ML17309A665

Technical Evaluation Rept Pump & Valve Inservice Testing Program,St Lucie-Unit 1.

ML17309A665
Person / Time
Site:	Saint Lucie
Issue date:	11/30/1991
From:	Cain R EG&G IDAHO, INC.
To:	NRC
Shared Package
ML17227A321	List: ML17309A665
References
CON-FIN-A-6812 EEG-NTA-9675, EGG-NTA-9675, TAC-M74794, NUDOCS 9111220229
Download: ML17309A665 (77)

Text

ATTACHMENT EGG-NTA-9675 TECHNICAL EVALUATION REPORT PUMP ANO VALVE INSERVICE TESTING PROGRAM ST. LUC I E UNIT ONE Docket No. 50-335 R. S. Cain C. B. Ransom R. S. Hartley Published November 1991 Idaho National Engineering Laboratory EGIlG Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U,S. Nuclear Regulatory Commission Washington, D.C. 20555 Under OOE Contract No. OE-AC07-76ID01570 FIN No. A6812 TAC No. 74794

ABSTRACT This report presents the results of the evaluation of relief requests for the inservice testing program for safety-related pumps and valves at St. Lucie Unit One of Florida Power and Light Company.

PREFACE This report is part of the "Review of Pump and Valve Inservice Testing Programs for Operating Reactors ( III)" program conducted for. the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc., Regulatory and Technical Assistance Unit.

BKR 920-19-05-02-0 .

FIN No. A6812 Docket No. 50-335 TAC No. 74794

0 CONTENTS ABSTRACT yQ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ t~~~~~~~~ '

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P REFACE ................ ..... ........ ..........................

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1. INTRODUCTION 1

2. PUMP TESTING PROGRAM ............................................. 3

2. 1 All Pumps in the IST Program ............................... 3 2.1.1 Bearing Temperature Measurements .................... 3 2.1.2 Instrument Range .....................,,............,

2.1.3 Static Pump Inlet Pressure .......................... 4 2.2 Diesel Fuel Oil, Intake Cooling Water, and Boric Acid Systems .. . .........................:.... 5 2.2. 1 Flow Measurement .................................... 5 2.2.2 Pump Suction and Differential Pressure .............. 6

3. VALVE TESTING PROGRAM ............................................ 9 3.1 General Relief Requests ................................... 9

3. 1. 1 Test Frequency .............. ~ ~ ~ ~ 9 3.1.2 Containment Isolation Valves 10

3. 1.3 Pressure Isolation Valves ... 11 3.2 Safety Injection System ................................... 12 3.2. 1 Category A and A/C Valves .......................... 12 3.3 Containment Spray System .................................. 16 3.3. 1 Category C Valves .................................. 16 3.4 Chemical and Volume Control System ........................ 17 3.4. 1 Category C Valves .................................. 17 3.5 Emergency Diesel Generator System ......................... 19 3.5. 1 Category 8 Valves .................................. 19 3.6 M ann Steam System ......................................... 22 3.6. 1 Category C Valves .................................. I 22 111

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3.7 Miscellaneous Systems .......................,............. 23 3.7.1 Hydrogen Sampling System .....,.....,.... 23 3.7.2 Sampling/Containment Isolation System ... 24 3.7.3 Intake Cooling Water System ............. 25 3.7.4 Make-up Water System .................... 25 Instrument Air System ...................

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3.7.5 26 3.7.6 Alternate Source of Cooling Water System 27 APPENDIX A--P8LID DRAWING LIST ............................... ~ ~ ~ ~ ~ ~ ~ ~ A 1 APPENDIX B--IST PROGRAM ANOMALIES ...,............................... B-1

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'.1/01/91 ST. LUCIE UNIT ONE SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER 5 SUBJECT TESTING USNRC PR-1 2. 1. 1. 1 IWP-3300 All centrifugal None Relief Granted 5 -4310: pumps in the IST (a)(3)(ii)

Measure program bearing temperature PR-2 2.1.2.1 IWP-4120: Various pumps Use portable Relief Granted Instrument listed in the instruments that (a)(3)(i) full-scale IST program meet Code accuracy range requirements.

PR-3 2.1.3.1 Tabl e All pumps in the Measure idle in1et Not required to IWP-3100-1: IST program pressure for pumps stop pumps per Measure inlet that are not IWP-3400(b).

pressure operating. Relief is not before pump necessary.

start PR-4 N/A Table Auxi1 i ary Test quarterly per Approved per IWP-3100-1: feedwater pumps: IWP-3200 and -6000. GL 89-04, Measure flow AFW-1A, -1B, 5 Cold shutdown test Position 9, rate -1C with flow rate per Relief not IWP-3200 and -6000. evaluated in TER.

PR-5 N/A Table Boric acid Test quarterly per Approved per IWP-3100-1: makeup pumps: IWP-3200 and -6000. GL 89-04, Measure flow BAM-IA 8 1B Cold shutdown test Position 9, rate with flow rate per Relief not IWP-3200 and -6000. evaluated in TER.

PR-6 N/A Table Containment Test quarterly per Approved per 'L IWP'-3100-1: spray pumps: IWP-3200 and -6000. 89-04, Measure flow CS-1A & 1B Refueling outage Position 9, rate test with flow rate Relief not

,per IWP-3200 and evaluated in TER.

-6000.

PR-7 2.2.1.1 IWP-4600: Diesel fuel oil Calculate flow rate. Provisional Relic Measure flbw transfer pump: Granted rate DOT-IA and -1B (g)(6)(i)

Page No.

1.1/Ol/91 ST. LUG IE UNIT'NE SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER 5 SUBJECT TESTING USNRC PR-8 2.2.2.1 Table Boric acid Calculate inlet Provisional Relief IWP-3100-1: pumps: pressure. Granted Measure inlet BAM -lA 5 1B (g)(6)(i) and Diesel fuel oil differential transfer pumps:

pressure DOT -1A L 1B PR-9 N/A Table High pressure Will not measure Approved per IWP-3100-1: safety injection flowrate for GL 89-04, Test shall (HPSI) pumps: quarterly testing, Position 9, include all HPSI-1A, -1B and but will measure it Relief not quantities -1C for refueling outage evaluated in TER.

in Table testing.

PR-10 N/A Table Low pressure Will not measure Approved per IWP-3100-1: safety injection flowrate for GL 89-04%

Measure flow (LPSI) pumps: quarterly testing, Position 9, rate LPSI -1A and -1B hut will measure it Relief noi for cold shutdown evaluated in TER.

testing.

PR-11 2.2.2.1 Table Intake cooling Calculate pressure. Provisional Relief IWP-3100-1: water pumps: Granted Measure inlet ICW-lA, -1B, & (g)(6)(i) and -1C differential

'pressure VR-1 3.1.1.1 IWV-3412, Various valves Test at frequency Relief Granted

-3415, listed in the described in IST (a)(3)(ii) and-3522: program program. Relief Denied For Test valves that can' frequency be tested each cold shutdown.

VR-2 3.1.3.1 IWV-3427(b): Safety injection Test per St. Lucie Relief Granted Trend P I V (S I) and Unit 1 (a)(3)(i) leakage rates residual heat Technical removal. (RHR) Specifications PIVs listed in Table 3.4.6-1.

the program

Page No.

11/01/'91 ST. LUCIE UNI'f ONE SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC VR-3 happen. B IWV-3417(a): Various valves Establish a maximum Approved per Item 19 Measure listed in the stroke time of 2 GL 89-04, stroke time program seconds for rapid Position 6, acting valves per GL Relief not 89-04, Position 6. evaluated in TER.

VR-4 Appen. B IWV-3411: Various valves Test when the out of Request not Item 5 Test in the program service subsystem is evaluated in TER.

frequency returned to service. Subject addressed in plant Technica Specifications.

VR-5 3.1.2.1 IWV-3426 and Various Valves will be Provisional Relic.

-3427: containment tested and evaluated Granted Test method isolation valves ifl groups. (g)(6)(i)

(CIVs) listed on Relief Denied for Table VR-5-1. valves that can b tested individually VR-6 3.4.1.2 IWV-3521: Chemical and Exerci se during Provisional R 'iie Test volume control refueling with boric Granted frequency valves: acid makeup pumps. (g)(6)(i)

V-2177, -2190,

& -2191 VR-7 N/A IWV-3521: LPSI pump Partial-stroke Preapproved Test suction valves: exercise quarterly. GL 89-04, frequency V-07000 and Foll-stroke exercise Relief not

-07001 during refueling evaluated in TER.

outages.

VR-8 N/A IWV-3521: HPSI pump Parti.al-stroke Preapproved Test suction valves: exercise quarterly. GL 89-04, frequency V-3401 and -3410 Full-stroke exercise Relief not during refueling evaluated in TER.

outages.

VR-9 3.2.1.2 IWV-3521: HPS I pump Manually exercise Provisional Rel is Test discharge and verify closed Granted frequency valves: quarterly. (g)(6)(i)

V-3405 -3414 & Full-stroke exercise

-3427 open at refueling outage.

Page No. 4 11/01/91 ST. LUCIE UNIT ONE SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC VR-10 Appen.

Item 8 B IWV-3521:

Test SI valves:

V-3113, -3123,

'reapproved Full-stroke exercise open each refueling. GL 89-04, frequency -3133, and -3143 Verify closure every see anomaly No. 8.

2 years.

VR-11 3.2.1.1 IWV-3521: LPSI injection Full-stroke exercise Relief Denied Test valves: at cold shutdown. ,

frequency V-3114, -3124, leak test once 'IV

-3134, and -3144 every 2 years.

VR-12 Appen. B IWV-3520: . SI valves: As described in IST Approved per Item 15 Test method V-3215 -3225, program, GL 89-04, GL 89-04, and frequency -3235 and -3245 Positions 1 and 2. Positions 1 and 2, Relief not evaluated in TER.

VR-13 3.2.1.4 IWV-3522: SI valves: Verify closure by Relief Granted Test method V-3217 -3227, PIV leak test every for closure and frequency -3237 and -3247 2 years. (9)(6)(i)

Full-stroke open by Full-stroke open disassembly per Approved per GL 89-04, GL 89-04)

Position.2. Position 2.

VR-14 3.6.1.1 IWV-3520: Hain steam Sample dissassembly Provisional Relief Test method valves: and inspection per Granted and frequency V-08117 and IST program, (g)(6)(i)

-08148 GL 89-04, Position 2.

VR-15 3.7.4.1 IWV-3521: Makeup water Exercise closed Relief Granted Test valve: during Appendix J (g)(6)(i) frequency V-15328 leak testing.

VR-16 3.7.5.1 IWV-3521: Instrument air 'xercise closed Relief Granted Test'requency valve: during Appendix J (g)(6)(i)

V-18195 leak testing.

VR-17 Appen. B IWV-3520: Containment Disassemble and Approved per Item 15 Test method spray (CS) inspect per IST GL 89-04, and frequency valves: program, GL 89-04, Position 2, V-07119 and Position 2. Relief not

-07120 evaluated in TER.

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Page No. 5 11/01/91 ST. LUC IE UNIT ONE SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC VR-18 3.3.1.1 IWV-3521: CS valves: Partial-stroke Relief Granted Test '-07129 and exercise quarterly. (g)(6)(i) frequency -07143 Full-stroke exercise at refueling.

VR-19 Appen. B IWV-3520: CS valves: Sample dissassembly Approved per Item 15 Test method V-07172 and and inspection per GL 89-04, and frequency -07174 IST program, Position 2, GL 89-04, Relief not Position 2. evaluated in TER.

VR-20 Appen. B IWV-3520: CS valves: Disassemble and Approved per Items 15 Test method V-07192 and inspect both valves GL 89-04, and 18 and frequency -07193 every other Position 2, refueling, GL 89-04, Relief not Position 2. evaluated in TER.

VR-21 N/A IWV-3521: CS additive tank Full-stroke exercise Preapproved Test valves: each refueling. GL 89-04, frequency V-07256 and Relief not FI -07258 evaluated in TER.

VR-22 Appen. B IWV-3520: CS valves: Sample disassembly Approved per Item 15 Test method V-07269 and and inspection per GL 89-04) and frequency -07270 IST program, Position 2, GL 89-04) Relief not Position 2. evaluated in TER.

VR-23 Appen. B IWV-3417(a): Various valves Assign maximum Approved per Item 19 Stroke time listed in stroke time of 2 GL 89-04, test method program seconds, GL 89-04, Position 6, Position 6. Relief not evaluated in TER.

VR-24 3.7.1.1 IWV-3522(a): Hydrogen Leak test Provisional Relic Test method sampling valves: simultaneously to Granted and frequency V-29305 and verify closure of at (g)(6)(i)

-29306 least one valve.

VR-25 3,7.6.1 IWV-3411: Secondary Exercise at 6 month Relief Granted Test cooling water intervals. (a)(3)(ii) frequency valves:

SB 1 and -2

Page No.

1.1/01/91 ST. LUCIE UNIT ONE SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER & SUBJECT TESTING USNRC VR-26 3.5.1.2 IWV-3413(b): Emergency diesel Observe operation Interim Relief Measure generator quarterly. Granted stroke time valves: Do not measure (g)(6)(i) for one SE-59-1A and -18 stroke time. year or until the next refueling outage.

VR-27 3.5.1.1 IWV-3413(b): EDG valves: Tested with the Interim Relief Measure FCV-59-1A1 thru emergency diesel., Granted stroke time -4A1, -1B1 thru Verify proper diesel (g)(6)(i) for one

-481, SE-59-3A start times. year or until the thru -6A, and next refueling

-3B thru -6B outage.

VR-28 3.4.1.1 IWV-3521: Chemical and Part-stroke exercise Relief Gr anted Test volume control quarterly. (g)(6)(i) frequency valves: Full-stroke exercise V-2443 and -2444 each refueling.

VR-29 Appen. 8 IWV-3520: SI valves: Part-stroke exercise Approved per Item 15 Test method V-3101, -3102 5, quarterly. GL 89-04, and frequency -3103 Verify closed at Position 2, cold shutdowns. Relief not Sample disassembly 5 evaluated in TER.

inspection, GL 89-04, Position 2.

VR-30 Appen. B IWV-3520: SI valves: Part-stroke exercise Approved per Item 15 Test method V-3104 and -3105 quarterly. GL 89-04, and frequency Verify closed at Position 2, cold shutdown. Relief not Sample disassembly 5, evaluated in TER.

inspection, GL 89-04, Position 2.

VR-31 Appen. B IWV-3520: Feedwater Part-stroke exercise Approved per Item 15 Test method valves: quarter ly. GL 89-04, and frequency V-9303, -9304, Sample dissassembly Position 2,

-9305 8L -12507 and inspection, GL Relief not 89-04, Position 2. evaluated in TER.

Page Na.

11/01/91 ST. LUCIE UNIT ONE SER TABLE 1

SUMMARY

OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREHENT IDENTIFICATION METHOD OF BY NUMBER -& SUBJECT TESTING USNRC 1'I VR-32 3.7.2.1 IWV-3521: Sampling 5 CIVs: Leak test per Relief Granted Test V-27101 and Appendix J every (g)(6)(i) frequency -27102 'ears. 2 VR-33 3.2.1.3 IWV-3413(b): SI valves: Observe operation Interim Relief Measure HCV-3618, -3628, du'ring exercise. Granted stroke time -3638, and -3648 Do not measure (g)(6)(i) for one stroke times. year or until the next refueling outage.

VR-34 Appen. B IWV-3427(b): Various CIVs Leak rate test per Approved per Item 20 Leak rate listed in the GL 89-04, GL 89-04, test method program Position 10. Position 10, Relief not evaluated in TER.

VR-35 3.7.3.1 IWV-3413(b): Intake cooling Observe operation Interim Relief Measure water valves: quarterly. Granted stroke times TCV-.14-4A and Do not measure (g)(6)(i) for one

-48 stroke time. year or until the next refueling outage.

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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM FLORIDA POWER AND LIGHT COMPANY ST. LUC I E UNIT ONE

1. INTRODUCTION This is a technical evaluation of relief requests in the pump and valve inservice testing (IST) program for St. Lucie Unit One (St.Lucie-l) submitted by Florida Power and Light Company (FPL).

With a letter dated January 3, 1990 FPL submitted the St. Lucie-1 pump and valve IST program. This program covers the second ten-year IST interval, which runs from February ll, 1988 to February 10, 1998. The relief requests pertain to requirements of the ASME Boiler and Pressure Vessel Code (the Code),Section XI, 1983 Edition through summer 1983 Addenda and 10 CFR 50.55a.

FPL requested relief from the Code requirements for specific pumps and valves. These requests are reviewed using the acceptance criteria of 10 CFR 50.55a and NRC Generic Letter No. 89-04 (GL 89-04), "Guidance on Developing Acceptable Inservice Testing Programs."

These TER relief request evaluations are applicable only to the components or groups of components identified by the submitted requests.

These evaluations may not be extended to apply to similar components that are not identified by the request at this or another comparable facility without separate review and approval by NRC. Further, the evaluations and recommendations are limited to the requirement(s) and/or. function(s) explicitly discussed in the applicable TER section. For example, the results of an evaluation of a request involving testing of the containment isolation function of a valve cannot be extended to allow the test to satisfy a requirement to verify the valve's pressure isolation function, unless that extension is explicitly stated.

Section 2 of this report presents FPL's bases for requesting relief from the requirements for pumps followed by an evaluation and the conclusion. Section 3 presents similar information for valves.

Appendix A lists piping and instrument diagrams (PS.IDs) and figures used during this review.

Appendix B lists program inconsistencies and omissions, and identifies needed program changes.

The review of the FPL justifications for exercising Category A, B, and C valves during cold shutdowns and refueling outages instead of quarterly during power operations found the justifications to be acceptable except as noted in Appendix B.

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2. PUMP TESTING PROGRAM The following relief requests were evaluated against the requirements of the Code,Section XI, 10 CFR 50.55a, and applicable NRC positions and guidelines. A summary and the licensee's basis for each relief request is presented. The evaluation and recommendation follow. They are grouped according to topic or system.

2. I All Pum s in the IST Pro ram

2. 1. I Bearin Tem erature Measurements 2.1.1.1 temperatures

~gtifg . PR.I 2 t 11 ff annually per Section XI, Paragraphs IWP-3300 and -4310, for 1gt lg all centrifugal pumps in the IST program. The licensee proposes to monitor other parameters to determine pump mechanical condition and monitor for degradation during routine surveillance testing.

2. l. I. l. 1 Licensee's Basis for Re uestin Relief--The data associated with bearing temperatures taken at one year intervals provides little statistical basis for determining the incremental degradation of a bearing or any meaningful trending information or correlation. Vibration measurements are significantly more reliable indication of pump. bearing degradation than are temperature measurements. All pumps in the IST program are subjected to vibration measurements in accordance with IWP-4500. Although excessive bearing temperature is an indication of an imminent or existing bearing failure, it is highly unlikely that such a condition would go unnoticed during routine surveillance testing since would manifest itself in other obvious indications such as audible noise, it unusual vibrations, increased motor current, etc.

Alternate Testin  : None 2.1.1.2.2 2 I I 2 I 2 I g an unreliable method for detecting a change in bearing condition.

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tl temperature rise in a failing bearing usually occurs only just before failure.. This makes detecting impending bearing failure by annual bearing temperature measurement very unlikely. Bearing temperatures taken yearly provide little statistical basis for determining the incremental degradation of a bearing. Requiring this measurement would be a hardship on the licensee without a compensating increase in the level of plant safety.

Measurement of pump vibration, per the Code, provides much more useful information about bearing condition. The proposed testing gives adequate assurance of operational readiness.

Based on the determination that the proposal provides a reasonable assurance of operational readiness and compliance with the Code would result in hardship without a compensating increase in the level of safety, relief should be granted as requested.

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2. 1.2 Instrument Ran e

2. 1.2. 1 Relief Re uest. PR-2 requests relief from the instrument full-scale range requirements of Section XI, Paragraph IWP-4120, for various pumps in the program. The licensee proposes to use portable instruments with an accuracy equal to or better than the Code, but that might exceed three times the reference value.

2. 1.2. 1. 1 Licensee's Basis for Re uestin Relief--Table IWP-4110-1 requires the accuracy of instruments used to measure temperature and speed to be equal to or better than +5% for temperature and +2% for speed, both based on the full-scale reading of the instrument. This means that the accuracy of the measurement can vary as much as +15% and +6%,

respectively, assuming the range of the instruments extended to the allowed maximum.

These IST parameters are 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 will be used where the reading accuracy is at least equal to Code requirement for full-scale accuracy. This will ensure that the measurements are always more accurate than the accuracy as determined by combining the requirements of Table IWP-4110-1 and Paragraph IWP-4120.

Alternate Testin : Whenever portable instruments are used for measuring pump speed or bearing temperatures, the instruments will be such that the reading accuracy is +5% for temperature and +2% for speed.

2. 1.2. 1.2 Evaluation--Portable test equipment is often used in performing surveillances. Portable instrumentation is frequently more accurate and sensitive than installed instrumentation. This is particularly true of instrumentation used to measure pump speed and bearing temperature. This equipment might not meet the IWP-4120, full-scale range requirements (full-scale range 3 times the reference value or less).

However, the licensee specified that the accuracy of the test measurement would be equivalent to or more accurate than the Code accuracy requirement irrespective of the instrument full scale range. Portable test equipment with reading accuracies that meet the Code accuracy requirements can be used in several applications and give meaningful data for both trending and monitoring for pump degradation.

The licensee proposes to use test instruments with reading accuracies that meet the Code accuracy requirements. This should provide measurements sufficiently accurate to assess pump condition and monitor for degradation.

Based on the determination that the proposal is essentially equivalent to the Code and provides an acceptable level of quality and safety, relief should be granted as requested.

2. 1.3 Stat'c Pum Inlet Pressure 1.1.1.1 ~Rff 1' pressure before starting the RR-pump 1 <<11 f 1' for the test, per Section 1

XI, Table IWP-3100-1 for all pumps in the IST program. The licensee proposes to

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measure inlet pressure prior to start only if .the pump is idle. If operating, only running inlet pressure will be recorded.

2. 1.3.1. I If icensee's Basis for Relief-- the pumps being tested are in operation as a result of plant or system needs, it is unreasonable to reconfigure system lineups simply to provide for measurement of static inlet pressure. Inlet pressure prior to pump start-up is not a significant parameter needed for evaluating pump performance or its material condition.

Alternate Testin : When performing a test on a pump that is already in operation due to system or plant requirements, inlet pressure will only be measured during pump operation.

2. 1.3. 1.2 Evaluation-- It is not reasonable to stop a running pump solely to ensure suction pressure is adequate and to record it.

Section XI, Paragraph IWP-3400(b) states pumps that are operated more frequently than every 3 months need not be run or stopped for a special test, provided the plant log shows each such pump was operated at least once every 3 months at the reference conditions, and the quantities specified were measured, observed, recorded, and analyzed. Therefore, operating pumps need not be stopped to measure pump inlet pressure, however, this parameter should be measured if the pump is idle immediately prior to the pump test.

Insufficient pump suction pressure would cause cavitation and be indicated in the evaluation of operating characteristics, such as differential pressure, flow, and vibration. A significantly blocked or degraded suction would likely cause excessive vibration or loss of head and would be evident during pump operation.

Although the Code does not specifically exempt the inlet pressure measurement when a pump is not running, the provision of IWP-3400(b) only requires taking those measurements performed at reference conditions, which does not include the inlet pressure measurement required to be taken before pump start-up. Therefore, when performing a test on a pump that is already in operation, the only required inlet pressure measurement is the one taken with the pump operating at reference conditions and the requested relief is not necessary.

2.2 Diesel Fuel Oil Intake Coolin Water and Boric Acid S stems 2.2.1 Flow Measurement 2211 ~fi f 2 . 2111 2 1 11 ff 1 2 fl rate per Section XI, Paragraph IWP-4600, for the diesel fuel oil transfer pumps, DOT 1A and IB, and proposes to calculate it based on the change in level in the fuel oil day tank over time.

2.2. I. I. 1 Licensee's Basis for Re uestin Re ief--The only available test circuit for these pumps consists of the normal day tank fill lines from the diesel oil storage tanks. There is a minimum flow recirculation line, however no flow instrumentation is installed.

Therefore, the only practical method of determining pump flow rate is by calculating the fill rate of the day tanks. Furthermore, due to the

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capacity of the fuel oil pumps and the available volume of oil from the low-level pump start point to the high-level setpoint, the run time for a pump is limited, precluding the Code required 5-minute minimum run time before taking readings.

Alternate Testin : When testing these pumps, the flow rate will be calculated based on the measured change in the diesel fuel oil day tank level over an elapsed period of pump run time. The starting point for taking measurements will be when the system conditions have stabilized.

2.2. 1. 1.2 Evaluation--The diesel fuel oil transfer pumps have only two discharge paths. These are the minimum flow recirculation line and the normal day tank fill line. Neither has installed, flow instrumentation. Therefore, it is impractical to directly measure pump flow rate. However, flow rate can be readily obtained by measuring the level change of the day tank over time. This indirect measurement should provide accurate and repeatable data. It can be used to monitor pump degradation provided the calculations are sufficiently accurate. The system would have to be redesigned and modified to permit direct measurement. This would be costly and burdensome to the licensee. The proposed testing should give adequate assurance of pump operational readiness and provide a reasonable alternative to the Code.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the proposed alternate testing, relief should be granted provided that the results are at least as accurate as measurements taken from installed instruments meeting the Code accuracy requirements.

1 2.2.2 Pum Suction and Differential Pressure R.f.l..l ~f1 i f <<. PR-8 8 Pll-ll 8 1 11 ff 1 8

inlet and differential pressure per Section XI, Table IWP-3100-1, for boric acid make up pumps, BAN 1A and 1B, intake cooling water pumps, ICW 1A, 1B, and 1C, and diesel fuel oil transfer pumps, DOT 1A and 1B. The licensee proposes to measure the height of fluid above the pump suction and calculate inlet and differential pressure.

Note The text of relief requests PR-8 and PR-11 differs. However, the technical concern is the same. Therefore, these requests are evaluated together.

2.2.2. 1. 1 Licensee's Basis for Re uestin Relief--The system installations do not provide any mechanism for measuring pump suction pressures, and thus, the requirement for measuring suction pressure and pump differential pressures cannot be satisfied. The intake cooling water pumps are vertical line shaft pumps submerged in the intake structure with no practical means of measuring pump inlet pressure. A measure of pump suction pressure can, however, be determined by calculation using the height of liquid in the intake pit, boric acid, and diesel oil storage tanks. Since there is essentially fixed resistances between the tanks and the pumps and the intake pit level is relatively constant, this will provide a consistent value for suction pressures.

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Alternate Testin : The intake cooling water, .boric acid make up, and diesel fuel oil transfer pump suction pressures will be calculated based on the height of liquid in the associated tanks or pit once during each inservice test. Subsequently, these calculated values will be used to determine pump differential pressures for evaluation of pump parameters.

Since the tank and pit levels are not expec'ted to vary significantly during the tests, tank and pit levels and associated calculations will only be taken once during each test instead of prior to pump operation and during operation as required by Table IWP-3100-1.

2.2.2. 1.2 Evaluation--It is impractical to directly measure inlet or differential pressure for the identified pumps, as there are no installed instruments. Significant system design changes and modification or replacement of equipment are needed for direct measurement. These changes would be costly and burdensome to the licensee.

Inlet pressure for these pumps is due to the height of water above the suction point. It can be calculated. This is a relatively simple calculation. It is not impractical or burdensome. The calculated inlet pressure can be used with discharge pressure to determine differential pressure. This can be used with flow rate to assess pump hydraulic condition per the Code. This method is a reasonable alternative provided the calculations are sufficiently accurate.

Since direct measurement of inlet and differential pressure is impractical and burdensome, relief should be granted provided that the calculated inlet and differential pressures are determined at least as accurately as would be indicated by installed instruments meeting the Code accuracy requirements.

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3. VALVE TESTING PROGRAM The following valve relief requests were evaluated against the requirements of the Code,Section XI, 10 CFR 50.55a, and applicable NRC positions and guidelines. A summary and the licensee's basis for each relief request is presented. The evaluation and recommendation follow.

They are grouped according to system and Code Category.

3. 1 General Relief Re uests

3. 1. 1 Test Fre uenc R.l.l.l requirement

~R1i fR for all valves that

<<. Rlt-1 1 t 11 ff tt t tf cannot be exercised at power per Code 1 1 Paragraphs IWV-3412, -3415, and -3522. The licensee proposes to test them during cold shutdowns on a deferred basis, if required.

3. 1. 1. 1. 1 Licensee's Basis for Re uestin Relief--In many instances testing of all valves designated for testing during cold shutdown cannot be completed due to the brevity of an outage or the 'lack of plant conditions needed for testing specific valves. It has been the policy of the NRC that if testing commences in a reasonable time and reasonable efforts are made to test all valves, then outage extension or significant changes in plant conditions are not required when the only reason is to provide the opportunity for completion of valve testing. ASME/ANSI OMa-1987, Operation and Maintenance of Nuclear Power Plants, Part 10 (Paragraphs 4.2. 1.2 and 4.3.2.2) recognizes this issue and allows deferred testing as set forth below.

Alternate Testin  : For those valves designated to be exercised or tested during cold shutdown, exercising shall commence as soon as practical after the plant reaches a stable cold shutdown condition as defined by the applicable Technical Specification but no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutdown. If an outage is sufficiently long enough to provide for testing of all valves required to be tested during the cold shutdown period, the 48-hour requirement need not apply if all valves are tested during the outage. Valve testing need not be performed more often than once every three months except as provided for in IWV-3417(a).

Completion of all valve testing during a cold shutdown outage is not required if plant conditions preclude testing of specific valves or if the length of the shutdown period is insufficient to complete all testing.

Testing not completed prior to start-up may be rescheduled for the next shutdown in a sequence such that the test schedule does not omit nor favor certain valves or groups of valves. It should be noted that there are two conditions of cold shutdown identified in the program tables (Appendices D and E), namely pressurized and vented. For the purpose of this requirement, the term "cold shutdown" refers to the respective condition as noted. in the tables. The program tables identify those valves to which cold shutdown testing applies. Refer to Appendix G for discussion of the reasons and justification for allowing cold shutdown instead of quarterly testing.

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3. 1. 1. 1.2 Evaluation--The staff does not require licensees to complete all testing, identified for the cold shutdown, before start-up.

To require that all cold shutdown testing is completed before start-up could delay the return to power. This would be a hardship on the licensee. The proposal is similar to staff approved alternatives. It provides a reasonable alternative to the Code test frequency requirements.

However, this approval is limited to valves that can be tested during any cold shutdown.

The licensee has included the statement "...Completion of all valve testing during a cold shutdown outage is not required if plant conditions preclude testing of specific valves...." For any valve, or class of valves, that cannot be tested during each cold shutdown of sufficient duration (such as, valves that cannot be tested when reactor coolant pumps are operating), a separate relief request must be submitted. It must be approved by NRC prior to implementation since the test interval could exceed the time period allowed by the Code.

Based on the determination that the proposal provides a reasonable alternative to the Code, and considering the hardship on the licensee without a compensating increase in safety if the Code test frequency requirements were imposed, relief should be granted as requested. However, it is limited to those valves that can be tested during any cold shutdown.

Relief is denied for valves that cannot be tested during any cold shutdown.

3. 1.2 Containment Isolation Valves

3. 1.2. I Relief Re uest. VR-5 requests relief from measuring and assigning individual valve leak rate limits, per Section XI, Paragraphs IWV-3426 and -3427 to several containment isolation valves (CIVs) listed in the IST program. The licensee proposes to leak test,and evaluate them in groups.

3. 1.2. 1. I Licensee's Basis for Re uestin Relief--Due to the configuration of the system piping and components, in many cases individual leakage rate tests are impractical. In these cases it is customary to perform tests with the test volume between valves in series or behind valves in parallel paths.

Alternate Testin : In those cases 'where individual valve testing is impractical, valves will be leak tested simultaneously in multiple valve arrangements and a maximum permissible leakage rate will be applied to each combination of valves. Test results from tests of multiple valves will be evaluated in accordance with IWV-3426 and -3427.

3.1.2. 1.2 Evaluation--The licensee proposes to leak rate test identified CIVs in groups and to evaluate the leakage per IWV-3426 and

-3427. It is impracticable to leak rate test some valves individually, due to the absence of test connections or isolation valves. System redesign and modification might be needed to allow it. This would be costly and burdensome to the licensee.

The Code required testing monitors changes in the condition of individual components to assess their operational readiness. Where 10

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practicable, valves should be individually tested and evaluated as required, even if they are in groups with others that cannot be tested individually. In cases where it is impracticable to test individually, testing in groups can be acceptable. This is provided the group leakage limits are set such that excessive leakage through any valve in the group is detected. If this limit is exceeded, the group must be declared inoperable and corrective action taken before return to service.

Based on the determination that compliance with the Code is impracticable and burdensome, and considering the proposal, relief should be granted from individually testing valves that can be practically tested only in groups, with the following provisions. The group leakage rate limits should be assigned, conservatively based on the smallest valve in the group, so that corrective action will be taken whenever the leak tight integrity of any group tested valve is in question. Relief should be denied for those valves that can be tested individually. The licensee should revise their procedures, as necessary, to be consistent with this approach.

3. 1.3 Pressure Isolation Valves 3.1.3.I ~Rii f . VR-2 q 1i f f t di 9 leakage rates, per Section XI, Paragraph IWV-3427(b), for the pressure isolation valves (PIVs) listed in the IST program. The licensee proposes to leak test and evaluate these valves per St. Lucie Unit 1 Technical Specifications, Table 3.4.6-1.

3. 1.3. 1. 1 Licensee's Basis for Re uestin Relief--Leak testing of these valves is primarily for the purpose of confirming their capability of preventing overpressurization and catastrophic failure of the safety injection piping and components. In this regard, special'eakage acceptance criteria is established and included in the St. Lucie I Technical Specifications (Table 3.4.6-1) that addresses the question of valve integrity in a more appropriate manner for these valves. Satisfying both the Technical Specification and the Code acceptance criteria is not warranted and implementation would be difficult and confusing.

Alternate Testin : The leakage 'rate acceptance criteria for these valves will be established per the St. Lucie Unit 1 Technical Specifications, Table 3.4.6-1.

1. Leakage rates less than or equal to 1.0 gpm are considered acceptable.

2. Leakage rates greater than 1.0 gpm but less than or equal to 5.0 gpm are considered acceptable if the latest measured rate has not exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50K or greater.

3. Leakage rates greater than 1.0 gpm but less than or equal to 5.0 gpm are unacceptable if the latest measured rate exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 505 or greater.

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4. Leakage rates greater than 5.0 gpm are unacceptable.

3 . 1.3 . 1.2 Evaluation-- IWV-3427(b) establishes trending requirements for leakage rate measurements of Category A valves. The Code requires comparison of measured leakage rates with previous rates and the margin between the previous rate and the maximum permissible rate has if been reduced by 50% or more, the testing frequency must be doubled.

Corrective action is required when a trend derived from three or more tests, projects that the leakage rate of the n'ext test will exceed the maximum rate by greater than 10%. The licensee requests relief from IWV-3427(b) and proposes to use the leak rate acceptance criteria of the St. Lucie Unit 1 Technical Specifications (TS). The proposed testing incorporates leak rate trending criteria similar to the Code and is more conservative than the criteria of IWV-3427(b) in some respects and at least equivalent overall.

The St. Lucie TS consider a valve unacceptable when a measured leakage rate reduces the margin between the previous leakage rate and the maximum permissible rate by 50% or more. Taking actions to reduce the leakage rates of these valves when this margin is so reduced is more conservative than doubling the test frequency for the same margin reduction per IWV-3427(b). The licensee's criteria does not include provisions to project valve leakage rates based on three or more test measurements as does the Code. However, when the rate of increase in valve leakage remains at or below the licensee's 50% margin criteria discussed above, it is unlikely that the maximum permissible rate would be exceeded prior to the next scheduled test. Therefore, the proposed testing should provide reasonable assurance of the PIVs'bility to isolate low pressure systems from RCS pressure. Based on the above considerations, the licensee's proposed testing is essentially equivalent to the Code requirements and should provide an acceptable alternative to the Code.

Based on the determination that the proposed testing is equivalent to or more conservative than the Code requirements, relief should be granted from the requirements of IWV-3427(b) as requested.

3.2 Safet In'ection S stem 3.2.1 Cate or A and A C Valves 1.1.1.1 ~fti f R <<. RR-ll q t 11 f f tt t t frequency requirements of Section XI, Paragraph IWV-3521, for LPSI header to RCS injection line check valves, V-3114, -3124, -3134, and -3144. The licensee proposes to full-stroke exercise them open during cold shutdowns.

Reverse flow closure will be verified in conjunction with PIV leak testing at least once every 2 years.

3.2. 1. 1. 1 Licensee's Basis for Re uestin Relief--Full-stroke exercising of these valves would require operating a low pressure safety injection (LPSI) pump at nominal accident flow rate and injecting into the reactor coolant system since no full flow recirculation path exists. At power operation this is not possible because the LPSI pumps do not develop sufficient discharge pressure to overcome reactor coolant system pressure.

These are simple check valves with no external means of position 12

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indication, thus the only practical means of verifying closure is by performing a leak test or reverse flow test. Performing leak tests of these valves involves a considerable effort such that testing during operation or at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

Alternate Testin : These valves will be full-stroke exercised to the open position during cold shutdown periods per Relief Request VR-1. At least once every two years these valves will be verified to close in conjunction with PIV leak testing.

3.2. 1. 1.2 Evaluation--It is impractical to full or part-stroke exercise these valves open during power operation. The only flow path through these valves is from the LPSI pumps into the RCS. The LPSI pumps do not develop sufficient discharge head to overcome RCS pressure and establish flow through the valves. The licensee indicated that these valves would be full-stroke exercised with flow during cold shutdowns in accordance with Relief Request VR-1. Exercising these valves open during cold shutdowns should provide reasonable assurance of their operational readiness. VR-1 is evaluated in Section 3. 1. 1. 1 of this TER.

These are simple check valves without external position indication.

The only practical means of verifying valve closure is by a leak or reverse flow test. The system P8 ID shows motor-operated isolation valves upstream of each check valve with drain lines tapping off between the isolation and the check valves. Using these provisions, it might be practical to verify the reverse flow closure of these valves at the Code specified frequency.

The licensee has not demonstrated the impracticality of performing this testing either quarterly or during cold shutdowns nor have they shown that doing so would be a hardship without a compensating increase in the level of quality and safety. Therefore, relief should not be granted; The licensee's proposal to full-stroke exercise these valves open during cold shutdowns should be acceptable. However, unless an adequate technical justification is provided and approved, relief should not be granted to defer verifying their reverse flow closure until once every two years in conjunction with PIV leak rate testing.

2.2.1.2 ~R1ifR . RR-9 q t 11f1 tt t tf requirements of Section XI, Paragraph IWV-3521, for the HPSI pump discharge q 9 check valves V-3405, -3414, and -3427. The licensee proposes to manually exercise them closed quarterly and full-stroke exercise them open each refueling outage.

3.2. 1.2. 1 Licensee's Basis for Re uestin Relief--full-stroke exercising these valves to the open position requires injection into the RCS via the HPSI pumps. During plant operation this is. precluded because the HPSI pumps cannot develop sufficient discharge pressure to overcome primary system pressure. During cold shutdown conditions, operation of the HPSI pumps is restricted to preclude RCS system pressure transients that could result in exceeding the pressure-temperature limits specified in the TS, Section 3.4.9. Partial stroke exercising during quarterly pump testing is not practical since minimum flow lines branch off upstream of these valves.

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Alternate Testin: These valves will be manually exercised and verified closed quarterly and full flow exercised to the open position during each reactor refueling outage.

3.2. 1.2.2 Evaluation-- It is impractical to full-stroke exercise these valves during power operation. This. is because the HPSI pumps do not provide sufficient discharge head to overcome RCS pressure and establish flow through- them. Partial-stroke testing during quarterly pump tests is impractical since the minimum flow lines branch off upstream of these check valves. However, the licensee has not addressed the possibility of partial-stroke exercising them open when shutting down to cold shutdown.

The RCS pressure would be lower. At the lower pressure the HPSI pumps develop ade'quate head to inject water through them. The increased boron and make-up injected into the RCS during a partial-stroke exercise could help maintain RCS inventory and achieve the required shutdown boron concentration.

It is impractical to partial or full-stroke'exercise these valves during low temperature and pressure cold shutdown conditions. Use of the HPSI pumps is restricted to prevent LTOP of the RCS. This could result in significant damage to important system components. System design changes and modifications are required to full-stroke exercise these valves during power operation or cold shutdown. This would be burdensome and costly to the licensee.

A means of determining valve position is needed when manually exercising these valves closed. This is to ensure the disk travels to its closed seat and is not binding or sticking. The proposal to manually exercise and verify closure quarterly and full-stroke exercise these valves open each refueling outage provides a reasonable 'assurance of operational readiness. However, the licensee should develop a method to partial-stroke exercise these valves open on the approach to cold shutdown. The licensee should use a positive means to ensure they fully close when manually stroked closed.

Based on the determination that compliance with the Code is impractical and burdensome, and considering the proposal, relief should be granted provided that the licensee develops a method to partial-stroke exercise these valves open on the approach to cold shutdown, if practicable, and verifies that they fully close when they are manually stroked closed.

3.2.1.3 ~li R t. YR-33 q t* 1i f f i g th stroke time of power-operated valves HCV-3618, -3628, -3638, and -.3648, the flow control valves in the SI check valve test lines, per Section XI, Paragraph IWV-3413(b). The licensee proposes to verify proper operation during exercising and fail-safe testing at cold shutdown by direct observation. Stroke times will not be measured.

3.2. 1.3. I icensee's Basis for Re uestin Relief--These valves are provided with a controller that positions the valve in response to a variable indicator-controller device. In order to stroke these valves and perform fail-safe tests, fuses in the control circuits are removed which, in turn, causes the loss of valve position indication. Thus measurements of valve closure times are not practical.

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Alternate Testin: During valve exercising and fail-safe testing performed under cold shutdown conditions, an individual will be stationed at the valve to verify proper operation. Valve stroke times will not be measured.

3.2. 1.3.2 Evaluation--It is difficult to accurately measure the stroke time of these valves. They do not have manual control switches, but instead receive position commands from a variable control signal. This signal is manually controlled by a station operator. The operator's speed of varying the signal would be reflected in the valve stroke time. This makes the repeatability of the test and evaluation of data difficult. An alternate method, deenergizing the valve by pulling fuses does not yield accurate stroke times. Design changes and modifications might be needed to stroke time these valves. This would be costly and burdensome to the licensee.

However, some method of accurately stroke timing or otherwise adequately evaluating these valves'ondition is necessary for assessing their operational readiness. The licensee should actively pursue an alternate test method. methods employing magnetics, acoustics, ultrasonics, or other technologies should be investigated for their suitability. The proposal to verify the valves are opening and closing quarterly during surveillance testing should. be acceptable on an interim basis, but, it does not adequately evaluate valve condition and does not present a reasonable long term alternative.

Based on the determination that complying with the Code requirements is impractical and burdensome and considering the licensee's proposal, relief should be granted for an interim period of one year or until the next refueling outage, whichever is longer. During this period, the licensee should develop a method of accurately measuring stroke time or some other means to adequately monitor valve condition.

3.2. 1.4 Relief'Re uest. VR-13 requests relief from the exercising requirements of Section XI, Paragraph IWV-3522, for V-3217, -3227, -3237, and -3247, the combined safety injection header check valves. The licensee proposed to verify valve closure in conjunction with the PIV leak rate testing at refueling outages.

In VR-13 the licensee also requests relief from full-stroke exercising these valves open per the Code requirements and proposes to part-stroke them open during cold shutdowns and full-stroke through a sample disassembly and inspection program. The licensee's proposed full-stroke exercise open test is in accordance with GL 89-04, Position 2, therefore, relief is granted by the GL for the open function of these valves and need not be evaluated in this TER.

3.2. 1.4. 1 Licensee's Basis for Re uestin Relief--These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or backflow test. Performing leak tests of these valves requires access to the containment building and involves a considerable effort such that testing during operation or at each cold shutdown outage would constitute an unreasonable burden on the plant staff.

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Alternate Testin : At least once every two (2) years these valves will be verified to close in conjunction with PIV leak testing.

3.2. 1.4.2 Evaluation--These are simple check valves located inside containment. They do not have remote position indication nor is there an observable system parameter that can indicate valve closure. The only practical method of verifying valve closure is leak rate or back flow testing. It is impractical to leak test these valves quarterly because the valves and test connections are located inside containment and are inaccessible during power operations. Non-intrusive techniques might be used to verify valve closure, however, these methods require access to the valves and would, therefore, be impractical during power operations.

Leak rate or non-intrusive testing of these valves involves complex procedures requiring considerable setup and recovery. This work would be .

inside containment in areas of possible high background radiation levels and other personnel hazards. It would be burdensome to perform this testing during. cold shutdowns because of ALARA and personnel safety concerns, further performing this testing during cold shutdowns could delay plant start-up. A system modification, such as replacing these valves with ones having position indication, would be necessary to allow closure verification at the Code frequency. It would be burdensome to require the licensee to make the necessary modifications due to the costs involved.

The proposal to verify valve closure at least once every two years in conjunction with PIV leak rate testing should provide a.reasonable assurance of the capability of these valves to perform their closed safety function. Therefore, the alternate testing method and frequency for closure verification is acceptable.

Based on the determination that complying with the Code requirements is impractical and burdensome and considering the licensee's proposal, relief should be granted as requested.

3.3 Containment S ra S stem 3.3. 1 Cate or C Valves 3.3. 1. 1 Relief Re uest. VR-18 requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for containment spray pump discharge check valves, V-07129 and -07143. The licensee proposes to partial-stroke exercise them quarterly and full-stroke exercise them each refueling outage.

3.3. 1. 1. 1 Licensee's Basis for Re uestin Relief--Full-stroke exercising of these valves would require operating each containment spray pump at nominal accident flow rate. Since exercising these valves through the normal containment spray flow path would result in spraying down the containment, the only practical flow path available for such a test requires pumping water from the RWT to the RCS via the shutdown cooling loops. At cold shutdown, the shutdown cooling system cannot provide sufficient letdown flow to the RWT to accommodate full design flow from the RWT while maintaining the necessary core cooling function.

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. Alternat Testin : Each of these valves will be partial-stroke exercised quarterly in conjunction with testing of the containment spray pumps via the minimum flow test line. During each refueling outage, each valve will be exercised at least once to demonstrate full-stroke capability.

3.3. 1. 1.2 Evaluation--It is impractical to full-stroke exercise these valves quarterly or during cold shutdowns as flow through the normal accident flow path would result in spraying down the inside of the containment building. This would wet down components inside containment and cause equipment damage. It would also require significant clean-up efforts and produce a large quantity of radioactive waste.

The only practical flow path for full-stroke exercising is through the shutdown cooling loops. It is impractical to use this path during power operation as the shutdown cooling loops are unavailable. It is also impractical to use during cold shutdown conditions. This is because the shutdown cooling loops cannot provide sufficient letdown flow for full flow design testing and maintain the necessary core cooling. System design changes and modifications would be required to full-stroke exercise these valves quarterly or at cold shutdowns. This would be costly and burdensome to the licensee. The proposal to partial-stroke exercise these valves quarterly and full-stroke exercise them each refueling outage allows an adequate assessment of operational readiness. It provides a reasonable alternative to the Code.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the proposal, relief should be granted as requested.

3.4 Chemical and Volume Control S ste I

3.4. 1 Cate or C Valves 3.4.1. 1 Relic'f Re uest. VR-28 requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for boric acid makeup pump discharge check valves, V-2443 and -2444. The licensee proposes to partial-stroke exercise them quarterly and full-stroke exercise them each reactor refueling outage.

3.4. 1. 1. 1 Licensee's Basis for Re uestin Relief--Full-stroke testing these valves requires operating the boric acid makeup pumps at or near rated flow and verifying full accident flow through each valve.

Operating the boric acid makeup pumps (BAH pumps) discharging into the charging pump suction header requires the introduction of highly concentrated boric acid solution from the boric acid, makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS which would adversely affect plant power level and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown.

During cold shutdown, the introduction of excess quantities of boric acid is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent start-up in over-boration of the RCS. In addition to the above, there is 17

no flow rate measurement instrumentation i'nstalled in this flow path. A second circuit that recirculates water to the RMT has flow rate measuring instrumentation installed, however, it is limited to 30 gpm (BAH pump design capacity is 142 gpm).

Alternate Testin : Each of these valves will be partial-stroke exercised quarterly. During testing of the boric acid makeup pumps performed during each reactor refueling (See Relief Request PR-S), system flow rate will be.

measured to verify. full-stroke of these valves.

3.4. 1. 1.2 Evaluation--Full-stroke exercising these valves requires verifying the full design or full accident flow rate through them. To accomplish this, the BAM pumps must be run at the full design flow rate. Operating them at that rate during power operations would inject highly concentrated boric acid into the RCS. A test circuit is available at cold shutdown, but is not instrumented to measure flow.

It is impractical to full-stroke exercise these valves during power operation. The boric acid injected would cause power fluctuations and could cause a plant shutdown or trip. It is impractical to full-stroke exercise them during cold shutdown as this would over-borate the RCS and upset plant chemistry. Dilution and removal of the highly-borated coolant to allow plant start-up, would create large quantities of radioactive waste water. Processing radioactive waste is expensive. Another opti'on would be system redesign and modification, which is also expensive. Either would be burdensome to the licensee. The proposal to partial-stroke exercise these valves quarterly and full-stroke exercise them each reactor refueling outage gives adequate assurance of operational readiness. It provides a reasonable alternative to the Code.

Based on the determination that compliance with,the Code test frequency is impractical and burdensome, and considering the proposal, relief should be granted. as requested.

3.4.1.2 Relief Re uest. VR-6 requests relief from the test frequency requirements of Section XI, Paragraph IMV-3521, for check valves in the charging pump suction lines from the boric acid makeup system, V-2177,

-2190, and -2191. The licensee proposes to full-stroke exercise these valves each refueling outage.

Note The licensee indicated that relief request VR-6 is preapproved by GL 89-04 since it was submitted prior to April 3, 1989. A comparison of VR-6 from the IST program dated January 3, 1990, with relief requests CVCS-1 and -2 from the licensee's IST program submitted by letter dated September 4, 1987, revealed substantive differences.

Therefore, VR-6 is not preapproved and is evaluated below.

3.4. 1.2. 1 Licensee's Basis for Re uestin Re e --Testing these valves in the open direction requires the introduction of highly concentrated boric acid solution from the boric acid makeup tanks to the suction of the charging pumps. This, in turn, would result in the addition of excess boron to the RCS which would adversely affect plant power level 18

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and operational parameters with the potential for an undesirable plant transient and a plant trip or shutdown. Duriiig cold shutdown, the introduction of excess quantities of boric acid is undesirable from the aspect of maintaining proper plant chemistry and the inherent difficulties that may be encountered during the subsequent start-up. Testing V-2190 and V-2191 in the closed direction should be done following the open exercise and is best performed in conjunction with testing of the boric acid makeup pumps during each reactor refueling outage.

Alternate Testin : These valves will be exercised as required during each reactor refueling outage.

3.4. 1.2.2 Evaluation--Exercising these check valves introduces highly concentrated boric acid to the suction of the charging pumps. It is impractical to full or partial-stroke exercise them at power. Injecting concentrated boric acid into the RCS would cause reactor power fluctuations and could cause a plant shutdown or trip. A test circuit is available at cold shutdown, but is not instrumented to measure flow.

It is impractical to full-stroke exercise these valves during cold shutdown as this would over-borate the RCS and upset plant chemistry.

Oilution by removal of the highly-borated coolant to allow plant start-up would create large quantities of radioactive waste water. This might delay the return to power. Also, processing radioactive waste is expensive.

Another option would be system redesign and modification, which is also expensive. Either would be burdensome to the licensee. The proposal to full-stroke exercise these valves each reactor refueling outage gives adequate assurance of operational readiness and provides a reasonable alternative to the Code.

However, the licensee has not shown impracticality nor 'hardship to partial-stroke exercise these valves on the approach to cold shutdown.

Boric acid is added to the RCS to maintain adequate shutdown margin during cold shutdown. The small amount of boric'cid added by a partial-stroke test of these valves would not significantly affect the RCS shutdown chemistry. The licensee should develop a method to partial-stroke exercise these valves on the approach to cold shutdown if practicable.

Based on the determination, that compliance with the Code frequency requirements is impractical and burdensome, and considering the proposal, relief should be granted provided the licensee develops a method to partial-stroke exercise these valves when approaching cold shutdown or documents the reason this testing is impractical.

3.5 Emer enc Oiesel Generator S stem 3.5. 1 Cate or B Valves 3.5.t.l ~R1i f <<. VR-2i q 1i f f th t k measurement requirements of Section XI, Paragraph IWV-3413(b), for the diesel air start valves, FCV-59-1A1 through -4A1, -181 through -481, SE-59-3A through -6A, and -3B through -6B. The licensee proposed to

.measure the emergency diesel generator start times in lieu of stroke timing the above valves.

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3.5. l. l. I Lice see's Basis for Re estin Relief--These valves are integral. with the diesel air start system for each emergency diesel generator with no valve position indication mechanism and, as such, there is no practical method for measuring the stroke times of each individual valve. If a valve were to fail to stroke as required it would be reflected in an unacceptable starting time for the respective diesel generator.

Alternate Testin : These valves will be exercised in conjunction with testing of the emergency diesel generators. The stroke times of the individual valves will not be measured but the starting time for each diesel generator will be verified to be acceptable.

3.5. 1. 1.2 Evaluation--These air start solenoid valves are small and rapid acting. They are completely enclosed. They operate from an engine start control signal rather than a control switch. They do not have remote position indication or any external means to determine valve position. Therefore, it is impractical to directly measure individual valve stroke times using normal test techniques. System design changes and modifications might be required to directly time these valves. These modifications would be costly and burdensome.

These valves operate rapidly to admit starting air to the diesel to start it within the allowed time interval. Significant degradation or valve failure during diesel testing might be indicated by increased diesel generator start times and prompt an investigation into the cause of the increase. However, the licensee has not indicated the degree of redundancy in the diesel air start system or whether air start trains are alternated during testing. If the air start trains are fully redundant and both are used during testing, failure or degradation of one or more air. start valves might not cause a significant increase in diesel start times. Therefore, the licensee's proposal might not provide a means of detecting valve degradation.

The licensee should develop a test that monitors valve condition to assess operational readiness, or should demonstrate the adequacy of the proposed testing. It might be possible to develop a method of measuring valve stroke times, such as using non-intrusive diagnostic techniques. If stroke times determined by such an alternate method are not sufficiently repeatable to permit trending, the licensee could classify these valves as rapid-acti.ng valves. Another alternative might be to establish an appropriate maximum stroke time limit using the guidelines of GL 89-04, Position 5, and to verify that stroke times remain under this limit. It would be burdensome to require immediate development of a means of monitoring for valve degradation. Therefore, an interim period should be provided to develop a method of performing this testing. The proposal of verifying valve operational readiness by quarterly exercising during diesel generator testing should provide an acceptable level of quality and safety during the interim period.

Based on the impracticality of measuring valve full-stroke times, the burden on the licensee if the Code requirements are imposed, and considering the proposed alternate testing, interim relief should be granted for one year or until the end of the next refueling outage, whichever is longer. During this interim period the licensee should 20

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develop a method of monitoring for valve degradation or demonstrate the adequacy of the proposed testing.

3.5. 1.2 Relief Re uest. VR-26 requests relief from measuring stroke times for SE-59-lA and -18, the solenoid operated isolation valves in the diesel fuel oil transfer lines, per Section XI, Paragraph IWV-3413(b). The licensee proposes to observe them locally during quarterly pump testing and monitor for audible noise or vibration. Individual valve stroke times will not be measured.

3.5. 1.2. 1 Licensee's Basis for Re uestin Relief--These valves are totally enclosed solenoid valves with no means of determining valve position, thus, measuring a stroke times is impractical. It is noted that the stroke times of these valves is not critical from the aspect of accident mitigation.

Alternate Testin  : During quarterly pump testing each of these valves will be exercised and verified to operate satisfactorily. By local observation, proper operation will be confirmed by the absence of any unusual audible noise or vibration. Valve stroke times will not be measured.

3.5. 1.2.2 Evaluation--These are enclosed solenoid-operated valves, with no externally visible position indication. It is difficult to accurately measure stroke times as there is no installed provision for determining when the valve receives a signal to operate or when it reaches the desired position.

The licensee proposes to determine operational readiness by exercising the valves and verifying the absence of any unusual audible noise or vibration. Stroke times will not be measured as required. An appropriate test method and acceptance criteria are needed to assess operational readiness. This is to ensure a severely degraded valve is declared inoperable and repaired or replaced before its return to service. Stroke timing or otherwise equivalently evaluating the condition of these valves is vital to the determination of operational readiness.

The proposed alternate testing provides some information about valve condition and should be acceptable during an interim period of one year or until the next refueling outage, whichever is longer. It does not provide a reasonable long-term alternative. The licensee should consider methods, such as ultrasonics, magnetics, and acoustics for stroke timing or otherwise monitoring the condition of these valves. A method should be developed and appropriate acceptance criteria assigned so that a severely degraded valve is. i'dentified for corrective action.

Based on the determination that the proposal provides a reasonable short, but not a long term alternative to the Code and considering the proposal, intetim relief should be granted for one year or until the next refueling outage, whichever is longer. During this period, the licensee should develop a method of accurately measuring stroke time or some other means to adequately monitor valve condition.

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3.6 Hain Steam S stem 3.6. 1 Cate or C Valves 3.6. 1. 1 Relief Re uest. VR-14 requests relief from the exercising method and frequency requirements of Section XI, Paragraph IWV-3520, for V-08117 and -08148, the main steam non-return valves, and proposed to verify valve closure by disassembly, inspection, and manual exercise of these valves on a sampling basis during refueling outages.

3.6. 1. 1. 1 Licensee's Basis for Re uestin Relief--There is no practical means or provision for verifying closure of these valves.

Alternate Testin  : During each reactor refueling outage at least one of these valves will disassembled, inspected, and manually s'troked to verify operability. Inspections shall be scheduled such that valves will be checked in a rotating sequence such that each valve is subject to inspection at least once every six (6) years. Should a valve under.

inspection be found to be inoperable, then the .remaining other valve will be inspected during the same outage, after which the rotational inspection schedule will be reinitiated.

3.6. 1. 1.2 Evaluation--These are simple check valves that are normally open to allow steam flow from the steam generators to the main turbines. To exercise'hese valves closed quarterly would require stopping steam flow from one steam generator. This would result in large power fluctuations and flux tilting problems in the reactor core and could cause a plant trip. Therefore, it is impractical to exercise these valves closed during power operations, The Hinutes of the Public Heetings on Generic Letter 89-04 state that the use of disassembly to verify closure capability may be found to be acceptable depending on whether verification by flow or pressure measurements is practical. These valves are located in the 38 inch diameter main steam lines and are close-coupled to the main steam isolation valves (HSIVs). A study of the system PAID indicated that there are no installed instruments or isolation valves that would facilitate reverse flow closure verification of these valves. Therefore, it is not practical to verify valve closure by leak testing or observation of system parameters during any plant mode. System modifications such as replacing these valves with ones having position indication would be necessary to allow a direct indication of valve closure. Performing such modifications would be burdensome to the licensee because of the costs involved.

The licensee's proposed disassembly and inspecti.on program should provide an indication of valve condition and reasonable assurance of its operational readiness. However, the NRC staff considers valve disassembly and inspection to be a maintenance procedure that is not equivalent to exercising produced by'fluid flow. This procedure has risks which may make its routine use as a substitute for testing undesirable when some method of testing is possible. Check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and service. The licensee 22

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should actively pursue the use of non-intrusive diagnostic techniques such as acoustics, magnetics, or radiography to demonstrate that these valves close when subjected to reverse flow conditions.

The Minutes of the Public Meeting on Generic Letter 89-04 also state that partial-stroke exercise testing with flow is expected to be performed after valve disassembly and inspection is completed but before returning the valve to service. This post inspection testing provides a degree of confidence that the disassembled valve has been reassembled properly and that the disk moves freely.

Based on the determination that compliance with the Code is impractical and burdensome and considering the adequacy of the proposed testing, relief may be granted provided that when disassembly and inspection is utilized in lieu of testing, the reassembled valve is part-stroke exercised prior to entering a plant condition where it might be required to perform its safety function in the closed position. If another method is developed to verify the reverse flow c'losure capability of these valves, this relief request should be revised or withdrawn as appropriate.

If the licensee's investigation indicates that both standard and non-intrusive techniques are impractical for demonstrating the reverse flow closure of these valves, the technical bases for this determination should 'e documented.

3.7 Miscellaneous S stems 3.7.1 H dro en Sam lin S stem 3.1.1.1 ~R1i f R t. TR-34 4 t 11 1 f tfyt 3 individual closure for hydrogen analyzer nitrogen supply check valves, V-29305 and -29306, per Section XI, Paragraph IWV-3522(a). The licensee proposes to test them simultaneously in the closed direction to verify at least one valve of the pair closes.

3.1.1.1.1 Li ' 1 F R ~iR 11 1 are in series for redundancy and act as one barrier for reverse flow with TR no mechanism to allow verification that both valves seat. Since they are in series, however, in order to perform the safety function only one valve need close.

Alternate Testin  : These valves will be tested simultaneously in the closed direction to verify that at least one valve closes.

3.7.1.1.2 Evaluation--These simple check valves are installed in series without intermediate test taps. No provisions are made to verify that both valves seat when flow is reversed. It is impractical to test them according to the Code due to this system's design. The licensee proposes to test them as a pair and verify at least one closes on cessation or reversal of flow. This does not indicate the condition of each valve.

However, it provides positive indication that at least one valve in. the pair is closed. System design changes and modifications would be required to perform Code testing. This would be costly and burdensome to the licensee. The proposed testing provides a reasonable assurance of operational readiness of the check valve pair.

23

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However, no mention has been made of how corrective action will be applied to these valves. Excessive back flow through the pair can occur only when both valves are degraded and fail to seat. Test failure indicates degradation of both valves. Therefore, both valves must be declared inoperable and be repaired or replaced before being returned to service.

Based on the determination that compliance with the Code requirements's impractical and burdensome, and considering the proposal, relief should be granted provided that if excessive back flow through the pair is observed, both valves are declared inoperable and repaired or replaced before being return to service. The licensee might consider the use of non-intrusive techniques to individually verify the closure of these valves.

3.7.2 Sam lin Containment Isolation S ste 3.1.2.1 ~R1i f R . RR-32 3 t 11 ff tt t t frequency requirements of Section XI, Paragraph IWV-3521, sampling system containment isolation check valves, V-27101 and -27102. The licensee proposes to verify closure, at least once every two years in conjunction with Appendix J leak testing.

3.7.2. 1. 1 Licensee's Basis for Re uestin Relief--These are simple check valves with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. This would require a considerable effort, including entry into the containment building, which is impractical during plant operation and would be an unreasonable burden on the plant staff to 'perform at cold shutdown.

Alternate Testin : At least once every two years, these valves will be verified to close in conjunction with the Appendix J leak testing program.

3.7.2. 1.2 Evaluation--These are simple check valves without external position indication. Valve closure cannot be verified by observing installed instrumentation. A practical means for verifying closure is to establish a reverse differential pressure across the valves and perform a leak rate or back flow test. It is impractical to test these valves during power operations as they and the necessary test connections are located inside containment. Containment entry is restricted during power operations due to personnel safety and radiation exposure concerns.

Verifying valve reverse flow closure by Appendix J leak testing or by using non-intrusive techniques involves non-routine procedures. These test methods require an extensive test setup and many man-hours. Leak testing or non-intrusive verification of valve closure during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify reverse flow closure with Appendix J type testing at least once every 2 years gives adequate assurance of valve closure and is a reasonable alternative to the Code.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the proposal, relief should be granted as requested.

24

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3.7.3 Intake Coolin W r S ste 3.1.3.1 ~Rli I . VR-35 q t 11 f f I 3 tl stroke times of power-operated valves in the intake cooling water system, TCV-14-4A and -4B, per Section XI, Paragraph IWV-3413(b). The licensee proposes to monitor them locally to verify proper valve oper ation. 'troke times will not be measured.

3.7.3.1. I Licensee's Basis for Re uestin Relief--These valves are provided with a controller that positions the valve in response to a variable indicator-controller device. In order to stroke these valves and perform fail-safe tests, fuses in the control circuits are removed which in turn, causes the loss of valve position indication. Thus measurements of valve closure times are not practical.

Alternate Testin : Ouring quarterly valve exercising and fail-safe testing an individual will be stationed at the valve to verify proper operation.

Valve stroke times will not be measured.

3.7.3.1.2 Evaluation-- It is difficult to accurately measure the stroke time of these valves. They do not have manual control switches, but instead receive position commands from a variable control signal. This signal is manually controlled by a station operator. The operator's speed at varying the signal would be reflected in the valve stroke time. This makes the repeatability of the test and evaluation of data difficult. An alternate method, deenergizing the valve by pulling fuses, has not yielded accurate stroke times. Oesign changes and modifications might be needed to stroke time these valves. This would be costly and burdensome to the licensee.

However, some method of accurately stroke timing or otherwise adequately evaluating these valves'ondition is necessary for assessing their operational readiness. The licensee should actively pursue an alternate test method. Hethods employing magnetics, acoustics, ultrasonics, or other technologies should be investigated for their suitability. The proposal to verify the valves are opening and closing quarterly during surveillance testing should be acceptable on an interim basis, but it does not adequately evaluate valve condition and does not present a reasonable long-term alternative.

Based on the determination that complying with the Code requirements is impractical and burdensome and considering the licensee's proposal, relief should be granted for an interim period of one year or until the next refueling outage, whichever is longer. Ouring this period, the licensee should develop a method of accurately measuring stroke time or some other means to adequately monitor valve condition.

3.7.4 Hake-u Water S stem 3.1.3.1 ~R1i f R <<. VR-15 q t 11 f f tq t t

.frequency requirements of Section XI, Paragraph IWV-3521, for primary makeup water supply check valve, V-15328. The licensee proposes to verify closure at least once every two years in conjunction with Appendix J testing.

25

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3.7.4. 1. 1 Licensee's Basis for Re u stin Relief--This is a simple check valve with no external means of position indication; thus the only practical means of verifying closure is by performing a leak test or back flow test. This would require a considerable effort, including entry into the containment building, which is impractical during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown.

Alternate Testin :,. At least once every two years, %his valve will be verified to close in conjunction with Appendix J leak testing program.

3.7.4. 1.2 Evaluation--This is a simple check valve with no external means of position indication. Valve closure cannot be verified by observing installed instrumentation. A practical means for verifying closure is to establish a reverse differential pressure across the valve and to perform a leak rate or reverse flow test. It is impracti,cal to test this valve during power operations as it and the necessary test connections are located inside containment. Containment entry is restricted during power operations due to personnel safety and radiation exposure concerns.

Verifying valve reverse flow closure by Appendix J leak testing or by using non-intrusive techniques involves non-routine procedures. These test methods require an extensive test setup and many man-hours. Leak testing or non-intrusive verification of valve closure during cold shutdown could delay plant start-up which would be costly and burdensome to the licensee.

The licensee's proposal to verify reverse flow closure with Appendix J type testing at least once every 2 years gives adequate assurance of valve closure and is a reasonable alternative to the Code.

Based on the determination that compliance with the Code test frequency requirements is impractical and burdensome, and considering the proposal, relief should be granted as requested.

3.7.5 Instrument Air S stem 3.7.5. 1 Relief Re uest. VR-16 requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for .instrument air supply to containment check valve, V-18195. The licensee proposes to verify closure once every 2 years in conjunction with Appendix J testing.

3.7.5.1.1 Licensee's Basis for Re uestin Relief--This is a simple check valve with no external means of position indication, thus the only practical means of verifying closure is by performing a leak test or back flow test. This would require a considerable effort, including entry into the containment building and securing all instrument air to the containment. Oue to access limitations and the undesirability of isolating the air supply for critical equipment, this is impractical during plant operation and would be an unreasonable burden on the plant staff to perform at cold shutdown.

A~it i: At t 1 verified to close in conjunction yt y, with the Appendix tM J

1 i11b leak testing program.

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3.7.5. 1.2 Evaluation--This is a simple check valve with no external means of position indication. Valve closure cannot be verified by observing installed instrumentation. A practical means for verifying closure is to establish a reverse differential pressure across the valves and perform a leak rate or back flow test. It is impractical to test this valve during power operations as it and the necessary test connections are located inside containment. Containment entry is restricted during power operations due to personnel safety and radiation exposure concerns.

Verifying valve reverse flow closure by Appendix J leak testing or by using non-intrusive techniques involves non-routine procedures. These test methods require an extensive test setup and many man-hours. Leak testing or non-intrusive verification of valve closure during cold shutdown could delay plant 'start-up which would be costly and burdensome to the licensee.

Further, this valve supplies air to critical equipment in containment that may be needed to support cold shutdown operations. The licensee's proposal to verify reverse flow closure with Appendix 3 type testing at least once every 2 years gives adequate assurance of valve closure and is a reasonable alternative to the Code.

Based on the determination that compliance with the Code requirements is impractical and burdensome, and considering the proposal, relief should be granted. as requested.

3.7.6 Alternate Source of Coolin Water S stem 3.7.6. 1 Relief Re uest. VR-25 requests relief from the test frequency requirements of Section XI, Paragraph IWV-3411, for barrier wall to emergency cooling intake valves, SB-37-1 and -2. The licensee proposes to exercise them every six months.

3.7.6. 1. 1 Licensee's Basis for Re uestin Relief--The operation of these valves is limited for environmental concerns to minimize the quantity of water drawn from the Indian River and discharged to the ocean.

For this reason the UFSAR (Section 9.2.7) specifies exercising these valves at six month intervals.

Alternate Testin  : These valves will be exercised at least once every six months.

3.7.6. 1.2 Evaluation--These 54" valves are in the barrier wall between the emergency cooling water intake canal and Big Mud Creek. Their exercise frequency is specified in the UFSAR, Section 9.2.7, as six months. This is for an environmental concern to minimize the transfer of fresh water from the creek into the ocean. There are no series isolations or other provisions to allow quarterly exercising without transferring water through the bar rier. Compliance with the Code test frequency would violate St. Lucie Unit One UFSAR.. This would create a hardship for the licensee without a compensating increase in the level of safety or quality. The licensee's proposal to exercise these valves once every six months provides a reasonable assurance of operational readiness.

27

Based on the determination that compliance with the Code required testing frequency would create a hardship without a compensating increase in the level of plant safety and considering the proposal, relief should be granted as requested.

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APPENDIX A PAID AND DRAWING LIST

APPENDIX A P&ID DRAWING LIST The P&IOs and Drawings listed below were used during the course of this review.

S stem P&IO or Orawin Revision Reactor Coolant G-078 Sh. 110 Rev.8 Chemical & Volume G-078 Sh. 120 Rev.2 Control Chemical & Volume G-078 Sh.121 Rev.6 Control Safety Injection G-078 Sh.130 Rev.4 Safety Injection G-078 Sh.131 Rev.3 Fuel Pool G-078 Sh. 140 Rev.2 Sampling G-078 Sh.150 Rev.4 Waste Management G-078 Sh. 160 Rev.4 Waste Management G-078 Sh.163 Rev.6 Hain Steam G-079 Sh.1 Rev.24 Feedwater & Condensate G-080 Sh.3 Rev.25 Circulating & Intake Cooling Water G-082 Sh.1 Rev.25 Intake & Cooling Water Lube Water G-082 Sh.2 Rev.2 Component Cooling Firewater, Domestic, and G-083 Rev.21 Make-up Water G-084 Sh. 1 Rev.22 A-3

S stem PKIO or Drawin Revision Service Air G-085 Sh.1 Rev.21 Instrument Air G-085 Sh.2 Rev.15 Hiscellaneous G-086 Sh.1 Rev.17 Containment Spray & G-088 Rev.18 Refueling Water Niscellaneous Sampling G-092 Rev.ll Miscellaneous G-093 Sh.3 Rev.14 HVAC-Air Flow G-0862 Rev.19 A-4

APPENDIX B IST PROGRAM ANOMALIES

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APPENDIX 8 IST PROGRAM ANOMALIES Inconsistencies and omissions in the program noted during the course of this review are summarized below. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines in this report.

In relief request PR-3, section 2. 1.3. 1 of this report, the licensee requests relief from measuring inlet pressure prior to pump start as required by Section XI, Table IWP-3100-1 for all pumps in the IST program. The licensee proposes to measure only the running pump inlet pressure for operating pumps. The idle inlet pressure will be measured only if the pump is not running upon commencing the test.

IWP-3400(b) states pumps that are operated more frequently than every 3 months need not be run or stopped for a special test, provided the plant log shows each such pump was operated at least once every 3 months at the reference conditions, and the quantities specified were measured, observed, recorded, and analyzed. Therefore, operating pumps need not be stopped to measure pump inlet pressure, and this relief request is not necessary.

2. In relief request PR-7, section 2.2. 1. 1 of this report, the licensee requests relief from measuring flow rate according to Section XI, Paragraph IWP-4600, for the diesel fuel oil transfer pumps, DOT 1A and

18. The licensee proposes to calculate flow rate based on the change in tank level over time. Relief is granted provided the calculations are within the accuracy that would result from installed instruments meeting the Code accuracy requirements.

3. In relief request PR-8 and PR-11, section 2.2.2. 1 of this report, the licensee requests relief from measuring inlet suction pressure as required by Section XI, Table IWP-3100-1, for boric acid make-up pumps, BAM 1A and 18, diesel fuel oil transfer pumps, DOT 1A and 18, and intake cooling water pumps, ICW 1A, 18, and 1C. The licensee proposes to calculate the inlet suction pressure based on the height of fluid above the suction. Relief is granted provided the calculations are within the accuracy that would result from installed instruments meeting the Code accuracy requirements.

4. In relief request VR-1, section 3. 1. 1. 1 of this report, the licensee requests relief from the test frequency requirements of Section XI, Paragraphs IWV-3412, -3415, and -3522 for all valves that cannot be exercised at power. The licensee proposes to test these valves during cold shutdowns on a deferred basis, if required. Relief is granted for those valves that can be tested during any cold shutdown.

However, relief is denied for valves that cannot be tested during any cold shutdown of sufficient duration to complete testing.

5. The licensee has requested relief in VR-4 from the test frequency requirements for safety-related pumps or valves that must be removed from service for testing. The licensee proposes to defer testing when the redundant subsystem is out of service for maintenance or repairs, and to perform the testing after the out of service subsystem is 8-3

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returned to service. This issue is addressed and the requirements are as stated in plant Technical Specifications. Therefore, this relief request is not evaluated in this TER.

6. In relief request VR-S, section 3. 1.2. 1 of this report, the licensee requests relief from measuring and assigning individual leak rates for various Category A and A/C valves per Section XI, Paragraphs IWV-3426 and -3427. The licensee proposes to test these valves in groups.

This is acceptable if leakage limits are set such that excessive leakage .through any individual valve, even the smallest, is detected and appropriate corrective action is taken. Relief is denied for any valves that can be individually tested.

7. In relief request VR-9, section 3.2. 1.2 of this report, the licensee requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for check valves V-3405, -3414, and -3427. The licensee proposes to manually exercise and verify closure quarterly and full-stroke exercise them open at refueling outages. Relief is granted provided the licensee uses position indication or some other positive means to ensure the valve has travelled to its seat and is not binding or stuck during the quarterly exercising. Furthermore, the licensee must develop a method to partial-stroke exercise these valves while shutting down to cold shutdown.

8. In relief request VR- 10 the licensee proposes to verify the reverse flow closure of the HPSI header to RCS injection line check valves, V-3113, -3123, -3133, and -3143, in conjunction with PIV leak testing at least once every two years. The system PKIO shows motor-operated isolation valves upstream of each check valve with drain lines tapping off between the isolation and the check valves. Using these provisions, it might be practical to verify the reverse flow closure of these valves at the Code specified frequency. Unless verifying the reverse flow closure of these valves quarterly or during cold shutdowns is impractical or constitutes a hardship without a compensating increase in the level of quality and safety, they should be tested at the Code required frequency. The licensee should respond to this staff concern within 90 days.

9. In relief request VR-33, section 3.2. 1.3 of, this report, the licensee requests relief from measuring stroke times for safety injection valves HCV-3618, -3628, -3638, and -3648 as required by Section XI, Paragraph IWV-3413(b). The licensee proposes to exercise and fail test these valves but not to measure stroke times. The licensee's proposal does not provide any means to monitor for valve degradation.

Interim relief is granted for a period of one year or until the next refueling outage, whichever is longer. The licensee should develop a method of monitoring for degradation of these valves.

10. The licensee indicated that relief request VR-6 is preapproved by GL 89-04 since it was submitted prior to April 3, 1989. A comparison of relief requests CVCS-1 and -2 from the licensee's IST program submitted by letter dated September 4, 1987,.with relief request VR-6 as submitted by letter dated January 3, 1990, showed that there are 8-4

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substantive differences in the relief requests. Therefore, VR-6 is not preapproved and is reviewed in section 3.4. 1.2 of this report. In VR-6 the licensee requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521 for check valves V-2177, -2190, and

-2191. The licensee proposes to full-stroke exercise these valves during refueling outages. Relief is granted provided the licensee develops a method to partial-stroke exercise these valves while shutting down to cold shutdown or documents the reason this testing is impractical.

In relief request VR-27, section 3.5. 1. 1 of this report, the licensee requests relief from measuring stroke times for diesel generator air start valves as required by Section XI, Paragraph IWV-3413(b). The licensee proposes to time these valves using the start time for the generators. Interim relief is granted for a period of one year or until the next refueling outage, whichever is longer. The licensee needs to develop a method of monitoring for valve degradation or demonstrate the adequacy of the proposed testing.

In relief request VR-26, section 3.5. 1.2 of this report, the licensee requests relief from measuring stroke time for power operated valves SE-59-lA and SE-59-1B as required by Section XI, Paragraph IWV-3413(b). The licensee proposes to exercise, fail-safe test, and observe these valves locally when operated but not'o measure stroke times. The licensee's proposal does not provide any means to monitor for valve degradation. Interim relief is granted for the period of one year or until the next refueling outage, whichever is longer.

The licensee needs to develop a method to monitor and identify severely degraded valves for corrective action.

In relief request VR-24, section 3.7. 1. 1 of this report, the licensee requests relief from individually verifying reverse flow closure for check valves V-29305 and -29306 as required by Section XI, Paragraph IWV-3522(a). The licensee proposes to verify reverse flow closure of these valves as a pair; Relief is granted provided that if excessive back flow through the pair is detected, both valves are declared inoperable and repaired or replaced before being returned to service.

In relief request VR-35, section 3.7.3. 1 of this report, the licensee requests relief from measuring stroke times for intake cooling water valves TCV-14-4A and -4B as required by Section XI, Paragraph IWV-3413(b). The licensee proposes to exercise and fail-safe test these valves 'but not to measure stroke times. The licensee's proposal does not provi'de any means to monitor for valve degradation. Interim relief is granted for a period of one year or until the next refueling outage, whichever is longer. During the interim period, the licensee should develop a method of measuring stroke times or some other means to adequately monitor valve condition.

Valve relief requests VR-12,-17,-19,-20,-22,-29,-30, and VR-31 are for check valves which cannot practically be full-stroke exercised open with system flow per GL 89-04, Position 1. The licensee proposes to full-stroke exercise these valves by sample disassembly, inspection, and a manual exercise per Generic Letter 89-04, Attachment 1, Item 2.

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Disassembly and inspection, to'erify the. full-stroke open capability of check valves is an option only where exercising cannot be practically performed by flow or by other positive means. The NRC staff considers valve disassembly and inspection to be a maintenance procedure that is not equivalent to the exercising produced by fluid flow. This procedure has some risk which may make its routine use as a substitute for testing undesirable. Check valve disassembly is a valuable maintenance tool that can provide a great deal of information about a valve's internal condition. It should be performed under the maintenance pWogram at a frequency commensurate with the valve type and service.

The use of non-intrusive techniques in conjunction with partial-stroke exercising is considered an acceptable means of verifying that a valve full-stroke exercises open. The licensee should investigate the use of non-intrusive diagnostic techniques to demonstrate whether or not check valves swing fully open during partial-stroke exercising.

If the licensee's investigation reveals that full-stroke exercising with flow is not feasible, then disassembly and inspection may be used as an alternative. The licensee must perform this procedure in accordance with GL 89-04 and should ascertain proper reassembly by performing a partial-stroke exercise or leak rate test prior to returning a valve to service.

16. In valve relief requests VR-13 and VR-14 the licensee stated that their alternate testing satisfies the requirements of GL 89-04, Position 2 and, as such, is considered to be approved upon submittal.

The Minutes of the Public Meetings on Generic Letter 89-04, state that the use of disassembly and inspection to verify closure capability may be found to be acceptable depending on whether verification by flow or pressure measurements is practical. However, the minutes further state, that for this use, the submission and approval of a relief request before implementation is required. Therefore, the licensee's statement that these relief requests are approved upon submittal is in error and should be corrected. 'These relief requests have been evaluated in this TER (refer to Sections 3.2. 1.4 and 3.6. 1. 1).

17. VR-14 requests relief (Section 3.6. 1. 1) from the exercising requirements of Section XI for the main steam non-return valves and proposed to verify valve closure by disassembly, inspection, and manual exercise on a sampling basis during refueling outages. The licensee did not provide a detailed technical basis that demonstrates why it is impractical to verify closure of these valves by leak testing or by using non-intrusive techniques. However, a review of the system PE IDs revealed that there are no isolation valves, test taps, or instrumentation that would facilitate this testing. Relief should be granted as requested provided when disassembly and inspection is utilized in lieu of testing, the reassembled valve is part-stroke exercised prior to entering a plant condition where it might be required to perform its safety function in the closed position. The licensee should actively pursue the use of non-intrusive techniques to verify the reverse flow closure of these valves. If another method is developed to verify valve closure, this B-6

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relief request should be revised or withdrawn as appropriate. If the licensee's investigation indicates that both standard and non-intrusive techniques are impractical for demonstrating closure of these valves, the technical bases for this determination should be documented.

18. The licensee indicated that Relief Request VR-20 is preapproved per GL 89-04. Testing and other requirements for preapproval are explicitly stated in the generic letter and must be followed to be in compliance. The relief request indicates that the two affected valves will be disassembled and inspected during the same period every other refueling outage. The generic letter states that a different valve of each group is required to be disassembled, inspected, and manually full-stroke exercised at each successive refueling outage. Therefore, the proposed interval is an extension from the GL specified interval.

The information provided in the alternate testing section of VR-20 is not adequate to justify extension of the inspection interval for the affected valves per GL 89-04, Position 2. The details of the analysis performed to justify the extended interval, as required by, the generic letter, are assumed to be available for inspection at the plant site.

19. Relief Requests VR-3 and VR-23 are nearlv identical and both request relief from the requirements of IWV-3417(a) For fast-acting valves.

One of these relief requests is unnecessary and should be deleted from the IST program.

20. VR-34 requests relief from the leakage rate trending requirements of IWV-3427(b) for containment isolation valves {CIVs). This request is in accordance with GL 89-04, Position 10, and is approved by the GL.

This request is not evaluated in Section 3 of this TER. However, some CIVs also perform a pressure isolation function and are identified to be tested as pressure isolation valves (PIVs) per the St. Lucie Unit 1 Technical Specifications (TS). The response to question 51 in the Minutes of the Public Meeting on GL 89-04, indicates that PIV leakage testing should be trended per IWV-3427(b). Therefore, VR-34 does not apply to the PIV leakage rate testing of dual function CIV/PIVs.

21. Section 3.2 of the licensee's IST program states that in some cases the performance of a pump may be adequate to fulfill its safety function even though there may be a value of an operating parameter that falls outside the allowable ranges as set forth in Table IWP-3100-2. It further states that should such a situation arise, an expanded allowable may be determined, on a case-by-case basis, in accordance with IWP-3210 and ASME Code Interpretation XI-1-79-19.

It is unclear how the licensee is employing this philosophy in the implementation of their IST program. Relaxing the ranges of pump acceptance criteria per IWP-3210 should be done only in those cases where data scatter from a pump known to te in good operating condition does not fall within the limits and cannot reasonably be brought within the limits. IWP-3210 should not be used to allow a potentially degraded pump to remain in service unless a thorough evaluation is performed that demonstrates that the reduced ranges would provide acceptable assurance of pump operational readiness. Pulp degradation

increases the likelihood of failure and significant degradation is unacceptable even if the pump retains a margin of performance above what is required by the system. If the,l.imits of Table IWP-3100-2 are relaxed using the above guidelines, the licensee should have documentation of their evaluation supporting the relaxation available for inspection.

22. VR-11 requests relief (Section 3.2. 1. I) from the test frequency requirements of Section XI for LPSI header to RCS injection line check valves, V-3114, -3124, -3134, and -3144. The licensee proposes to exercise these valves open during cold shutdowns and verify reverse flow closure in conjunction with PIV leak testing at least once every 2 years. The system PKIO shows motor-operated 'isolation valves upstream of each check valve with drain lines tapping off between the isolation and the check valves. Using these provisions, it might be practical to verify the reverse flow closure of these valves at the Code specified frequency. The licensee has not demonstrated the impracticality of performing this testing either quarterly or during cold shutdowns. nor have they shown that doing so. would be a hardship without a compensating increase in the level of quality and safety.

Unless an adequate technical justification is provided and approved, relief should not be granted to defer verifying their reverse flow closure until once every two years.

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