ML17334A513

Ser,Pump & Valve Inservice Testing Program,Dc Cook Nuclear Plant,Units 1 & 2

ML17334A513
Person / Time
Site:	Cook
Issue date:	10/31/1983
From:	Cook T, Rockhold H EG&G, INC.
To:	NRC
Shared Package
ML17320A962	List: ML17320A961 ML17334A513
References
CON-FIN-A-6265 EGG-EA-6413, NUDOCS 8403070395
Download: ML17334A513 (29)

Text

ATTACHMENT EGG-EA-6413 SAFETY EVALUATION REPORT PUMP ANO VAl VE INSERVICE TESTING PROGRAM 00NALO C.

COOK NUCLEAR PLANT, UNITS 1

ANO 2 T. L. Cook H.

C.

Rockhold

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4I - I Published October 1983 EGKG Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Under OOE Contract No.

OE-AC07-761001570 FIN No. A6265 XA Copy Has Been Sent to PDR

$0$07o $Qg-pk 2 ~pp

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ABSTRACT h~

This EG&G Idaho, Inc., report presents the results of our evaluation of the Donald C.

Cook Nuclear Plant, Units 1 and 2, Inservice Testing Program for pumps and valves whose function is important to safety.

FOREWORD This report is supplied as part of the "Review of Pump and Valve Inservice Testing Programs for Operating Plants" P~ogram being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering, by EG&G Idaho, Inc.,

NRC Licensing Support Section.

The U.S. Nuclear Regulatory Commission funded the work under the authorization B&R 20-19-01-09, FIN No. 6265.

Docket No. 50-315/316

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

OREWORD o

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ii 1.

INTROOUCTION 2.

PUMP TESTING PROGRAM.......................,...........,.........

3 2.1 All Pumps in the IST Program.....

3.

VALVE TESTING PROGRAM................

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3.1 General Comments.....

5 3.1.1 Number of Valves Affected........... ~....,......,..

5 3.2 All Systems 3.2. 1 Various Valves 3.2.2 Unspecified Valves 3.2.3 Radiation Areas.....

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10 4.

AODITIONAL SYSTEMS...

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4. 1 All Systems...

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12 4.1.1 Review of Valve Categor ies..

4. 1. 2 Possible IST Program Addition 5.

PROBLEM AREAS

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s 12 14 18 APPENOIX A

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19 1.

COOE REQUIREMENTS-"VALVES 21 2.

COOE REQUIREMENTS PUMPS

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SAFETY EVALUATION REPORT

.. PUMP AND VALVE INSERVICE-TESTING PROGRAM DONALD C.

COOK NUCLEAR PLANT UNITS 1 AND 2 1

8 p 1.

INTRODUCTION Contained herein is a safety evaluation of the, pump and valve inservice testing (IST) program submitted by the Indiana and Michigan Electric Company for its Donald C.

Cook Nuclear Plant, Units 1 and 2.

The working session with Indiana and Michigan Electric Company and D.

C. Cook, Units 1 and 2, representatives was conducted on July 29, 30, and 31, 1980.

The licensee's resubmittal dated December 17,

1982, was received by EGEG Idaho, Inc.,

on January 24,

1983, and was very briefly reviewed to verify compliance of proposed tests of Class 1, 2, and 3 pumps and valves whose function is important. to safety with the requirements of the ASME Boiler and Pressure Vessel

Code,Section XI, 1974 Edition;-through the summer of 1975 Addenda.

In their resubmittal Indiana and Michigan Electric Company has requested relief from the ASME Code testing requirements for specific pumps and these requests have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed impractical.

However, the licensee has not requested specific relief from the ASME Code testing requirements for any active valves in the IST program and has supplied no acceptable specific technical information for evaluation.

The evaluations in this SER of the 0.

C.

Cook Nucl'ear Plant, Units 1

and 2, pump and valve inservice testing program and associated relief requests are the recommendations of EG8G Idaho, Inc.

The licensee's pump testing program is discussed in Section 2.

A brief review of the licensee's valve testing program is discussed in Section 3.

Valves that should be reviewed to detey mine if they are categorized correctly and valves that"we feel should be included to the IST program are discussed in Section 4,.

General program comments, problem'reas, and a discussion of this review are contained in Section 5.

A summary of pump and valve Section XI testing requirements is provided in Appendix A.

2.

PUMP -'ZESZXNG PROGRAM The 0.

C. Cook, Units 1 and 2, pump testing program was very briefly reviewed for compliance with the ASME,Section XI, Code.

The one request for relief from the Section XI. pump testing requirements is evaluated below.

2.1 All Pum s in the IST Pro ram R.R.R

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R The licensee has requested specific relief from testing all pumps in the IST program monthly in accordance with the requirements of Section XI and proposed to test pumps in accordance with Section XI quarterly.

2.1. 1. 1 Code Re uirement.

Refer to Appendix A.

2. 1. 1.2 Licensee's Basis for Re uestin Relief.

a.

Request that frequency of testing be changed from monthly to quarterly for the following pumps:

Auxiliary Feedwater Pumps Centrifugal Charging Pumps Containment Spray Pumps Residual Heat Removal Pumps Safety Injection Pumps The requirement of the testing of the pumps at'onthly intervals causes unnecessary operation of safeguards equipment which could

'be detrimental to the availability, operability, and useful service life of the equipment.

b.

Request that frequency of testing be changed from monthly to quarterly for the following pumps:

o Boric Acid Transfer Pumps

o Component Cooling Water'umps o

Essential Service Water Pumps

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One or more of each of these pumps are generally in operation.

However to provide a uniform test program, the frequency of testing should be the same for all pumps involved in the program.

2. 1. 1.3 Evaluation.

We do not agree with the licensee's basis

and, therefore, feel that relief should not be granted from the test frequency requirements of Section XI for all pumps in the IST program.

We feel the licensee has not provided sufficient technical information to justify an increase in the pump testing interval from monthly to quarterly.

We agree that later editions of the Code specify quarterly pump testing intervals,

however, the edition utilized by the licensee in preparation of their IST program requires monthly pump tests.

2. 1. 1.4 Conclusion.

We conclude that the licensee should test all pumps in the IST program in accordance with the requirements of Section XI until sufficient information is provided to the NRC staff that demonstrates no reduction in pump reliability because of an increased testing interval.

3.

VALVE TESTING PROGRAM The 0: C. Cook, Units 1 and 2, valve testing program was very briefly reviewed for compliance with the ASME,Section XI, Code.

What appear to be requests for relief from the Section XI valve testing requirements have been evaluated below.

3. 1 General Comments

3. 1. 1 Number of Valves Affected There are a total of 319 valves addressed in the justifications for exemptions taken from Figure 4 of the licensee's IST program.

We have proceeded under the assumption that each justification for exemption constitutes one relief request and have simply totaled the number of valves to which each applies.

On this basis, we have recommended that relief from testing not be granted for 274 valves.

The remaining 45 valves have been identified in the IST program as passive valves and we have recommended relief be granted from exercising.

3.

3'.1 Various Valves

.1 exercising 10 valves in various systems in accordance with the requirements of Section XI.

3.2. 1. 1. 1 Code Re uirement Refer to Appendix A.

3.2. 1. 1.2 Licensee's Basis for Re uestin ReliefThe exercising of valves whose failure in a nonconservative position during the cycling test would cause a loss of system function.

3.2. 1. 1.3 Evaluation.

We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the

exercising requirements of Section XI for the 10 valves in the IST program to which this relief request applies.

The licensee has supplied insufficient.specific:.technical information,to allow evaluation of this request.

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3.2.1.1.4 Conclusion Me conclude that the licensee should test these 10 valves in compliance with Section XI requirements or supply the NRC staff with sufficient technical information to allow, proper evaluation of this relief request.

.2.1.2

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exercising 146 valves in various systems in accordance with the requirements of Section XI.

3.2. 1.2. 1 Code Re uirement Refer to Appendix A.

3.2.1.2.2 Licensee' Basis for Re uestin ReliefValves which cannot be exercised (verification of full stroke) due to their design and their physical location, arrangement, alignment, and orientation in the system.

3'. 1.2.3 Evaluation We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the exercising requirements of Section XI for the 146 valves in the IST program to which this relief request applies.

The licensee has supplied insufficient specific technical information to allow evaluation of this request.

3.2. 1.2.4 Conclusion We conclude that the licensee should test these 146 valves in compliance with Section XI requirements or supply the NRC staff with sufficient technical information to allow proper evaluation of this relief request.

T exercising 118 valves in various systems in accordance with the requirements of Section XI.

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3.2.1.3.2 Licensee's Basis for Re uestin ReliefValves in systems which cannot be tested (exercised) within the required test period.

Testing these valves during plant operation could put the plant in an unsafe condition.

'3 3.2. 1.3.3 Evaluation We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the exercising requirements of Section XI for the 118 valves to which this relief request applies.

The licensee has supplied insufficient specific technical information to allow evaluation of this request.

3.2. 1.3.4 Conclusion We conclude that the licensee should test these 118 valves in compliance with Section XI requirements or supply the NRC staff with sufficient technical information to allow proper evaluation of this relief request.

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3 exercising 45 valves in various systems in accordance with the requirements of Section XI.

3.2.1.4.1 Code Re uirement Refer to Appendix A.

3.2.1.4.2 Licensee's Basis for Re uestin ReliefPassive valves not required to change position to accomplish a safety related function.

Record the position of these valves before operations are performed and after operations are completed.

3.2. 1.4.3 Evaluation We agree with the licensee's basis

and, therefore, feel that relief should be granted from the exercising requirements of Section XI for the 4S valves in the IST program identified as passive.

These valves are in their safety position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform.

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3.2.1.4.4 Conclusion We'.'conclude 'that'..the quart'erly stroke and

.,:.. stroke.time measurements are meaningless for passive valves.-

Based on the considerations'discussed above we conclude that the alternate testing proposed will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

3.2.2 Uns ecified Valves 2.2.2.1

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f f exercising unspecified containment isolation valves in accordance with the requirements of Section XI.

3.2.2. 1. 1 Code Re uirement Refer to Appendix A.

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. Licensee's Basis for Re uestin ReliefThe exercising of valves whose failure to close during a cycle test would result in a loss of containment integrity.

3.2.2. 1.3 Evaluation We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the exercising requirements of Section XI for any valves to which this relief request may be applied, now or in future amendments to the IST program.

The licensee has not applied this relief request to any valves in the present IST program, therefore, we question its inclusion in the program and its ultimate application.

In either case, the licensee has supplied insufficient specific technical information to allow evaluation of this request.

3.2.2. 1.4 Conclusion We conclude that the licensee should delete this relief request from the IST program or identify the valves to which it applies and provide the NRC staff with sufficient technical information to allow proper evaluation of the request.

3.2.2.2 Relief Request.

The licensee has requested relief from exerci sing.,unspeci fied~ pressure boundadr y'isolation:. valves in.accordance "

with the requirements of Section XI.

3.2.2.2. 1 Code Re uirement Refer to Appendix A.

3.2.2.2.2 Licensee's'asis for Re uestin ReliefThe exercising of valves which could subject a system to pressures in excess of its design pressures.

3.2.2.2.3 Evaluation We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the exercising requirements of Section XI for any valves to which this rel.ief request may be applied, now or in future amendments to the IST program.

The licensee has not applied this relief request to any valves in the present IST program, therefore, we question its inclusion in the program and its ultimate application.

In either case, the licensee has supplied insufficient specific technical information to allow evaluation of this request.

3.2.2.2.4 Conclusion We conclude that the licensee should delete this relief request from the IST program or identify the valves to which it applies and provide the NRC staff with sufficient technical information to allow proper evaluation of the request.

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1 testing unspecified valves in accordance with the requirements of Section XI.

3.2.2.3.

1 Code Re ui rement Refer to IWV-3420(a-g).

3.2.2.3.2 Licensee's Basis for Re uestin ReliefValves which cannot be seat leak tested due to their design, physical location, arrangement, alignment, and orientation in the system.

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0 3.2.2.3.3 Evaluation Me do not.agree with the licensee's basis and, therefore,~feel that" relief~should"not"be granted'fr'om the'>>1eako"-"'""'"""

testing requirements of Section XI for any valves to which this relief request may be applied, now or in future amendments to the IST program.

The licensee has not'applied this relief request to any valves in the present IST program, therefore, we question its inclusion in the program and its ultimate application.

In either case, the licensee has supplied insufficient specific technical information to allow evaluation of'his request.

3.2.2.3.4 Conclusion We conclude that the licensee should delete this relief request from the IST program or identify the valves to which it applies and provide the NRC staff with sufficient technical information to allow proper evaluation of the request.

3.2.3 Radiation Areas

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testing unspecified valves in high radiation areas in accordance with the requirements of Section XI.

3.2.3. l. 1 Code Re uirement Refer to Appendix A.

3.2.3. 1.2 Licensee's Basis for Re uestin ReliefValves whose access may be restricted due to a high radiation area coupled with its physical location and arrangement in the system.

1 No tests shall be conducted on valves where the radiation level is 1000 mr/hr or greater.

3.2.3. 1.3 Evaluation We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from testing requirements of Section XI for any valves to which this relief request may be applied, now or in future amendments to the IST program.

The licensee has not applied this relief request to any valves in the present IST

program, therefore, we question its inclusion in the program and its 10

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ultimate application.

ln either case, the licensee has supplied insufficient specific technical information to allow evaluation of this re uest, q

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~ I We feel the following valves should be reviewed to determine if they are categorized correctly or if they should be included in the IST program

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and categorized appropriately.

4.1 2~11 2 <<

4.1.1 Review of Valve Cate pries 4.1.1.1 Main Steam Unit 1

MRV-221:

MRV"231:

These valves have no category assigned to them.

MRV"241:

4.1.1.2 Essential Service Water Unit 2 WRV-722:

WRV-724:

Should these valves be Category B instead of WRV-726:

Category E?

WRY"728:

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PA-342 PA-343:

Should these valves be Category A/C instead of Category C?

4.1.1.4 WOS Vents and Orains Units 1 and 2

OCR-206:

This valve has no category

assigned, to it.

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4.1.1,5 Emer enc Core Cool in SIS

'Units 1'nd 2"

SI"142-Ll:

SI-142-L2:

Should these valves be Category A/C instead of SI-142-L3:

Category C?

SI"142-L4:

4.1.1.6 Emer enc Core Coolin Units 1 and 2

ICM-111:

Should these valves be Category A instead of IMO-128:

Category B?

IMO-330:

IMO-331:

IMO-315:

IMO-325:

SI-152-S:

Should these valves be Category A/C instead of S I-152-N:

Category C?

SI-151-E:

SI"151-W:

SI-166-1:

SI-166"2:

SI"166"3:

SI-166"4:

S I-158"L1:

S I-158-L2:

S I-158-L3:

SI"158-L4:

SI-161"Ll:

S I-161-L2:

SI-161-L3:

S I "161-L4:

S I-170"L):

S I-170-L2:

SI"170-L3:

SI-170-L4:

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WA 4.1.2.1 Main Steam, 4.1.2 Possible IST Pro ram Additions',c e

Units 1 and 2

MMO"210 MMO-220 MMO-230 MMO-240

4. 1.2. 2 Feedwater Units 1 and 2

FW"131-1 FW"131 "2 FW"131 "3 FW-131-4 FW"137-1 FW-137-2 FW"137-3 FW"137"4 FW-125 FW"126 FW"127 FW-136 FW-129 FW-130 FW"158

4. 1.2.3 Essential Service Water Units 1 and 2

ESW-243 ESW-109 ESW"130 ESW-131 ESW" 132 ESW-115 14

ESW" 145 ESW"243 ESW-240 ESW-159 ESW" 160 ESW-161

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4. 1.2. 4 CVCS Reactor Char in and Letdown Units 1 and 2

CS"338 CS"300E CS"300W CS-307 CS-319 CS "301E CS-301W CS-296E CS"296W CS-304 CS"305

4. 1.2.5 Com onent Coolin Units 1 and 2

Page 2 of 2 missing'rom program.

CCW-180E CCW-180W CCW-183E CCW-183W 4.1.2.6 Emer enc Core Coolin SIS Units 1 and 2

SI-103-S SI-111-S SI-106"S 15

'SI-103-N '"'

SI"111-N SI"'106-N SI-205 S I"206 4.1.2.7 Emer enc Core Coolin Units 1 and 2

RH-104-E RH-104"W RH-113-E RH-113-W RH-116" E RH"116-W

4. 1.2.8 Containment S ra Units 1 and 2

CTS" 139" E CTS" 139 "W CTS"116 CTS-106 CTS-119-E CTS-119 "W CTS-105-E CTS-105-W CTS" 121" E CTS-121 "W CTS-122-E CTS-122-W SI-181 SI-182 16

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PROBLEM -ARQS -.....-'. -...,.

This was a very brief review intended to identify general problem areas in the licensee's IST program.

Those areas are summarized below.

The PKIDs used for this review were used during the initial review (March 1980) and most are out of date.

New PKIDs are needed if a proper program review is to be performed.

1 There are no specific relief requests in the valve testing program.

The licensee has used very general "exemption" explanations and has applied these to large numbers of valves in lieu of a'ormal technical relief request(s).

However, an attempt has been made to explain why a particular valve cannot be exercised in accordance with Section XI in each section of the program (yellow pages).

The plant operational mode number have not been explained.

For example; a check valve that is going to be full-stroke exercised during cold shutdowns while in operational modes 1 through 5 is rather confusing because we believe mode 1 is power operation..

It is not clear if pressure boundary isolation valves have been addressed in the program.

Four check valves in the residual heat removal system have been categorized A/C and the 1

gpm leakage limit assigned,

however, safety injection header check valves and SI accumulator discharge checks are categorized C.

Much of the technical information presented at the working meeting was not included in the revised program.

That may have been the result of a

2-1/2 year delay between the working meeting and the resubmittal date.

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APPEHOIX A, 19

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APPENDIX A 1.

CODE REQUIREMENTS-VALVES Subsection IWV-3410(a) of the 1974 Edition and the Section XI ASME Code (which discusses full-stroke and partial-stroke requirements) requires that Code Category A and 8 valves be exercised once every three months, with ~exce tione as defined in IWV-3410(b)(1), (e),

and (f).

IWV-3520(a)

(which discusses full-stroke and partial-str'oke requirements) requires that Code Category C valves be exercised once every three months, with

~exce tions as defined in IWV-3520(b).

In the above exceptions, the Code permits the valves to be tested to cold shutdown where:

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It is not practical to exercise the valves to the position required to fulfilltheir function or to the partial position durin ower o eration 2.

It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.

Subsection IWV-3410(c) requires all Category A and 8 power-operated valves to be stroke-time tested to the nearest second or 10K of the maximum allowable owner-specified time.

2.

CODE REQUIREMENTS-"PUMPS An inservice test shall be conducted on all pumps that perform a

function important to safety, nominally once each month during normal plant operation.

Each inservice test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.

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