordance with OM Part 10 g 4.2.1.2{c).
Item Number Valve Drawing Licensee's Justification forDeferring Valve Exercising Proposed Alternate Testing Evaluation ofLicensee's Identification No.
Justification COMPONENT COOLING WATERSYSTEM CSJ-UI<C41 Units I and 2:
(CSJ-U2ZC-OI)
HCV-14-1,2, 6'
RCP Cooling Water Supply/
Return
'solation Valves 8770%483 Sh I B 2998%483 Sh2 Component Cooling System "These valves are required to be open during plant operations to ensure continued coo! ing ofreactor coolant pump components.
Closing any ofthese valves during plant operation could result in severe RCP (and CRD for Unit2) damage leading to plant operation in a potentially unsafe mode and a subsequent plant shutdoIvn."
Per the Unit I and Unit 2 Valve Tables, these valves are exercised closed and tested to their fail-safe position during cold shutdowns.
lt is impractical to partial-stroke or full-stroke cxercisc these valves to thc closed position quarterly because liowofcomponent cooling water to the reactor coolant pumps and motors (and CRD air coolers for Unit2) would bc interrupted resulting in equipment damage.
The alternative provides full-stroke exercising to the closed position during cold shutdowns in acoirdance with OM Part 10, $
4.2.1.2(c).
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Item Number Valve Drawing Licensee's Justification for Deferring Valve Exercising Proposed Altcmatc Testing Identification No.
Evaluation ofLicensee's Justification INSTRUMENTAIRSYSTEM CSJ-Ul-IA41 (CSJ-U2-IA41)
Units I and 2:
VI&279 and VI&283 Instruincnt AirSupply to Maintcnancc Hatch Door in Annulus Check Valves Units I and 2:
VI&290,
- VI8291, V 1 8294 and V18295 Instrument Airto Containmcnt Vacuum Breakers Check Valves 8770%-085 Sh 2A 2998%485 Sh 2A Instrument Air "Thcsc (are) simple check valves with no cxtemal means of cxcrcising nor for determining disc position, thus thc only practical way ofverifyingclosure is by means ofa backflow test Testing ofthcsc valves by any method rcquircs isolation ofa common instrument air header to the shield building annulus so that a vent path may bc created on the upstream side ofthe check valves to determine closure.
This test removes onc maintenance hatch seal and/or containmcnt vacuum relieffroin scrvicc and potentially renders both trains inopcrablc due to the time that instruincnt air would bc isolated from the common hcadcr and thc usc ofthe opposing train component as the requisite vent path. Although isolation ofinstrument air and subscqucnt testing ofa single train should not keep at least onc train from functioning, it requires that both trains ofthe shield building ventilation system (Technical Specification 3.6.6.1) and containmcnt vacuum relief(Tcchnical Specilication 3.6.5) be considered out ofservice. This would require entry into tcchnical specification applicability statements as noncompliance for containment vacuum reliefapplicable in Modes I through 0 (and require p'lant shutdown)(Unit I).
Testing ofthese valves requires entry into thc shield building annulus forvalve lineup and monitoring purposcs-neutron radiation area during Modes I and 2. Due to ALARAconsiderations and the aforemcntioncd dual train operability concerns with components credited for accident mitigation, thcsc valves should only bc tested at cold shutdown intervals. (This is consistent with the guidelines presented in NUREG-1482, Paragraph 3.1.1(l)(Unit I)."
Pcr thc Unit I and Unit 2 Valve Tables, thcsc check valves arc exercised closed during cold shutdowns.
(The instrument air to containment vacuum breaker valves are tcstcd in series pcr VR-12).
It is impractical to partial-stroke or fuilctroke exercise these valves closed quarterly because ofentry into multiple LCO.
The altcmative provides fullwtrokc exercising to the dosed position during cold shutdowns in accordance with OM Part 10, $
4.32.2(c).
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Item Number Valve Identification Drawing No.
Licensee's Justification for Dcfcrring Valve Exercising Proposed Altcmate Testing Evaluation ofLiccnscc's Justification CSJ-U I-IA42 Unit I only:
- VI8099, V18695, V18696 and V18699 MSIV Accumulator Instrument AirSupply Check Valves 8770~85 Sh3 Instrument AirSystem Testing ofthese valves (closed) is not practical during plant operation because it isolates thc instrument air supply to thc main steam isolation valves (MSIVs) and the atmospheric dump valves (ADVs)and could lead to an inadvertent MSIVclosure. Closure ofan MSIVwould isolate steam from thc respective steam generator which would result in a severe transient on the steam and reactor systems and a possible plant trip. Isolation ofair to the ADVswould cause them to be inoperable and incapable of opening. Although these valves arc not "safety-related they are operationally important in minimizing plant transients and shutting down the plant ifnecessary.
Per thc Unit I Valve Table, these valves arc cxcrciscd closed during cold shutdowns.
(Thcsc valves are tested in series per VR-12).
It rs impractical to exercise thcsc valves closed quarterly bccausc thc testing could lead to an inadvertent MSIVclosure and plant transient.
The alternative provides full~ke exercising to the closed position during cold shutdowns in accordance with OM Part 10, $
4.3.2.2(c).
CSJ-U2-IA42 Unit2only:.
HCV-18-1 Primary Containment Instrument AirSupply Valve.
2998<485 Sh 2C Instrument AirSystem
'Closing this valve isolates operating air to critical components in the containment building including the prcssurizcr spray, RCP cooling water supply and return, and CVCS letdown isolation valves and could cause scverc plant transients, RCP damage and a plant trip. Failure in thc closed position would cause a plant shutdown and RCP damage."
Per thc Unit2 Valve Table, this valve is exercised closed and tcstcd to the fail-safe position during cold shutdowns.
It is impractical to exercise this valve to thc closed position quarterly because this could result in a plant transient and trip.
Thc alternative provides full-stroke cxcrcising to thc closed position at cold shutdowns in accordance with OM Patt 10, $ 4.2.1.2(c).
CONTAINMENTSPRAY SYSTEM CSJ-V I<$41 (CSJ-UPS-OI)
Units I and 2:
V07119 Bild V07 120 RWT Outlet Check Valves 8770%488 Sh I 8770%488 Sh I Contain-mcnt Spray "These arc simple check valves with no cxtemal m<<ans of exercising or for determining obturator position. Thus, testing these valves in the closed direction rcquircs a back-leakagc test. Such a test requires realignment ofthc associated safety injection and containment spray train that would render the complete train (LPSI, HPSI, and containment spray) inopcrablc for an extended period of time and entry into a multiple LCO. During plant power operation this is considcrcd to be imprudent. This justification agrees with the guidelines provided in NUREG-1482, Paragraphs 3.1.1 and 3.1.2."
Pcr the Unit I and Unit2 Valve Tables, thcsc check valves arc cxcrcised closed during cold shutdowns.
They arc partially cxcrcised open quarterly and disassembled and inspected in accordance with VR-14.
It is impractical to exercise these valves closed quarterly because this requires entry into multiple LCOs.
In accordance with NUREG-1482, $
3.1.2, entry into multiple LCOs is to bc avoided.
Thc alternative provides exercising to thc closed position during cold shutdowns in accordance with OM Part 10, $ 4.3.2.2(c).
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Item Number Valve Drawing Licensee'sJustificationforDefemngValveExercising ProposcdAltematc Testing Identification No.
Evaluation ofLieenscc's
'Justilication HEATING,AIRCONDITIONINGANDVENTILATIONANDAIRCONDITIONING CSJ-Ul-HVAC-01 (CS1-U2-HVAC-01)
Units I and 2:
FCV-25-1 through FCV-254 Primary Containmcnt Purge and Vent Valves 8770%-878 2998%-878
- Heating, Ventilation, and Air Condition-ing For Unit I, "Thcsc valves arc administratively maintained in the closed position at all times when the plant is operating in Modes I, 2 or 3 thus they are not required to operate (close) during operational periods.
Due to the large size ofthese valvcs and thc potential for damage as a result
/
offrequent cycling, it is not prudent to operate them morc than is absolutely necessary."
For Unit 2, "These valves arc required to remain closed at all times when the plant is operating in Modes I through 4, thus they arc not rcquircd to opcratc (close) during operational periods.
Duc to thc large size ofthcsc valves and the potential for damage as a result offrequent cycling, it is not prudent to operate them more than is absolutely nece Pcr thc Unit I and Unit2 Valve Tables, these valves are excrciscd closed and tested to their fail safe position during cold shutdowns.
It is impractical to exercise these locked closed valves quarterly because oftheir large size, 48 in.
diameter, and the potential for a gross breach ofcontainmcnt.
Thc alternative provides full-stroke cxcrcising to thc closed position at cold shutdowns in accordance with OM Part 10, $ 4.2.1.2(c).
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