ML17334B629

Safety Evaluation Approving Relief Requests REL-02,REL-05 & REL-12 & Denying Relief Requests P-1,REL-12 (Test Frequency Portion) & REL-13 for IST Program for Plant Units 1 & 2

ML17334B629
Person / Time
Site:	Cook
Issue date:	05/27/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML17334B628	List: ML17334B627 ML17334B629
References
NUDOCS 9706030239
Download: ML17334B629 (70)

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UN(TED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON> D.C. 2055&4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE THIRD 10-YEAR INSERVICE TESTING PROGRAM RELIEF RE UESTS INDIANA MICHIGAN POWER COMPANY DONALD C.

COOK NUCLEAR PLANT UNITS 1

AND 2 DOCKET NUMBERS 50-315 AND 50-316

1.0 INTRODUCTION

(he Code of Federal Re ulations, 10 CFR 50.55a, requires that inservice testing (IST) of certain American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code (the Code) and applicable

addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(i),

(a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a.

In proposing alternatives or requesting relief, the licensee must demonstrate that:

(1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficultywithout a compensating increase

-in the level of quality and safety;'or (3) conformance is impractical for its facility.

Section 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings.

NRC guidance contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable, Inservice Testing Programs,"

provides alternatives to the Code requirements determined acceptable to the staff.

Further guidance was given in GL 89-04, Supplement 1,

and NUREG-1482, "Guidelines for Inservice Testing at Nuclear Power Plants."

The Donald C.

Cook Nuclear Plant, Units 1 and 2, third 10-year IST interval program was submitted in two letters dated April 24,

1996, and June 12,

1996, for valves and pumps, respectively.

The third 10-year IST interval began on July 1,

1996, and ends on June 30, 2006.

'The IST program was developed in accordance with the 1989 Edition of the Code which incorporates Operations and Haintenance (OH) Standards Part 1, Part 6, and Part 10 (OM-1, OM-6, and OM-10), for IST of safety and relief devices,

pumps, and valves, respectively.

The NRC's findings with respect to authorizing alternatives and granting or denying the IST program relief requests are given below.

In addition, the staff has reviewed the deferred testing justifications for valves, the scope for selected

systems, and technical positions stated in the IST program.

As a

result, several anomalies were identified which are given in Section 6.

The licensee should address these anomalies within 1 year of the date of this safety evaluation or by the next refueling outage, whichever is longer, unless otherwise noted.

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2.0 IST PROGRAM.ISSUES The IST program includes "comments" for pumps and valves.

These "comments" state certain technical positions.

The staff reviewed these "comments" with results as follows:

PUHP COHHENTS:

The review of pump comments indicated one possible compliance issue.

The program states that the emergency diesel generator fuel oil transfer pumps do not fall within the scope requirements of the ASME OM Code in accordance with NUREG-1482 (Section 3.4),

GL 89-04, and 10 CFR 50, Appendix A and Appendix B.

These pumps are included in the program, with comments regarding the portions of the Code that are not met.

Section 3.4 of NUREG-1482 does not discuss the scope of the program; rather, it discusses testing of skid-mounted or component subassemblies.

Section 2.2 of NUREG-1482 addresses the scope of the IST program.

The licensee should review Section 2.2 and Section 3.4 of-NUREG-1482 and the Donald C.

Cook Safety Analysis Report (SAR) to determine if the IST program accurately reflects the SAR as related to these pumps.

The comments in the IST program should be corrected.

VALVE COHHENTS:

The valve comments were reviewed for consistency with Code requirements and regulatory guidance.

System piping and instrument diagrams, and applicable'ections of the SAR and Technical Specifications were referenced as necessary.

The following discrepancies were noted as a result of this review:

Valve Comment COM-02 Valves CMO-411, -412, -413, -414, -415, and -416 should be checked to verify that they are not required to move from the closed to open position at any time during accident mitigation (e.g., if the valves are closed while the system is still in an "operable" status - and receive a signal to open).

If so, then testing requirements shou1d be expanded to include stroke timing in the closing direction.

Valve Comments COM-04 COM-05 and COM-07 These notes state that, if an opposite train is unavailable, testing will be deferred until the opposite train is returned to service.

Such a deferral is generally governed by the plant technical specifications;

however, the licensee should use the 25X extension allowed by technical specifications for the valve exercise scheduling when such plant conditions occur.

Valve Comment COM-06 Valves VRV-315 and VRV-325 are part-stroke exercised quarterly with no full-stroke exercise during cold shutdowns or refueling outages.

Neither are the valves stroke timed as required by the Code because the valves have no position indicators arid operate on temperature controls.

The valves should be tested per the Code or a relief request should be submitted.

A periodic

I

preventative maintenance program may be an acceptable alternative to stroke time testing when testing is not practical.

3.0 PUMP RELIEF REQUESTS 3'.I Relief Re uest P-I The licensee has requested relief from the vibration limits specified in Table 3a, "Ranges for Test Parameters,"

of ON-6 for containment spray (CTS) pump PP-009.

The licensee proposes to change the values as follows:

the acceptable range from <2.5 V to <2.0 V I

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the alert range limit from 2.5 V - 6 V to 2.0 V - 4 V and from 0.325 inches/second (in/sec) to 1.2 in/sec

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the required action limit from >6 V to >4 V and from >0.70 in/sec to >2.0 in/sec.

3. I. 1 Licensee's Basis for Re uestin Relief The licensee states:

The design of the CTS pumps utilizes a four-vane impeller in a'ouble volute casing.

This combination of an impeller with an even number of vanes oper ating in a casing with two volutes creates a high, reinforced vibration response at the vane passing frequency (7,200 gallons per minute [gpm]).

This condition is further compounded by the fact that the quarterly IST tests are performed at only 25X of the pump's design flow.

This results in the discharge angle of the impeller flow not matching the stationary volute angle, producing high interaction forces between the impeller and the volutes.

This high vane pass frequency amplitude is the major component of overall amplitude and is not indicative of overall pump condition.

On thi s basis, compliance

• with the referenced acceptance criteria would be impractical due to the burden created by unnecessary repair and replacement of otherwise suitable pump components.

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3. 1.2 Alternate Testin The licensee proposes:

The acceptable range for the CTS pumps will be set at <2.0 V, the alert range will be set at 2.0 V to 4 V or 1.2 in/sec, and the action range will be set at >4 V or >2.0 in/sec.

Although the overall vibration amplitude is increased over the alert and required action limits of ASNE OMa-1988, Part 6, Table 3a, the proposed alternate values are based upon our review of past operating data for these pumps.

The values are a more representative basis for trending performance of the CTS pumps

and, as such, provide an acceptable level of quality and safety.

3. 1.3 Evaluation The CTS pump has a safety function to provide cool water flow to spray the containment atmosphere in a loss of coolant accident (LOCA) or steamline break.

The Code requires the measurement of hydraulic and mechanical performance data on this pump to assess the condition of the component.

Mechanical performance data are in the form of vibration measurements.

Table 3a establishes criteria to assess pump degradation for centrifugal pumps.

The criteria are based, in part, on.the reference vibration value (V ) of the pump.

The acceptable range is defined in the Code as <2,5 V.

fhe alert range is defined in 'the Code as 2.5 V to 6 V or between 0.325 in/sec and 0.70 in/sec.

When a

pump enters the alert range, OHa-1988, paragraph

6. 1 requires that frequency specified in paragraph

5. 1 be doubled until the cause of the deviation is determined'nd the condition corrected.

The action range is defined in the Code as

>6 V or >0.70 in/sec.

Paragraph 6.1 requires a

pump with a vibration value measured in the required action range to be declared inoperable until the cause of the deviation has been determined and the condition corrected.

'he licensee proposes that the acceptable range for the CTS pump be set at

<2.0 V (multiplier limit) or at <1.2 in/sec (absolute limit), the alert range be established between 2.0 V

and 4 V (multiplier limit) or at 1.2 in/sec (absolute limit), and the action range will be set at >4 V (multiplier limit) or >2.0 in/sec (absolute limit).

Though the proposed vibration multipliers are more conservative, the absolute limits are not as conservative as the Code.

The relief request did not contain

~s ecific information on (1) the pump vibration history, and (2) the licensee's efforts to improve performance, to justify the less conservative absolute requirements.

The four key components that the staff considers in evaluating these particular alternate requests are listed in NUREG/CP-0152, "Proceedings of the Fourth NRC/ASME Symposium on Valve and Pump Testing," in the paper, "Nuclear Power Plant Safety-Related Pump Issues,"

by Joseph Colaccino.

The licensee should have sufficient vibration history from inservice testing which verifies that the pump has operated at this vibration level for a significant amount of time.

The licensee should have consulted with the pump manufacturer or a vibration expert about the level of vibration the pump is experiencing to determine if

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• the operation of the pump is acceptable.

Third, the licensee should describe attempts to lower the vibration below the defihed Code absolute levels through modification to the pump.

Fourth, the licensee should perform a spectral analysis of the pump-driver system to identify all contributors to the vibration levels.

3.1.4 Conclusion Relief is denied.

The licensee must perform testing of the CTS pump in accordance with the Code requirements.

If the licensee compiles additional information that it believes supports the proposed limits, using the guidance discussed

above, a revised relief request should be submitted prior to implementing the alternative limits.

3.2 Relief Re uest P-2 The licensee has requested relief from the axial direction vibration measurement requirements of ASME OMa-1988, Section 4.6.4(a), for the boric acid transfer pumps 1-PP-45-1,2 and 2-PP-46-3,4.

The licensee has proposed to take measurements in a plane approximately perpendicular to the shaft in two orthogonal directions on each accessible pump bearing

housing, but not take measurements in the axial direction, as required by the Code.

3.2.1 Licensee's Basis for Re uestin Relief The licensee states:

The pump thrust bearing housing is inaccessible.

It is very close to the coupling, and safety considerations prevent placement of the probe.

In addition, the housing is partially blocked by the impeller adjustment nuts.

Measurements taken in planes perpendicular to the shaft in two orthogonal directions have provided adequate data to evaluate pump performance and condition.

3.2.2 ~1<<2 <<1 The licensee proposes:

Take measurements in a plane approximately perpendicular to the shaft in two orthogonal directions on each accessible pump bearing housing.

3.2.3 Evaluation The boric acid transfer pumps have a safety function to transfer boric acid solution from a storage tank to the charging pump suction header.

Section 4.6.4(a) of the Code requires that, for centrifugal pumps, vibration measurements shall be taken (1) in a plane approximately perpendicular to the rotating shaft in two orthogonal directions on each accessible pump bearing

housing, and (2) in the axial direction on each accessible pump thrust bearing housing.

- The licensee proposes that these vibrational measurements be taken in a plane approximately perpendicular to the shaft in only two orthogonal directions on each accessible pump bearing housing.

The licensee proposes to not take the measurement in the axial direction because of the inaccessibility of the thrust bearing housing and because measurements taken in planes perpendicular to the shaft in two orthogonal directions have provided adequate data to evaluate pump performance and condition.

While meeting the Code requirements is impractical, the burden of performing an alternative measurement is not identified.

The licensee does not discuss the thrust load of the pump and whether vibration would be a potential identifier of bearing wear, nor does it describe attempts to take axial measurements at some other location on the housing or with different instrumentation.

As such, long-term relief is not justified.

Additional review will be necessary to completely assess the concerns identified herein, representing an immediate burden; therefore, an interim period to address these concerns and revise the relief request should be allowed.

The proposed alternative testing will provide reasonable assurance of operational readiness during the limited period of time it will be used.

3.2.4 Conclusion Interim relief is granted from the Code axial vibration measurement requirements for boric acid transfer pumps I-PP-45-1,2 and 2-PP-46-3,4 pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of performing testing in accordance with the Code requirements, and in consideration of the burden on the licensee if the Code requirements were immediately imposed on the facility.

The relief.is granted for an interim period of 90 days from the date of the safety evaluation to allow the licensee time to further review the concerns discussed above.

3.3

. Relief Re uest P-3 The licensee requests relief from the acceptance criteria requirements of OM-6, paragraph 6.1, for all 'pumps in the licensee's IST program.

The licensee proposes to use the action range requirements of ASME OM Code ISTB-1995, paragraph 6.2.2, "Action Range."

3.3. 1 Licensee's Basis for Re uestin Relief The licensee states:

Compliance with the required acceptance criteria will impose a

significant burden if test data cannot be analyzed to determine if a pump is still capable of performing its safety function.

Past experience evaluating pump test data clearly indicates a burden will be

created by unnecessary extension of Technical Specification limiting condition for operation (LCO) durati ons, unnecessary reportabi 1 ity submittals, unnecessary repairs and replacements of otherwise suitable equipment, arid unnecessary component wear due to accelerated testing frequencies.

It is requested that the corrective action requirements, per ASHE OHa-1988, Part 6, Subsection

6. 1, be superseded for all pumps included in the IST program.

The proposed alternative is to follow Subsection ISTB 6.2.2 of ASHE OH-1995, "Action Range."

When applying the requirements of ISTB 6.2.2, Tables 5.2. 1-1 'and ISTB 5.2. 1-2; the Group A test hydraulic acceptance criteria will be used since all pumps are treated as Group A pumps by ASME OMa-1988.

The current pump IST program trends the test results and replaces the pumps as they approach the IST lower limits. The trending allows for eval.uations of system conditions if the test point deviates from the trend path.

At that time, the pump is retested or the system conditions are reviewed to determine the cause of the deviation.

This type of evaluation is consistent with the current code (i.e., the requirements of Section XI, Subsection IWP, of the ASHE Boiler and Pressure Vessel Code) and is consistent with the 1995 code.,

On this basis, we are requesting that the corrective actions be established per ASHE OM-1995 requirements since the OHa-1988 Code does not" allow evaluation of test conditions.

3.3.2 Alternate Testin The licensee proposes:

OH-1995, Subsection ISTB 6.2.2, "Action Range," (will be implemented for the IST of safety-related pumps).

If the measured test parameter values fall within the required action range of Table. ISTB 5.2. 1-1 or Table ISTB 5.2. 1-2, as applicable, the pump shall be declared inoperable until either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and new reference values are established in accordance with paragraph ISTB 4.6.

3.3.3 Evaluation The corrective action requirements of ASHE Section XI, paragraph, IWP-3230(c),

allowed licensees to perform an analysis to demonstrate that the mechanical or hydraulic performance levels of a pump do not impair pump operability; that is, the pump would still perform its safety function even though test results indicate that degradation is occurring.

Further,Section XI allowed the licensee to establish new reference values after the analysis was performed.

OH-6 was revised to address the concern that repeated establishment of new reference values would allow the pump to operate in a significantly degraded condition from the original pump reference

values, even though it might meet

the design basis flow and pressure requirements of the system.

In addition, there were concerns as to the ability of a licensee to perform an "analysis" of the pump to demonstrate that the pump was'operating acceptably, though degraded.

This issue is further discussed in NUREG-1482, Section 5.6.

OM-6, paragraph

6. I, "Acceptance Criteria," specifies actions required if any of the measured pump parameters fall within the required action ranges.

Entry into a required action range requires that the licensee declare the pump inoperable until the cause of the deviation is determined and the condition corrected.

The 1995 Edition of the ASME OM Code, Subsection ISTB 6.2.2, "Action Range,"

which is not yet endorsed by the NRC; allows that "(if) the measured test parameter values fall within the required action range of ISTB 5.2. 1.1, Table ISTB 5.2. 1-2, Table ISTB 5.2.2-1, or Table ISTB 5.2.3-1, as applicable, the pump shall be declared inoperable until either the cause of the deviation has been determined and the condition is corrected, or an analysis of the pump is performed and new reference values are established in accordance with paragraph ISTB 4.6."

This paragraph allows that, if a licensee can demonstrate by analysis that a pump is still capable of performing its safety function, it may be returned to service by establishing new reference values.

The provision recognizes that there are pumps that may have a significant margin over the safety requirements, that have degraded from their initial performance, but are within the margin of the safety function for flow and differential pressure.

Pumps without extra margin could not be returned to service without repairs or replacement.

The analysis must justify that the degradation mechanism will not cause further degradation such

that, before the next pump test or before repairs can be performed, the pump would no longer be capable of performing its safety function.

The licensee has also stated in their proposed alternative that they would meet the related requirements of ISTB 4.6, "New Reference Values," in establishing the new reference values.

As such, the alternative will provide an acceptable level of quality and safety for monitoring the pumps and assuring that the pumps are capable of performing their safety function for flow and differential pressure.

Returning a pump to service by analysis should be done cautiously, rather than regularly, when evaluating pumps in the required action range.

Repeated application of analysis could lead to "stair stepping" the Code action range

'imit downward to the safety limit of the pump.

The available margin of pumps will be the determining Factor in whether or not continued operation is acceptable.

The analysis, which should include detailed justification and discussion of changes in the pump reference

values, must be documented in accordance with Code requirements.

If the licensee uses the provision for vibration, the absolute limits continue to apply, as these are not dependent on reference values.

Additionally, the licensee is cautioned when using the alternative for vibration, as there are no defined safety margins related to pump vibration.

3.3.4 Conclusion The alternative to use the 1995 edition of the ASNE Code, Section ISTB 6.2.2, for pumps in the required action range is authorized pursuant to 10 CFR 50.55a(a)(3)(i) based on the acceptable level of quality and safety that will be provided by the alternative.

4.0 VALVE RELIEF RE(UESTS J

The 1ST program included several valve relief requests as evaluated below.

Certain of these relief requests were related to deferring testing to a refueling outage.

Where this is allowed by the Code, the evaluation so notes.

4;1 Relief Re uest REL-Ol The licensee has requested relief from the testing requirements of ON-10, paragraphs 4.2. 1.4 (stroke timing) and 4.2. 1.6 (fail-safe testing), for the steam generator power-operated relief valves (PORVs)

NRV-213, NRV-223, NRV-

233, and NRV-243.

The licensee has proposed to exercise the valves quarterly under local observation to assure smooth operation and lack of apparent problems which could affect valve operation.

4. 1. 1 Licensee's Basis for Re uestin Relief The licensee states:

These power-operated relief valves act to prevent. inadvertent lifting of the steam generator safety valves.

These valves are designed to fail closed on loss of control air, but are not provided with means to individually vent air from the valves.

Each valve is provided with hand-auto stations for valve setpoint adjustment.

The PORV controllers modulate their respective valves based on the input error signal generated by comparison of actual steam generator pressure and the operator adjusted setpoint.

Stroke time is not repeatable since it depends on hand-auto station setting, actual pressure conditions and signal processing time.

Due to the design of these valves, relief is requested from the testing requirements of OMa-1988, paragraphs 4.2. 1.4 (stroke timing) and 4.2. 1.6 (fail-safe testing) as this testing is impra'ctical for this valve design.

4. 1.2 Alternate Testin The licensee proposes:

The valves will be exercised quarterly under local observation to assure smooth operation and lack of apparent problems which could affect valve operation.

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4. 1.3 Evaluation The Code requires that the limiting stroke time for power-operated valves'be specified by the licensee, and that valves with fail-safe actuators be tested by observing the operation of the actuator upon loss of valve actuating power.

The steam generator power-operated relief valves in each of the Donald C.

Cook units are not designed to be individually actuated and stroke timed.

As such, stroke timing and fail-safe testing is impractical.

Imposing such testing would impose a burden on the licensee because of the extensive modifications that would be necessary to individually stroke and time the valves.

The licensee has proposed to cycle these valves quarterly without performing a

stroke time or fail-safe test.

The proposed testing provides a reasonable assurance of operational readiness because the valves will be exercised quarterly under local observation;

however, the licensee must establish acceptance criteria for-the test and determine what corrective actions are necessary if the valve fails to meet the acceptance criteria.

The acceptance criteria and corrective action must be included in the appropriate IST procedure.

4. 1.4 Conclusion Relief,to exercise the steam generator power-operated relief valves HRV-213, HRV-223, HRV-233, and HRV-243 is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of performing testing in accordance with the Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility.

The relief is provisional upon the inclusion of acceptance criteria and corrective actions in the appropriate IST procedure.

4.2 Relief Re uest REL-02 The licensee has requested relief from the exercising test frequency and exercise requirements of ASHE OHa-1988, paragraph 4.3.2.1, for the reactor coolant pump (RCP) thermal barrier heat exchanger check valves CCM-224-1, -2,

-3, and -4, and CCM-255-1, -2, -3, and -4.

The licensee has proposed to disassemble, manually full-stroke exercise, and visually inspect the valves on a sampling basis (two of eight) at refueling frequency such that all valves will be examined no less frequently than once every fourth refueling outage.

4.2. 1 Licensee's Basis for Re uestin Relief The licensee states:

1 These check valves are upstream of the RCP thermal barrier heat exchanger (one valve from each group in series for each loop).

The valves cannot be tested during reactor coolant pump operation without securing component cooling water flow to the thermal barrier heat exchanger, which could cause RCP failure.

There is

no method -to establish reverse flow for closure testing and no instrumentation upstream or downstream to measure successful closure.

4.2.2 Alternate Testin The licensee proposes:

The valves will be disassembled, manually. full-stroke exercised, and visually examined on a sampling basis (two of eight), per GL 89-04 Attachment 1 Position 2, at refueling frequency such that all valves will be examined no less frequently'han once every fourth refueling outage.

4.2.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

The NRC staff has indicated that a sample disassembly program is an acceptable alter native when it is impractical to test check valves in a manner that will verify that the valve obturator travels to the full open position or closes on cessation of flow.

ON-10 (paragraph 4.3.2.4(c))

specifies that disassembly and inspection is one means of verifying the necessary check valve obturator

movement, though it specifies disassembly of each valve every refueling outage.

The 1995 Edition of the OH Code allows a sample disassembly

program, and, therefor e, the Code committee has indicated that it generally supports continued use of-the NRC staff's position.

Because testing these valves in accord with the Code requirements is impractical, a sample disassembly and inspection program is an acceptable means of verifying obturator travel; therefore, the licensee may implement such a program, provided all the guidance in Position 2 of Attachment 1 to GL 89-04 is followed.

Modifications to the valves or to the system would be necessary if the Code requirements were imposed on the licensee, creating an undue burden.

Note that the guidance in Position 2 is that each valve be disassembled and inspected at least once every 6 years, except in cases of extreme hardship; therefore, if a fuel cycle is 24 months rather than 18 months, once every fourth refueling outage may not comply with the guidance and the licensee would need to adjust the schedule to ensure compliance.

4.2.4 Conclusion Relief from the testing requirements, with an alternative to disassemble, manually full-stroke exercise, and visually inspect the check valves CCW-224-1, -2, -3, and -4, and CCW-255-1, -2, -3, and -4 on a sampling basis, is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of testing these valves in accordance with the Code, provided the guidance in Position 2 of Attachment 1 of GL 89-04 is followed.

The implementation of a sample disassembly and inspection program that conforms to the guidance of Position 2 of GL 89-04 will provide reasonable assurance of the operational readiness

'of the valves.

The burden on the licensee if the Code requirements were imposed has been considered in granting this relief.

4.3 Relief Re uest REL-03 The-licensee has requested relief from the stroke'ime measurement requirements of ASME OMa-1988, paragraph 4.2. 1.4, and from the testing frequency for fail-safe valves, paragraph 4.2. 1.6, for the component cooling water letdown heat exchanger regulating valve, CRV-470 (both units).

.The*

licensee has proposed to full-stroke exercise the valves quarterly using the auto/manual station and fail-safe test the valves to their closed position at a cold shutdown frequency.

4.3.1

- Licensee's Basis for Re uestin Relief The licensee states:

-The air-operated

valve, CRV-470, is used to regulate component cooling water to the letdown heat exchanger.

The valve is normally in service during power operation.

The valve is controlled by an auto/manual station with auto input from the letdown heat exchanger, outlet temperature sensor.

The valve also trips closed from a safety injection signal via a solenoid valve.'eaningful stroke time data is not available since this valve does not have local or remote position indication.

4,3.2 Alternate Testin The licensee proposes:

The valve will be full-stroke exercised quarterly using the auto/manual station which will permit rapid cycling and result in minimal impact on letdown temperature.

The valve will be fail-safe tested to its closed position at a cold shutdown frequency with letdown flow out of service to avoid high letdown line temperatures that could cause flashing of the letdown heat exchanger and lifting of safety valves.

4.3.3 Evaluation The Code requires that the stroke.time for power-operated valves be measured quarterly, and that valves with fail-safe actuators be tested by observing the operation of the actuator upon loss'f valve actuating power.

These valves are not equipped with any type of position-indication apparatus that could be used to aid in stroke timing the valves.

The licensee proposes to exercise these valves quarterly.

The licensee did not propose any method to monitor the valves for degradation in their relief,request.

Requiring these valves to be stroke timed is impractical and an undue burden on the licensee because the licensee would have to replace the installed valves with valves capable of stroke time measurement or install position indication.

l

13-The proposed testing does not directly monitor the valves for degradation.

However, the valves are exercised at a quarterly frequency and system parameters are monitored which should provide indication that these valves have actuated to their closed safety position.

The licensee should develop acceptance criteria based on the proposed testing for the quarterly stroke test of these valves.

In addition, corrective action should be specified, such as valve replacement, if the valves fail the quarterly testing.

Finally, the licensee should take advantage of any future technologies that are developed to measure the stroke time of these valves.

With the addition of acceptance criteria and corrective action for these valves, the proposed testing provides reasonable assurance of operational'eadiness.

NUREG-1482, Section 3. 1, provides supplemental guidance on the IST of power-operated valves.

In this section, it is stated that exercising valves at each cold shutdown outage is not a deviation from the Code and does not require a

relief request.

Therefore, performing the fail-safe test during cold shutdown is an acceptable frequency because it is impractical to perform the. test quarterly and the Code includes provisions for deferral to cold shutdowns.

4.3.4 Conclusion Relief for stroke timing component cooling water letdown heat exchanger regulating valve, CRY-470, is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of performing testing in accordance with the Code requirements, and in consideration of the burden. on the licensee if the Code requirements were 'imposed on the facility.

The granting of this relief is provisional upon the licensee developing acceptance criteria for the proposed alternate testing and appropriate corrective action if the valves fail the quarterly testing.

Relief for fail-safe testing the valve to its closed position at cold shutdown frequency is not needed, as the Code allows test

deferral, and the proposed frequency is considered a cold-shutdown justification.

4.4 Relief Re uest REL-04 The licensee has requested relief from the testing frequency requirements of ASHE ONa-1988, paragraph 4.2. 1. 1, for Un'its 1 and 2 component cooling water downstream isolation valves CCH-451, -452, -453, -454, -458, and -459.

The licensee has proposed to full-stroke test and time the valves at cold shutdown frequency if the RCPs are stopped.

4.4.1 Licensee's Basis for Re uestin 'elief The licensee states:-

Component cooling water valves CCN-451, -452, -453, -454, -458, and -459 are the downstream isolation valves for the RCP thermal barriers and motor oil coolers.

They cannot be tested during power operation without securing cooling water to the RCPs which could cause failure of the pumps.

14-4.4.2 Alternate Testin The licensee proposes:

The valve will be full-stroke tested and timed at cold shutdown frequency if the RCPs are stopped.

4.4.3 Evaluation The Code requires that the stroke time for power-operated valves be measured quarterly, but allows for valves to be tested on a cold shutdown frequency under paragraph 4.2. 1.2 of OMa-1988.

NUREG-1482, Sections 2.4.5 and 3. 1, discuss guidance on the IST of power-operated valves that cannot be tested during power operation, and may be tested at only those cold shutdowns when the RCPs are stopped.

The licensee's justification is consistent with the guidance provided in Section 3. 1. 1.4 of NUREG-1482, in that the staff recommends that RCPs not be stopped solely to perform valve testing.

Therefore, the staff agrees with the deferral of this test to cold shutdown with the condition that the test be performed during each cold shutdown when the RCPs are stopped, including refueling outages.

4.4.4 Conclusion The justification for full-stroke testing and timing of these valves at cold shutdown frequency if the RCPs are stopped is consistent with the guidance provided in Section 3. 1. 1.4 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown with the condition that the test be

.performed during each cold shutdown when the RCPs are stopped, including refueling outages.

Therefore, the justification is acceptable as a refueling outage justification, rather than a cold shutdown justification, because the valves may not be tested at each cold shutdown (i.e., those when the RCPs are not stopped).

The Code allows testing deferrals to refueling outages; therefore, this justification does not constitute a relief request.

4.5 Relief Re uest REL-05 The licensee has requested relief from the exercising test frequency.and exercise requirements of ASNE OHa-1988, paragraph 4.3.2. 1, for the CTS valves CTS-,103E, CTS-103W, CTS-138E, and CTS-138W.

The licensee has proposed to disassemble, manually full-stroke exercise, and visually inspect the valves on a sampling basis (one of two in each pair) on a frequency of once every other refueling outage.

4.5.1 Licensee's Basis for Re uestin Relief The licensee states:

CTS-103E and CTS-103W are check valves located in the discharge lines of CTS pumps to the spray ring headers in the containment.

CTS-138E and CTS-138W are check valves located in the lines that supply water from the refueling water storage, tank (RWST) to the CTS pumps.

These valves cannot be full-stroked exercised during power operation, cold shutdown, or refueling without spraying the containment.

The valves are part-stroke exercised during CTS pump testing on a

quarterly basis.

The only practical method to verify full-stroke is by disassembly.

The valves are not equipped with position indicators.

4.5.2 Alternate Testin The licensee proposes:

The valves will be disassembled, manually full-stroke exercised, and visually examined on a sampling basis (one of two in each pair), per GL 89-04, Attachment 1, Position 2,

on a frequency of once every other refueling outage.

4.5.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

In Position 2 of Attachment 1 to GL 89-04, the NRC staff has indicated that a

sample disassembly program is an acceptable alternative when't is impractical to test check valves in a manner that will verify that the valve, obturator travels to the full open position or closes on cessation of flow. It is impractical to test these valves in accordance with the Code in that the containment would be sprayed during each test.

It would be an undue burden to impose the testing on the licensee in that modifications would have to be made or a cleanup effort would be necessary -after each test.

OH-10 (paragraph 4.3.2.4(c)) specifies that disassembly and inspection is one means of verifying the necessary check valve obturator movement, though it specifies disassembly of each valve every'refueling outage.

The 1995 Edition of the OM Code allows a sample disassembly program and, therefore, the Code committee has indicated that it generally supports continued use of the NRC staff's

'osition.

Because it is impractical to test these valves, a sample disassembly and inspection program may be used for assuring an adequate level of quality and safety.

However, the sampling program must comply with guidance in Position 2 of Attachment 1 to GL 89-04 in that the valves will be.

grouped in two pairs, as stated, and one of each group must be inspected during each refueling outage.

4.5.4 Conclusion Relief from the testing requirements, with an alternative to disassemble, manually full-stroke exercise, and.visually inspect check valves CTS-103E, CTS-103W, CTS-138E, and CTS-138W on a sampling basis, is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of testing these valves in accordance with the Code, provided the guidance in Position 2 of Attachment 1

of GL 89-04 is followed.

The implementation of a sample disassembly and inspection program that conforms to the guidance of Position 2 of GL 89-04 will provide a reasonable assurance of the operational readiness of the valves.

The burden on the licensee if the Code requirements -were'mposed has been considered in granting this relief.

4.6 Relief Re uest REL-06 The licensee has requested relief from the exercising test frequency and exercise requirements of ASME OMa-1988, paragraph 4.3.2.1, for the CTS valves CTS-127E, CTS-127W, CTS-131E, CTS-131W, RH-141, and RH-142.

The licensee has proposed to. disassemble, manually full-stroke exercise, and visually inspect the valves on a sampling basis (one of two in each pair) on a frequency of once every other refueling outage.

4.6.1 L'icensee's Basis For Re uestin Relief The licensee states:

These check valves are located in the supply lines to the (CTS-127E and

-W, lower compartment; CTS-131E and

-W, RH-141 and RH-

142, upper compartment)

CTS ring headers.

These valves are in the closed position during normal plant operation.

They perform an open safety function when CTS is active (passing flow to the ring header) and a subsequent closed safety function if CTS is suspended.

The valves are exposed to containment atmosphere on the downstream side and are isolated from fluid pressure on the upstream side by closed motor-operated valves.

The valves cannot be part-or full-stroked exercised during power operation, cold

shutdown, or refueling without spraying the containment.

The.only practical method to verify full-stroke is by disassembly.

The valves are not equipped with position indicators.

4.6.2 Alternate Testin The licensee proposes:

The valves will be disassembled, manually full-stroke exercised, and visually examined on a sampling basis (one of two in each pair), per GL 89-04, Attachment 1, Position 2, on a frequency of.

once every other refueling outage.

4.6.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

In Position 2 of Attachment 1 to GL 89-04, the NRC staff has indicated that a

sample disassembly program is an acceptable alternative when it is impractical to test check valves in a manner that will verify that the valve obturator travels to the full open position or closes on cessation of flow. It is impractical to test these valves in accordance with'he Code in that the containment would be sprayed during each test.

It would be an undue burden to.

impose the testing on the licensee in that modifications would have to be made

or a cleanup effort would be necessary after each test.

ON-10 (paragraph 4.3.2.4(c)) specifies that disassembly and inspection is one means of verifying the necessary check valve obturator movement, though it specifies disassembly of each valve every refueling outage.

The 1995 Edition of the OM Code allows a sample disassembly program and," therefore, the Code committee has indicated that it generally supports continued use of the NRC staff's position.

Because it is impractical to test these valves, a sample disassembly and inspection program may be used for assuring an adequate level of quality and safety.

However, the sampling program must comply with guidance in Position 2 of Attachment 1 to GL 89-04 in that the valves will be grouped in two pairs, as stated, and one of each group must be inspected during each refueling outage.

4.6.4 Conclusion Relief from the testing requirements, with an alternative to disassemble, manually full-stroke exercise, and visually inspect check valves CTS-127E,"

CTS-127W, CTS-131E, CTS-131W, RH-141, and RH-142 on a sampling basis is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of testing these valves in accordance with the Code, provided the guidance in Position 2 of Attachment 1 of GL 89-04 is followed.

The implementation of a sample disassembly and inspection program that conforms to the guidance of Position 2 of GL 89-04 will provide a reasonable assurance of the operational readiness of the valves.

The burden on the licensee if the Code requirements were imposed has been considered in granting this relief.

4.7 Relief Re uest REL-07 The licensee has requested relief from the stroke-time measurement requirements of ASNE ONa-1988, paragraph 4.2. 1.4, and from the fail-safe testing requirements for fail-safe valves, paragraph 4.2.1.6, for the charging header regulating valve, HARV-251 (both units).

The licensee has proposed to part-stroke exercise the valves on a quarterly basis and full-stroke exercise the valves at a cold shutdown frequency.

The alternative fail-safe testing will consist of locally observing the valve during full-stroke testing for smooth operation and apparent problems which can affect valve operation.

4.7.1 Licensee's Basis for Re uestin Relief The licensee states:

The air-operated

valve, HARV-251, is used to regulate charging header flow to the reactor coolant system (RCS) and seal water flow to the RCP seals.

The valve cannot be full-stroke exercised at power operation because it would inte'rrupt the RCP seal injection flow and would also upset pressurizer level.

The valve has no local or remote position indicator and meaningful stroke times are not achievable.

The control scheme of this valve functions to remove air from the valve operator, which duplicates the fail-safe condition, resulting

~in the valve going to its fail-safe open position.

4.7.2 Alternate Testin The licensee proposes:

This valve will be part-'stroke exercised during power operation and full-stroke exercised at a cold shutdown frequency.

The alternative fail-safe testing will consist of locally observing the valve during full-stroke testing for smooth operation and apparent problems which can affect the valve operation.

4.7.3 Evaluation The Code requires that the stroke time for power-operated valves be measured quarterly, and that valves with fail-safe actuators be tested by observing the operation of the actuator upon loss of valve actuating power.

These valves are not equipped with any type of position indication apparatus that could be used to aid in stroke timing the valves or detecting fail-safe operation.

The licensee proposes to part-stroke exercise these valves quarterly, and full-stroke exercise at a cold shutdown frequency.

The cold shutdown justification is consistent with Section 2.4.5 of NUREG-1482, and is consistent with the Code in paragraph 4.2.1.2.

The licensee did not propose any method to monitor the valves for degradation in their relief request.

Requiring these valves to be stroke timed and fail-safe test'ed is impractical and an undue burden on the licensee because the'licensee would have to replace the installed valves with valves capable of stroke-time measurement and fail-safe testing, or install position indication.

The proposed testing does not directly monitor the valves for degradation.

However, the valves are part-stroke exercised at a quarterly frequency and system parameters are monitored which should provide an indication that these valves have actuated to their closed safety position.

The licensee should develop acceptance criteria based on the proposed testing for the quarterly part-stroke test and full-stroke test at cold shutdown of these valves.

In addition, corrective action should be specified, such as valve replacement, if the valves fail the testing.

Finally, the licensee should take advantage of'ny future technologies that are developed to measure the stroke time of these valves.

With the addition of acceptance criteria and corrective action for these

valves, the proposed testing provides reasonable assur ance of operational readiness.

4.7.4 Conclusion Relief for stroke timing and fail-safe testing of charging header regulating

valve, HARV-251, is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of performing testi,ng in accordance with the Code requirements, and in consideration of the burden on the licensee if the Code requirements were imposed on the facility.

The granting of relief is provisional upon the

19-licensee developing acceptance criteria for the proposed alternate testing and appropriate corrective action if the valves fail the quarterly testing.

Relief for full-stroke testing at a cold shutdown frequency is not needed, as the cold shutdown frequency is allowed by the Code.

4.8 Relief Re uest REL-08 The licensee has requested relief from the test frequency and exercise requirements of ASME OMa-1988, paragraph 4.3.2. 1, for the feedwater check valves FW-118-1, FW-118-2, FW-118-3, and FW-118-4.

The licensee has proposed to partially disassemble and verify closed on a sampling basis (one of four) on a refueling outage frequency.

4.8. 1 Licensee's Basis for Re uestin Relief The licensee states.:

These check valves, FW-118-1, FW-118-2, FW-118-3, and FW-118-4, open during power.operation to pass main feedwater flow to the steam generators.

The valves close to isolate the feedwater headers on a loss of main feedwater flow, and to prevent diversion of auxiliary feedwater flow.

The valves cannot be exercised during power operation because this would require securing feedwater flow to the steam generators.

Main feedwater to the steam generators cannot be isolated on a loop basis because a

three loop operation is not allowed per Technical Specification 3.4. 1. 1.

Backflow cannot be quantified at cold shutdown due to system configuration.

The only practical method to verify valve closure is by disassembly.

Due to the size and weight of the valve and the close proximity to physical barriers (whip restraints);

valve disassembly at cold shutdown would impose constraints on the manpower and scheduling that may delay essential cold shutdown-related activities and plant startup.

There has been no operational or maintenance adverse trend noted.

4.8.2 Alternate Testin The licensee proposes:

The valves, will be partially disassembled and verified closed on a

sampling basis (one of four) at refueling outage frequency.

4.8.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

OM-10 (paragraph 4.3.2.4(c)) specifies that disassembly and inspection is one'eans of verifying the necessary check valve obturator movement, though it specifies disassembly of each valve every refueling outage.

The NRC staff has indicated in GL 89-04, Attachment 1, Position 2, that a sample disassembly program and partial disassembly testing are acceptable alternatives when it is impractical to test check valves in a manner that will verify that the valve obturator travels to the full open position or closes on cessation of flow.

NUREG-1482 in guestion Group 10 on page A-9 gives guidance on partial disassembly testing.

While the valve is in a partial disassembled condition, the valve internals should be inspected and the condition of the moving parts evaluated.

This inspection and evaluation should include verification by hand that the valve disk is free to move, but measurement of force or torque is not required.

Because of the impracticality of meeting the Code requirements, disassembly and inspection is an acceptable alternative, if the proposed testing conforms to the guidance in GL 89-04, Attachment 1, Position 2, and 'NUREG-1482.

The licensee does not clearly discuss this guidance and its incorporation into the program.

The licensee must have a relief request approved before the next refueling outage after the date of this SE if the licensee does not follow the guidance given in GL 89-04, Attachment 1, Position 2.

4.8.4 Conclusion Relief to parti ally disassemble and verify closed check, valves FW-118-1, FW-118-2, FW-118-3, and FW-118-4 on a sampling basis (one of four) at a refueling outage frequency is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of performing testing in accordance with the Code.

The granting of this relief is provisional on the sampling program complying with the guidance in GL 89-04, Attachment 1, Position 2,

and NUREG-1482.

4.9 Relief Re uest REL-09 The licensee has prepared justification for a refueling outage exercise frequency for containment isolation check valves NS-283 and NS-357 (both units).

The licensee has proposed to full-stroke exercise the valves in the open position quarterly by performing flow tests and confirm valve closure in conjunction with the Appendix J seat-leakage testing at a refueling outage frequency.

4.9.1 Licensee's Basis for Re uestin Relief The licensee states:

These containment isolation check valves, NS-283 and NS-357, are located on return lines of the post accident sampling system inside containment.

The l.ines are open-ended inside containment.

4.9.2 Alternate Testin The licensee proposes:

The valves will be full-stroke exercised in the open position quarterly by performing flow tests and will be confirmed closed in conjunction with the Appendix J seat-leakage testing at refueling frequency.

4.9.3 Evaluation The relief request is treated here as a refueling outage justification which implements provisions of the Code.

The justification is consistent with guidance in Section

4. 1.4 of NUREG-1482 for extending the test interval to each refueling outage for check valves verified closed by leak testing.

If the licensee intends to extend the test interval beyond each refueling outage, NRC approval would be necessary and additional justification, such as conditioning monitoring, would be required.

4.9.4 Conclusion The licensee has justified a refueling outage frequency for the containment isolation check valves NS-283 and NS-357.

The staff agrees with the deferral of this test to each refueling outage in that the justification is consistent with guidance in Section.4.1.4 of NUREG-1482.

4.10 Relief Re uest REL-10 The licensee has requested relief from the exercising test frequency and exercise requirements of ASHE OHa-1988, paragraphs 4.3.2. 1 and 4.3;2.2, for the accumulator check valves SI-166-1, SI-166-2, SI-166-3, and SI-166-4.

The licensee has proposed to disassemble, manually full-stroke exercise, and

. visually inspect the valves on a sampling basis (one of four) on a refueling frequency per GL 89-04, Attachment 1, Position 2.

4.10.1 Licensee's Basis for Re uestin Relief The licensee states:

Val.ves SI-166-1, SI-166-2, SI-166-3, and SI-166-4 function to prevent backflow from the RCS into the accumulators during normal operation.

The valves function to supply flow from the accumulators to the RCS during an accident condition.

The valves cannot be exercised at power operation because the accumulators do not have sufficient head to overcome RCS pressure.

The valves cannot be exercised during cold shutdown because this would result in a possible low temperature overpressurization of the reactor.

Full-stroke testing during refueling outages is not possible because of the resulting water surge into the reactor and the potential for high airborne contamination.

4.10.2 Alternate Testin The licensee proposes:

~

~ The valves will be disassembled, manually full-stroke exercised, and visually examined on a sampling basis (one of four) at refueling frequency per GL 89-04, Attachment 1, Position 2.

4. 10.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3,. 4.3.2.4, and 4.3.2.5.

The NRC staff has indicated that a sample disassembly program is an acceptable alternative when it is impractical to test check valves in a manner that will verify that the valve obturator travels to the full open position or closes on cessation of flow.

ON-10 (paragraph 4.3.2.4(c)) specifies that disassembly and inspection is one means of verifying the necessary check valve obturator

movement, though it specifies disassembly of each valve every refueling outage.

The 1995 Edition of the ON Code allows a sample disassembly program and, therefore, the Code committee has indicated that it generally supports continued use of the NRC staff's position.

Exercising the valves during any plant mode is impractical due to design limitations that preclude establishing sufficient flow through the valve, chal.lenge low-temperature/overpressure protection, or result in a water surge into the reactor causing high airborne contamination.

Because of these impracticalities, a sample disassembly and inspection program is an acceptable alternative when the guidance of Position 2 of Attachment 1 to GL 89-04 is followed.

To impose exercising in accordance with the Code would create an undue burden on the licensee in that system modifications would be necessary.

The alternative sample disassembly and inspection program will provide an adequate means of assessing the operational.

readiness of the valves.

4. 10.4 Conclusion Relief from the testing requirements, with an alternative to disassemble, manually full-stroke exercise, and visually inspect check valves SI-166-1, SI-166-2, SI-166-3, and SI-166-4 on a sampling basis, is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of testing these valves in accordance with the Code, provided the guidance in Position 2 of Attachment 1

of GL 89-04 is followed.

The implementation of a sample disassembly and inspection program that conforms to the guidance of Position 2 of GL.89-04 will provide reasonable assurance of the operational readiness of the valves.

The burden on the licensee if the Code requirements were imposed has been considered in granting this relief.

4.11 Relief Re uest REL-11 The licensee has requested relief from the test frequency and exercise requirements of ASHE OHa-1988, paragraphs 4.3.2. 1 and 4.3.2.2, for the emergency core cooling system (ECCS) check valves SI-170Ll, SI-170L2, SI-170L3, and SI-170L4.

The licensee has proposed to part-stroke exercise the

, valves during cold shutdown and disassemble, manually full-stroke exercise, and visually inspect the valves on a sampling basis (one of four) at refueling frequency per GL 89-04, Attachment 1, Position 2.

r

'- 4.11.1 Licensee's Basis for Re uestin Relief The licensee states:

Check valves SI-170L1, SI-170L2, SI-170L3, and SI-170L4 are located in the RCS cold leg, loops 1 through 4, injection lines from the accumulators, residual heat removal and safety injection systems.

They cannot be exercised during power operation because the pumps in these systems do not develop sufficient head to overcome RCS pressure.

The valves are sized such that full-stroke testing cannot be attained without discharging the accumulators and operating safety injection and residual heat removal pumps simultaneously.

4. 11.2 Alternate Testin The licensee proposes:

The valves will be part-stroke exercised at cold shutdown frequency.

The valves will be disassembled, manually full-stroke exercised, and 'visually examined on a sampling basis (one of four) at refueling frequency per GL 89-04, Attachment 1, Position 2.

4. 11. 3 Eval uat ion The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

The NRC staff has indicated that a sample disassembly program is an acceptable alternative when it is impractical to test check valves in a manner that will verify that the valve obturator travels to the full open position or closes on cessation of flow.

OH-10 (paragraph 4.3.2.4(c)) specifies that disassembly and inspection is one means of verifying the necessary check valve obturator

movement, though it specifies disassembly of each valve every refueling outage.

The 1995 Edition of the OH Code allows a sample disassembly program and, therefore, the Code committee has indicated that it generally supports continued use of the NRC staff's position.

Testing these valves in accordance with the Code is impractical due to design limitations in developing sufficient head to overcome RCS pressure without draining the accumulators and operating in essentially an accident situation (safety injection and residual heat removal pumps operating simultaneously),

which causes undue stress to components.

Because of the impracticality, a sample disassembly and inspection program is an acceptable alternative when the guidance of Position 2 of Attachment 1 to GL 89-04 is followed.

To impose exercising in accordance with the Code would create an undue burden on the licensee in that system modifications or operation in an accident condition would be necessary.

The alternative sample disassembly and inspection program will provide an adequate means of assessing the operational readiness of the valves.

4.11.4 Conclusion Relief from the testing requirements, with an alternative to part-stroke exercise on a cold shutdown frequency and disassemble, manually full-stroke

exercise, and visually inspect check valves SI-170L1, SI-170L2, SI-170L3, and SI-170L4 on a sampling basis during refueling outages, is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of testing these valves in accordance with the Code, provided the guidance in Position 2 of Attachment 1

of GL 89-04 i's followed.

The implementation of a sample disassembly and inspection program that conforms to the guidance of Position 2 of GL 89-04 will provide reasonable assurance of the operational'eadiness of the valves.

The burden on the licensee if the Code requirements were imposed has been considered in granting this relief.

4.12 Relief Re uest REL-12 The licensee has requested relief from the test frequency and exercise requirements of ASME OMa-1988, paragraphs 4.3.2. 1 and 4.3.2.2, for the ECCS check valve SI-189.

The licensee has proposed to part-stroke exercise to the open position the valve during cold shutdown and disassemble, manually full'-

stroke exercise, and visually inspect the valves at every third refueling outage.

4. 12. 1 Licensee's Basis for Re uestin Relief The licensee states:

Check valve, SI-189, is located in the safety valves discharge (emergency core cooling, residual heat removal, centrifugal charging pump, etc.) collection header leading to the pressurizer relief tank.

Isolating this valve for testing would result in dead heading all safety valves in the above systems.

This,would result in loss of overpressurization protection and could put the plant in an unsafe condition.

The licensee proposes:

The valve will be part-stroke exercised to the open position using an external source via test connection at a cold shutdown frequency.

The valve will be disassembl.ed, manually full-stroke exercised, and visually examined every third refueling frequency.

4. 12.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

OM-10 (paragraph 4.3.2.4(c)) specifies that disassembly and inspection is one means of verifying the necessary check valve obturator movement, though it

specifies disassembly of each valve every refueling outage.

The staff has indicated that, when exercising is impractical, a sample disassembly and inspection program is an acceptable alternative for assuring an adequate level of quality and safety provided guidance is GL 89-04, Attachment 1, Position 2,

is followed.

The licensee's alternative does not meet the guidelines given in GL 89-04, Attachment 1, Position 2.

The valve is in a group of only one, and must be disassembled, inspected, and manually full-stroke exercised at each successive refueling outage.

Extension of the val,ve disassembly and inspection interval to one valve every other refueling outage or expansion of the group size above four valves should only be considered in cases of extreme hardshi where the extension is supported by actual in-plant data from previous testing.

A definition of extreme hardshi is given by the staff 'in NUREG-1482, guestion Group 19, on, page A-13.

Because the licensee did not provide any justification of the extreme hardshi for this valve, disassembly and inspection of the valve must be performed each refueling outage.

4.12.4 Conclusion Relief to part-stroke exercise the check valve SI-189 at cold shutdown frequency and disassemble, manually full-stroke exercise, and visually inspect the valve, per GL 89-04, Attachment 1, Position 2,

on a frequency of each refueling outage is granted pursuant to 10 CFR 50.55a(f)(6)(i) based on the impracticality of exercising the valve in accordance with Code requirements.

The implementation of a part-stroke exercising and a sample disassembly and inspection program that conforms to the guidance of Position 2 of GL 89-04 will provide an adequate level of assurance of the operational readiness of the valve.

The proposal

.to perform the examination every third refueling outage the valve is not acceptable because there is insufficient justification of an extreme hardshi

therefore, the disassembly and inspection must be performed each refueling outage.

If the licensee believes that additional justification cari be provided, the relief request may be revised and resubmitted for NRC review.

4.13 Relief Re uest REL-13 The licensee has requested relief from the test frequency and exercise requirements of ASHE OMa-1988, paragraphs 4.3.2. 1 and 4.3.2.2, for the chemical volume and control system (CVCS) check valves CS-328Ll, CS-328L4, CS-

329L1, and CS-329L4.

The licensee has proposed to disassemble and inspect the valves on a sampling basis (one of four) at refueling frequency per GL 89-04, Attachment 1, Position 2.

4.13.1 Licensee's Basis for Re uestin Relief The licensee states:

Check valves CS-328L1, CS-328L4, CS-329L1, and CS-329L4 function to provide the interface point between the RCS and the CVCS.

.Since the discharge piping of the CVCS is designed to a pressure rating higher than the

RCS, these valves do not perform a pressure i.solation function.

The high pressure to low pressure isolation is accomplished by other valves which are tested to Category A requirements.

These 3-inch bolted, bonnet-swing check valves have no external position indication or means 'of exercising, and are located inside the crane wall in reactor containment.

These valves are in the INPO SOER 86-03 Check Valve preventative maintenance (PM) program.

Those which have been internally inspected under this program have been found in good condition.

4. 13.2 Alternate Testin The licensee proposes:

Per GL 89-04, Attachment 1, Position 2, the valves will be disassembled and inspected on a sample basis (one of four) each refueling outage.

4.13.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.'3, 4.3.2.4, and 4.3.2.5.

The NRC staff has indicated that a sample disassembly program is an acceptable alternative when it is impractical to test check valves in a manner that will

~ verify that the valve obturator travels to the full open position or closes on cessation of flow.

OM-10 (paragraph 4.3.2.4(c))

specifies that disassembly and inspection is one means of verifying the necessary check valve obturator

movement, though it specifies disassembly of each valve every refueling outage.

The 1995 Edition of the OM Code allows.a sample disassembly program and, therefore, the Code committee has indicated that it generally supports continued use of the NRC staff's position.

Testing these valves in accordance with the Code may be impractical due to design limitations in that no external position indication is installed, no external exercising means.

However, the licensee does not discuss whether the valves can be exercised using flow or back pressure and monitoring system conditions.

Because the justification is incomplete, relief cannot be granted.

4.13.4 Conclusion Relief from the testing requirements, with an alternative to disassemble, manually full-stroke exercise, and visually inspect check valves CS-328Ll, CS-

328L4, CS-329L1, and CS-329L3 on a sampling basis during refueling outages,.is.

denied at this time.

The licensee may provide additional justification of the impracticality of performing testing in a revised relief request.

4.14 Relief Re uest REL-14 The licensee has requested relief from the test frequency and exercise requirements of ASME OMa-1988, paragraphs 4.3.2. 1 and 4.3.2.2, for the check valve CS-295.

The licensee has proposed to exercise the valve in accordance with OM-10, paragraph 4.3.2.4, at refueling frequency and close position verify by radiography or other non-intrusive means.

If non-intrusive examination does not yield conclusive results, the valve will be disassembled and inspected at refueling frequency.

4. 14.1 Licensee's Basis for Re uestin Relief The licensee states:

The normally open check valve, CS-295, is located in. the volume control tank discharge to charging pump suction header and is downstream of the RCP seal water return branch connection.

Under certain conditions (see Westinghouse NSAL-92-012), this valve may perform an important to safety function during the recirculation phase of a LOCA by closing to prevent leakage of significant amounts of containment sump water back through the seal water heat exchanger circuit, ultimately preventing a leakage path outside of containment.

Exercising the valve closed during normal plant operation would require securing the charging pumps which would interrupt charging/letdown flow as well as RCP seal injection.

Loss of charging could result in loss of pressurizer level control followed by a reactor trip.

Testing this valve would require termination of seal injection flow.

Seal injection flow is maintained continuously to cool and lubricate the RCP seals, and to prevent contaminants in the RCS from coming into contact with (and potentially damaging) the RCP seals and pump bearing.

This valve has been disassembled and inspected under the INPO SOER 86-03 Check Valve PM Program with no degradations found.

4.14.2 Alternate Testin The licensee proposes:

This valve will be exercised in accordance with OM-10, paragraph 4.3.2.4, at a refueling frequency and 'closed position verified by radiography or other non-intrusive means.

If non-intrusive examination does not yield conclusive results, the valve will be disassembled and inspected at a refueling frequency.

4.14.3 Evaluation The Code requires that check valves be exercised nominally every 3 months, except as provided by paragraphs 4.3.2.2, 4.3.2.3, 4.3.2.4, and 4.3.2.5.

OM-10 (paragraph 4.3.2.4(c)) specifies that disassembly and inspection is one means of verifying the necessary check valve obturator movement, with the disassembly and inspection at each refueling outage.

Nonintrusive techniques are considered "other means" of verifying obturator travel in accordance with the Code.

Because the licensee's proposal complies with the provisions allowed in the Code, relief is not necessary.

Therefore, the proposal is considered a refueling outage justification as allowed by the Code.

4. 14.4 Conclusion The licensee has requested a refueling outage justification for the check valve CS-295.

If non-intrusive examination does not yield conclusive results, OM-10 (paragraph 4.3.2.4(c))

allows for the valve to be disassembled and inspected.

Therefore, the staff agrees with the deferral of this test to each refueling outage, whether performed with nonintrusive techniques or by disassembly and inspection.

5.0 REVIEW OF IST PROGRAM SCOPE The staff performed an IST program scope review on the Donald C.

Cook Auxiliary Feedwater, Essential Service Water and Safety Injection Systems.,

System piping and instrument diagrams, the Updated Final Safety Analysis Report (UFSAR),

and plant Technical Specifications were reviewed.

Valves determined to have safety functions were compared to the licensee's IST program listing for the respective systems.

Individual valve testing and safety attributes proposed by the IST program were also reviewed for consistency with applicable codes and regulatory guidance for each of the sample systems.

As a result of this review, the staff 'determined that certain components and component safety functions may have been omitted from the scope of the licensee's IST program.

The licensee should review the following components identified by the staff with respect to the requirements of OMa-

1988, Part 10 (Section 1.1),

and revise the IST program as necessary.

Because the staff's review was for a limited number of systems, the licensee should assess the remaining systems for any generic omissions identified by this review.

. 5. 1 Auxiliar Feedwater S stem

5. 1. 1 Motor Driven Pum Suction Relief Valves Relief valves SV-169E and SV-169W in the auxiliary feedwater system are not included in the IST program for Units 1 or 2. It appears these relief valves may have an overpressure protection function in protecting the suction piping of the auxiliary feedwater system in accordance with the scope requirements of OMa-1988, Part 10 (Section 1.1).

5. 1.2 Motor Driven Pum Dischar e Manual Crosstie Valve Valve FW-129 in the auxiliary feedwater system is not included in the IST program for Units 1 or'2.

It appears this manual valve may have a safety function as a crosstie connection on the discharge of the motor-driven auxiliary feedwater pumps from one unit to the other in accordance with the scope requirements of OMa-1988, Part 10 (Section

1. 1).

The emergency function of the valve, which provides flexibilityfor motor power from the other unit, is discussed in Section 10.5.2.2 of the Donald C.

Cook UFSAR.

I I'

5. 1.3 Motor Driven Pum Dischar e Check Valves Check valves FW-153 and FW-160 in the auxiliary feedwater system are not included in the IST program for Units 1 or 2.

It appears these check valves may have a safety function in preventing flow from the condensate storage tank to the discharge of the motor-driven auxiliary feedwater pumps in accordance with the scope requirements of OHa-1988, Part 10 (Section l.1).

5. 1.4 Auxiliar Feedwater Pum Suction Crosstie Valve Valve CRV-51 in the auxiliary feedwater system is not included in the IST program for Units 1 or 2 with a safety position of open.

It appears this valve has a safety function to open to provide an additional source of high purity water to the auxiliary feedwater pumps through the crosstie connection between the two units'ondensate storage tanks in accordance with the scope requirements of OMa-1988, Part 10 (Section

1. 1).

The emergency function of the valve, which provides flexibilityin aligning to the other unit's tank,for a backup suction water supply to the AFW pumps, is discussed in Section 10.5.2.2 of the Donald C.

Cook UFSAR.

5.2 Essential Service Water S stem 5.2. 1 Essential Service Water Relief Valves Relief valves SV-14E and SV-14W in the essential service water system are not included in the IST program for Units 1 or 2.. It appears these relief valves may have an overpressure protection function in protecting the heat exchanger of the essential service water system in accordance with the scope requirements of OHa-1988, Part 10 (Section

1. 1).

5.2.2 Essential Service Water Relief Valve I

Relief valve SV-16 in the essential service water system is not included in the IST program for Units 1 or 2. It appears this relief valve may have an overpressure protection function in protecting the discharge piping of the heat exchanger of the essential service water system in accordance with the scope requirements of OHa-1988, Part 10 (Section l. 1).

5.2.3 Essential Service Water Keat Exchan er Outlet Valves Valves WHO-737 and WHO-733 in the essential service water system are not included in the IST program for Units 1 or 2 with a safety function to close.

It appears these valves may have a safety function to close if the heat exchanger must be bypassed in accordance with the scope requirements of OMa-

1988, Part 10 (Section l. 1).

Valves WHO-713 and WMO-717 were included in the program with a safety function of open and closed on the two other heat exchangers.

30-5.3 Safet In ection S stem No questions on the scope of the safety injection system were identified.

6.0 ANONALIES The following anomalies were noted during the course of the IST program review.

The licensee should review these items and make changes to their IST program, testing procedures, or other plant documentation as necessary.

Items which require a response to the NRC should be completed within 1 year or the next refueling outage, whichever is longer, unless otherwi,se stated.

Relief requests determined to be required as a result of this review should be submitted for NRC evaluation prior to the next scheduled testing, or within 90 days, whichever is later.

Proposed alternatives may not be implemented without prior NRC approval except. where testing in accordance with the Code is impractical.

6.1 P-1 SE Section 3.1 Relief was denied to change the Code vibration acceptable range from <2.5 V

to g2.0 V, the Code vibration alert range limit from 2.5 V to 6 V or 0.325 inches/second (in/sec) to 2.0 V to 4 V or 1.2 in/sec, and the Code required action range from >6 V or >0.76 in/sec to >4 V or >2.0 in/sec for the CTS pump PP-009. 'he relief request did not contain sufficient

~s ecific

, information on the pump vibration history and efforts to improve performance to justify the less conservative absolute requirements.

Therefore, the licensee must perform testing of the CTS pump in accordance with the Code requirements.

6.2 P-2 SE Section 3.2 Interim relief was granted from the Code axial direction vibration measurement requirements for the boric acid transfer pumps 1-PP-45-1,2 and 2-PP-46-3,4.

The licensee's proposed alternative did not provide sufficient justification to exclude the axial measurement as a major vibrational contributor.

The licensee did not describe methods or attempts at taking axial vibrations, or discuss other examples of similar pumps where axial vibration is not a major contributor to the vibration of the pump.

The relief is granted for an interim period of 90 days from the date oF the SE to allow the licensee time to revise its relief request to address the concerns raised in this evaluation and incorporate any appropriate guidance provided in NUREG-1482.

6.3 REL-Ol SE Section 4.1 Relief is granted for local observation of the steam generator power-operated relief valves HRV-201/223/233/243 based on the 'impracticality of performing testing in accordance with the Code.

The granting of relief is provisional on the licensee establishing acceptance criteria and corrective actions and including these in the appropriate IST procedure.

31 6.4 REL-03 SE Section 4.3 Relief is granted for stroke timing component cooling water letdown heat exchanger regulating valve CRV-470.

The relief was granted provided the licensee develops acceptance criteria for the proposed alternate testing and appropriate corrective action if the valves fail the quarterly testing.

Relief for fail-safe testing the valve to its closed position at cold shutdown frequency is not needed.

6.5 REL-07 SE Section 4.7 Relief is granted for stroke timing and fail-safe testing of charging header regulating valve HARV-251.

The relief was granted provided the licensee develops acceptance criteria for the proposed alternate testing and appropriate corrective action if the valves fail the quarterly testing.

Relief for full-stroke testing at cold shutdown frequency is not needed, and the alternate cold shutdown frequency is justified based on the consistence with Section 2.4.5 of NUREG-1482.

6.6 REL-08 SE Section 4.8 Relief is granted provided the sample disassembly program conforms to the guidance in GL 89-04, Attachment 1, Position 2, and NUREG-1482.

If the program does not conform with the guidance given in GL 89-04, Attachment 1,

Position 2, and NUREG-1482, the licensee must seek approval of a relief request for the differences.

6.7 REL-09 SE Section 4.9 and A

endix C

The licensee has requested ll refueling outage justifications (REL-09, ROJ-Ol, ROJ-02, ROJ-05, ROJ-06, ROJ-08, ROJ-09, ROJ-'10, ROJ-16, ROJ-17, and ROJ-18).

The justifications are consistent with Section

4. 1.4 of NUREG-1482.

Option 8

of Appendix J may not,

however, be used to justify changing the closure testing frequency beyond each refueling outage.

The licensee should ensure that the closure testing frequency is each refueling outage.

If an extended interval for local leakage rate testing is justified under Option 6, the licensee may consider an alternative means of performing closure testing and revise these refueling outage justifications.

6.8 REL-12 SE Section 4.12 Relief is granted to part-stroke exercise the check valve, SI-189, at cold shutdown frequency and,disassemble, manually full-stroke exercise, and visually inspect the valve, per GL 89-04, Attachment 1, Position 2, on a

frequency of each refueling outage.

The relief requested to perform the examination every third refueling frequency for the valve is denied, because the licensee has not provided adequate justification to extend the testing beyond a period of every refueling outage.

The licensee should submit, for approval prior to the next refueling outage, a revised relief request justifying the extreme hardshi to extend the interval to every other refueling outage.

6.9 REL-13 SE Section 4.13 For CYCS check valves CS-328L1, CS-328L4, CS-329L1, and CS-329L4, the licensee's basis for relief does not adequately describe the impracticality in performing testing in accordance with the Code requirements and relief is denied.

The relief request should be revised to more completely describe why the valves cannot be tested with flow or back pressure.

6.10 ROJ-13 A

endix C

For deferral of testing valve SI-148 to refueling outages, when the reactor vessel head is removed, the core is offloaded, and sufficient volume to inject

is available, the ROJ is sufficient if the core is offloaded and the test performed each refueling outage.

If the core is not offloaded each refueling

outage, then the ROJ should be changed to a relief request for performing testing only during those refueling outages when the core is offloaded, with justification that such an extended test interval will continue to provide assurance of the operational readiness of the valve.

This is not meant to suggest that the licensee offload the core each refueling outage, but is meant to point out that extensions beyond each refueling outage must be covered by a relief request.

6. 11 Relief Re uests REL-02 REL-05 REL-06 REL-10 and REL-ll For the listed relief requests, the licensee has proposed to use a sample disassembly and inspection program.

The use of such a program is acceptable where testing in accordance with the Code is impractical;

however, the program must comply with the guidance delineated in Position 2 of Attachment 1 to GL 89-04.

Where the program does not comply with the guidance, relief for the deviations must be graqted.

If test methods are developed that make testing practical, the licensee>'.should investigate the use of such methods and make changes to the IST oF,,'these valves as appropriate.

7. 0 CONCLUSION The staff concludes that the relief requests, as evaluated and modified by this SE, will provide reasonable assurance of operational readiness of the pumps and valves in the IST program.

Where relief requests are denied, the licensee must comply with the Code requirements.

Where relief requests are granted or approved on an interim basis, the licensee should take the recommended actions prior to the expiration of the interim period.

The staff has determined that granting relief requests and approving alternatives pursuant to Sections (f)(6)(i) and (a)(3)(i) of 10 CFR 50.55a is authorized by law and will not endanger life or property, or the common defense and

security, and is otherwise in the public interest.

In making a determination of impracticality, the staff has considered the burden on the licensee if the requirements were imposed.

Principal Reviewers:

P.

Campbell J; Colaccino R. Hall Date:

May 27, 1997

APPENDIX A SUNNARY OF SUBNITTED RELIEF REQUESTS Relief Reques Number

SE Sectio

.'G

i'OMa-1988"

, Paragraph 8

Requirements,

,'=Equi pment

.".'.'Identif ication'-.',.-.,':,,,"::

.,',. -. Alternate

.'.:,",~':,;,'.Method of

,; MRC,;,~,

,::-Action-P-1 P-2 3.1 3.2 Part 6, Table 3a Ranges for Test Parameters Part 6, Section 4.6.4(a)

Vibration Measurement PP-009 contaiwent spray pump 1-PP-45-1, 1-PP-45-2, 2-PP-46-3, and 2.PP.46.4 boric acid transfer putlps The acceptable range for the,CTS pumps vill be set at <2.0 V the alert range vill be set at 2.0 V, to 4 V, or 1.2 in/sec, and the action range vill be set at >4 V, or >2.0 in/sec.

Although the overaLL vibration amplitude is increased over the alert and required action limits of ASME OMa-1988, Part 6, Table 3a, the proposed alternate values are based upon our review of past operating data for these psnps.

'The values are a more representative basis for trending performance of the CTS

psrps, and as such provide an acceptable level of quality and safety.

For these centrifugal

punps, measurements shall be taken in a plane approximately perpendicular to the shaft in two orthogonal directions on each accessible pwp bearing housing.

Relief denied See Section 6.1 of this SE.

Interim relief granted (f)(6)(i) for 90 days ~

See Section 6.2 of this SE.

I

Relief Reques t

Rumba r SE Sectio n

OHa-1988

'Paragraph 8

Requirements

- Equipment Ident ification'-

Alternate Method of Testing HRC Action P-3 REL-01 REL-02 3.3 4.1 4.2 Part 6, paragraph 6.1 Acceptance Criteria Part 10, paragraphs 4.2.1.4 (stroke timing) and 4.2.1.6 (fail-safe testing)

Part 10, paragraph 4.3.2.1 All IxNps in IST program MRV-213, MRV-223, HRV-233, and HRV-243 steam generator power-operated relief valves CCM-224-1, -2, -3, and

-4, and CCll-255-1, -2,

-3, and -4 reactor coolant IxNp thermal barrier heat exchanger check valves In lieu of the requirements of OHa-1988, Part 6, Subsection 6.1, "Acceptance Criteria" for pumps whose deviations fall within the required action range of Table 3, "Ranges for Test Parameters,4 the requirements of OM.1995, Subsection ISTB 6.2.2, wAction Range," will be ispiemented for the IST of safety-related pwys.

If the measured test parameter values fall within the required action range of Table ISTB 5.2.1-1 or Table ISTB 5.2.1-2, as applicable, the pmp shall be declared inoperable until either the cause of the deviation has been determined and the condition is corrected, or an analysis of the Ixwp is performed and new reference values are established in accordance'ith paragraph ISTB 4.6.

The valves will be exercised quarterly under local observation to assure smooth operation and lack of apparent problems ~hich could affect valve operation.

The valves will be disassembled, manually full.stroke exercised, and visually examined on a sampling basis (two of eight), per GL 89-04, Attachment 1, Position 2, at refueling frequency such that all valves will be examined no less frequently than once every fourth refueling outage.

Alternative authorized (a)(3)(i)

Relief granted (f)(6)(i)

See Section 6.3 of this SE ~

Relief granted (f)(6)(i)

See Section 6.11 of this SE.

A-2

Relief Reques t

Number SE Sectio n

OMa-19SS Paragraph 8

Requirements Equi pment identification Alternate Method of Testing NRC Action REL-03 REL-04 REL-05 REL 06 REL-07 4.3 4.5 4.6 4.7 Part 10, paragraph 4.2.1.4, and from the testing frequency for fail-safe

valves, paragraph 4.2.1.6 Part 10, paragraph 4.F 1.1 Part 10, paragraph 4.3.2.1 Part 10, paragraph 4.3.2.1 Part

'IO, paragraph 4.2.1.4, and from the fail-safe testing requirements for fail-safe

valves, paragraph 4.2.1.6 CRV-470 Units 1 and 2 conponent cooling water letdown heat exchanger regulating valve CCM.451, -452, -453,

-454, -458, and -459 Units 1 and 2 component cooling water downstream isolation vatves CTS-103E, CTS-103W, CTS-138E, and CTS-138M contaiment spray valves CTS-127E, CTS-127M, CTS-131E, CTS-131',

RH-141, and RH-142 contairlent spray valves ORV.251 Units 1 and 2 charging header regutating valve The valve wi lt be full-stroke exercised quarterly using the auto/manual station which will permit rapid cycling and result in minimal inpact on letdown tenperature.

The valve will be fail-safe tested to its closed position at cold shutdown frequency with letdown flow out of service to.avoid high letdown line tenperatures that could cause flashing of the letdown heat exchanger and lifting of safety valves.

The valve witt be full-stroke tested and timed at cold shutdown frequency if the reactor coolant ixmps are stoppede The valves will be disassembled, manually fult-stroke exercised, and visually examined on a sampling basis (one of two in each pair), per GL 89-04, Attachnent 1,

Position 2, on a frequency of once cvcry other refueling outage.

The valves will be disassembled, manually full-stroke exercised, and visually examined on a sampling basis (one of two in each pair), per GL 89-0C, Attachment 1,

Position 2, on a frequency of once every other refueling outage.

This valve will be part-stroke exercised during po~er operation and full-stroke exercised at a cold shutdown frequency.

The alternative fail-safe testing wilt consist of localLy observing the valve during full-stroke testing for smooth operation and apparent problems which can affect the valve operation.

Relief granted (f)(6)(i)

See Section 6.C of this SE.

The request constitutes a

refueling outage/cold shutdown justification and no further NRC review is r

uired.

Relief granted (f)(6)(i).

See Section 6.1'1 of this SE.

Retief granted (f)(6)(i)-

Sce Section 6.11 of this SE.

Relief granted (f)(6)(i) with provisions.

See Section 6.5 of this SE.

A-3

lI

Relief Reques t

Nlnher SE Sectio n

OMa-1988 Paragraph Requilements Equipment

, Identification Alternate

'Iiethod,of Testing NRC Action REL-08 REL-09 REL-10 REL-11 REL-12 REL-13 4.8 4.9 4.10 4'1 4.12 4.13 Part 10, paragraph 4.3.2.1 Refueling Outage Justification Part 10, paragraph 4.3.2.1 and 4.3.2.2 Part

'10, paragraph 4.3.2.1 and 4.3.2.2 Part 10, pal'agraph 4.3.2.1 and 4.3.2.2 Part 10, paragraph 4.3.2.1 and 4.3.2.2 FW-118-1, FW.118-2, FW-118-3I and FM-118-4 feedwater check valves NS-283 and NS-357 contailment isolation check valves S1-166-1, S1-166-2, SI-166-3, and S1-166-4 accumulator check valves SI -170L1, S1-170L2, S1-170L3, and SI-170L4 ECCS check valves SI -'189 ECCS check valves CS-328L1I CS-328L4, CS-329L1, and CS.329L4 CVCS check valves The valves will be partially disassembled and verified closed on a sampling basis (one of four) at refueling outage frequency.

The valves still be full-stroke exercised in the open position quarterly by performing flow tests and will be confirmed closed in conjunction with the Appendix J seat leakage testing at refueling fr uency.

The valves will be disassembled, manual ly full-stroke exercised and visually examined on a sampling basis (one of four) at refueling frequency per GL 89-04, Attachment 1

Position 2.

The valves will be part-stroke exercised at cold shutdown frequency.

The valves will be disasseahied, manually full-stroke exercised, and visually examined on a sampling basis (one of four) at refueling frequency per GL 89-04, Attachment 1, Position 2.

The valve will be part-stroke exercised to the open position using an external source via test connection at a cold shutdown frequency.

The valve will be disassembled, manually full-stroke exercised, and visually examined every third refueling frequency.

Per GL 89-04, Attachment 1, Position 2, the valves will be disasselllbled and inspected on a sample basis (1 of 4) each refueling outage.

Relief granted (f)(6)(i) with provisions.

See Section 6.6 of this SE.

The request constitutes a

refueling outage justification.

See Section 6.7 of this SE.

Relief granted (f)(6)(i)~

See Section 6.11 of this SE ~

Relief granted (f)(6)(i)-

See Section 6.11 of this SE.

Relief granted in part per (f)(6)(i) and denied in part.

See Section 6.8 of this SE.

Relief denied.

See Section 6.9 of this SE.

Relief Reques t

Mmber SE Sectio n

OHa-1988 Paragraph 8,

Requirements Equipment Identification Alternate Hethod of Test ing

',,NRC Action REL-14 4.'l4 Part 10, paragraph 4.3.2.1 and 4.3.2.2 Refueling Outage Justification CS-295 CVCS check valve This valve will be exercised in accordance with OH-10, paragraph 4.3.2.4 at refueling frequency, and close position verify by radiography or other nop-intrusive means.

If non-intrusive examination does not yield conclusive

results, the valve will be disasserhled and inspected at refueling frequency.

The request constitutes a

refueling outage justification for either method of verifying obturator travel.

A-5

l i a

~

e

~

f

APPENDIX B REVIEW OF COLD SHUTDOWN JUSTIFICATIONS

,

',;iNumber'Ãi: ;'.;";,:iand::Function".:6(

CSJ-01 CSJ-02 CSJ-03 FM.132.1, FM-132-2, FM-'332-3, and FM-132-4 Auxiliary Feedwater FM-134 and FM-135 Aux'ilfary Feedwater FM-138 1, FM-138-2, FM-138-3, and FM-138-4 AuxIl fary Feedwater These auxiliary feedwater (AFM) check valves functim to supply AFM to the stems generators when the AFM System is actuated.

These check valves cannot be full-or part-stroke exercised during power operation without energizing the AFM System and delivering cold water to the stean generators.

'This would result fn thermal shock to the steam generator nozzles.

These valves are full-stroke exercised dur ing startup.

These valves are located on the suctfon and discharge lines of the turbine driven AFM pcmp.

The maxinua flow rate through the turbine driven AFM punp during IST is approximately 700 gpm using the pcap test line.

Passing the design flow of 900 gpm through these valves would require delivering cold auxiliary feedwater to the steam generators.

This would result in thermal shock to the steam generator nozzles.

The vatves will be part-stroke exercised quarterly and full-stroke exercised.(passing design flow of 900 gpn through the valves) on a cold shutdown frequency.

These AFM check valves function to s~ty AFM to the steam generators when the AFM System actuates.

The valves carnot be full-or part-stroke exercised during power operation without energizing the AFM System and delivering cold water to the steam generators.

This would result in thermal shock to the stems generator nozzles.

These valves are futl-stroke exercised when the plant is returned to wer after cotd shutdown.

The Justificat3on Is consistent with guidance provided in Section 2 4.5 of NIREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

The Justiffcation is consistent with Section 2A.5 of NUREG-1482.

Therefore, the staff agrees wfth the deferral of this test to cold shutdown.

The Justfffcat3on is consistent with Section 2.4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

CS J-04 XCR-100, XCR-101, XCR-102, and XCR-103 Contaiwent Air These air-operated containnent isotatfon valves are tocated fn the control air supply lines to the contafreent.

These valves caraot be full-stroke tested during power operation without causing a Loss of contaiwent controt afr.

Testing of these valves can potentially cause:

1) disruption of operation of air-operated valves In the contaicment, causing the valves to go to their fail-safe positfon (e.g. ~ closed position for containnent isolation valves)

~ 2) systens from performing their design fcxw:tion (I.e., termination of system flow and change in RCS pressure and temperature),

and 3) challenge ta system safeguard protection which aay result in a cxlit trip.

The valves will be fult-stroke exercised and tfmed at cold shutdown fr The Justfficatfon is consistent with guidance provided in Sections 2A.S and 3.1.1 of NLNEG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdcxal.

CSJ-05 CCR-455, CCR-456, and CCR-457 Coaponent Cooling Mater These valves are the component cooling water 3solation valves for the reactor support coolers.

The valves cannot be tested at power operation without securing cooling water to reactor support coolers which could cause overheating of the concrete around the reactor sorts.

The vatves will be full-stroke tested and timed at cold shutdown frequency.

The Justification is consistent with guidance prov3ded 3n Section 2.4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

8-1

J

~

1

~

."

.PCS J ('-'..",-.'~'4:ahd iFunct I one CSJ-06 CSJ-07 CTS-109 and CTS-110 Contaiwent Spray QRV-111 and ORV-112 Chemfcal and Volune Control These check valves fuw:tion as vaccxsrr breakers for the additive tank.

The valves are closed during normal plant operation to maintain the tank pressurized.

Since there is no set pressure specified, verifying freedom of movement with'no noticeable resistance assures the valves will open shortly after pressure reversal at the onset of vacuus fn the tank and reclose upon tank repressurization.

There is no seat'eakage criteria associated with these valves since nitrogen leakage does not conpromise their safety furction.

The closed furction of the valves is to prevent hunidity from entering the tank, condensing and diluting the sodiun hydroxfde.

Since nitrogen supply is regulated at 5 psig, the pressure within the tank prevents in-Leakage.

The valves will be verified closed quarterly during power operation and will be verified en on a cold shutdown frequency.

These valves are in the normal letdown line (Reactor Coolant System Loop 4 to CVCS Regenerative Heat Exchanger).

They carnot be tested at power as the resulting Letdownicharging flow mismatch would cause Pressurizer level osci llations and possibly cause the reactor to trip.

These valves.will be full-stroke tested,

timed, and fail-safe tested on a cold shutdown frequency.

This deferral is consistent with Sections 3.1.1 and 4.3.8 of NUREG-1482.

Therefore, the staff agrees with the Licensee's basis for deferring valve testing to cold shutdown.

Th3s deferral is cons3stent with Secti on 2.4.5 of NUREG-1482.

Therefore, the staff agrees w3th the licensee's basis for deferring this testing to cold shutdown.

CSJ-08 QCH-250 and OCH.350 Chemical and Vofur>> Control These motor-operated valves provide isolation capability for reactor coolant pump seal water return to the vofur>> control tank.

These valves cannot be exercised during power operation as testing would interrupt seal water flow which could cause damage to the purp seals.

These valves will be full-stroke exercised and timed on a cold shutdown fr This deferral Is consfstent with Section 2.4.5 of NUREG-1482.

The

, staff agrees with the licensee's basis for deferring this testing to cold shutdown.

CSJ-09 QCR-300 and QCR.301 Chemfcal and Vofur>> Control, These air-operated contafrm>>nt isolation valves are located on the Letdown l3ne.

Exercising the valves during power operation would result in Letdown isolation, possibly result3ng in a loss of pressurizer Level control which could cause a reactor trip.

These valves will be fuLL-stroke exercised, timed and fail-safe tested on a cold shutdown frequency.

The Justification fs consfstent with the guidance provided fn Sections 2.4.5 end 3.1.1 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

CSJ-10 CSJ-11 CSJ-12 QHO-200 and QHO-201 Chemical and Vofur>> Control QHO-451 and OH0.452 Chemical and Volur>> Control 1-CS-427N and 2-CS-427S Chemical and Vofur>> Control These valves are installed on the CVCS charging L3ne which provfdes borated water for RCS chemical shim control and reactor coolant makeup.

Isolation of this system would result in loss of pressurizer Level control which could cause a reactor trip.

These valves will be fuLL-stroke exercised and timed on a cold shutdown frequency.

These valves fcmctfon as volur>> control tank isolation valves.

Exercising these valves durfng power operatfon would result in Letdown isolation, possibly resulting fn a loss of pressurizer level control wfrich could cause a reactor trip.

These valves will be full-stroke exercised and timed on a cold shutdown frequency.

This valve fs located 3n the emergency boration flow path.

The valve cannot be tested during power without Inserting large negative reactivity which should result in a unit shutdown.

The valve will be full-stroke exercised on a cold shutdown frequency.

The Justification Is consistent with the guidance provided fn Section 2.4.5 of NUREG-1482

'herefore, the staff agrees wfth the deferral of this test to cold shutdown.

The Justificatfon is cons3stent with the guidance provided In Sections 2.4.5 end 3.1.1 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

The Justification is consistent with the guidance provided fn Section 2 4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

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CSJ-13 CS J-14 ECR-36 Contafrvaent Mas'te 0'Isposal 1-ESM-109, 1-ESM-115, 1-ESM.243, 2-ESM-145, 2-ESM-240, and 2-ESM-243 Essential Serv3ce Mater This valve is Located in the ccemon sample return line of the lower contaireent radiation monitors.

Lt cannot be part-or full-stroke exercised during power operation or refueling because closure would isolate both radiation monitors which are required to be operable (per T/S Table 3.3-6) during Nodes 1 through 4 and Hode 6.

The valve will be full-stroke exercised on a cold shutdown frequency.

These valves are norseLLy closed and are required to open when the condensate storage tank voLMne is exhausted.

Exercising these valves during power operation could cause lake water contamination of the steam generators.

Lake water chemistry can fspact steam generator tube integrity, leading to tube leaks.

Therefore, the valves will be full-stroke tested on a cold shutdown frequency.

The Justification fs consistent with the guidance provided fn Section 2A.S of NUREG-1C82.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

The Justification fs consistent with the guidance provided fn Section 2.4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

CSJ-15 CSJ-16 CS J-17 HS-108-2 and HS-108-3 Hain Steam HRV-210, HRV-220, HRV-230, and HRV.240 Hain Stems Not assigned in final doccznent.

These check valves are located fn the main steam supply lines to the Auxilfary Feedwater Pen@.Turbine.

These valves are part-stroke tested during turbine driven auxiliary feedwater pump testing at least quarterly at a flow rate of approximately 700 gpm.

Flow is restricted to a maxfrmmr of approximately 700 gpm through the 3-inch test line used during puap testing.

These valves are "nozzle" check valves which are equipped with an exercising port on the upstream side of the disc.

Due to the personnel hazard associated with reaeving the inspection plug at power (live steam fn Line), both valves will be full-stroke exercised on a cold shutdown frequency (port plug removed, disc exercised to full ition and aLLowed to return to full closed ftion).

These steam generator stop valves cannot be full-stroke exercised during power operation because this would require securing steam from a steam generator which could result in a reactor trip.

Three Loop operation is not aLLowed per Technical Specificatfon 3.4.1.1.

The valves will be part-stroke exercised quarterly by use of hydraulics attached to the valve operators and full-stroke exercised during hot standby (Hode 3 with RCS temperature less than or equal to, SC1 F) on a cold shutdown fr The Justification is cons3stent with the guidance provided fn Sect'ion 2.4.5 of NUREG-1482.

Therefore, the staff agrees wfth the deferral of this test to cold shutdown.

The Justification is consistent with the guidance provided in Section 2A.S of NUREG-1482.

Therefore, the staff agrees with-the deferral of this test to cold

shutdown, CS J-18 NRV-151,

- NRV-152, and NRV.153 Reactor Coolant These pressurizer power-operated relief valves are normally closed during power operation.

The valves cannot be exercised at power without initiating a primary system pressure transient which could result in a reactor trip.

The valves will be full-stroke exercised and timed on a cold shutdown frequency.

The Justification fs consistent with the guidance provided 3n Section 4.4.1 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

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CSJ.19 CSJ-20 CSJ-21 CSJ-22 NS0.021, NS0-022, NS0.023, NS0-024, HS0-061, NS0-062, MSO-063, and HSO-064 Post Accident Sampling RH-108E and RH-108M Residual Heat Removal IHO-261 Safety Injection IHO-262 and IHO-263 Safety Injection These solenoid-operated isolation valves are installed (two in each leg in series) in the reactor head vent (02x series) and in the pressurizer vent (06x series).

These valves cannot be tested during power operation, hot standby, or hot shutdown since the valves design is such that testing of either valve can cause momentary opening of the second valve, resulting in the release of radioactive fluid creating an airborne condition in containment.

The vaLves will be'full-stroke exercised and timed at cold shutdown frequency.

(Comnent:

The valve stem cannot be observed for movement since the stem of each valve is coapletely enclosed.

Remote position indication will be verified during refueling outages by the performance of flow test.

This method of testing is consistent with Technical S

cification R irements.)

These valves cannot be full-stroke exercised quarterly since the residual heat removal (RHR) punps cannot develop full head on the minisxsn flow recirculation circuit with the reactor coolant system at full temperature and pressure.

The valve will be part-stroke exercised quarterly and full-stroke exercised on a cold shutdown frequency (during RHR operation).

This valve is*the suction isolation valve for both high head safety injection (SI) pumps from the refueling water storage tank.

The valve" cannot be tested when the safety injection pumps are required to be operable as the testing would result in isolation of the comnon suction line, rendering the safety injection system inoperable.

This valve will be stroke tested and timed on a cold shutdown fr when the SI are not r ired to be o rable.

These valves are located in series in the recirculation line of the safety injection pumps.

Exercising either of the valves would render both safety injection Ixmps inoperable.

The valves will be stroke tested and timed on a cold shutdown frequency when the SI Ixsrps are not required to be operable.

The Justi fication is consistent with the guidance provided in Sections 2.4.5 and 4.2.8 of HUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

The Justification is consistent with the guidance provided in Section 2 4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

The Justification is consistent with the guidance provided in Section 2.4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

The Justification is consistent with the guidance provided in Section 2 4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

CS J:23 IHO-315 and IHO-325

'afety Injection These valves are normally closed valves located in the residual heat removal and safety injection supply header to the reactor coolant system hot legs.

The valves cannot be exercised during power operation because failure in a non-conservative position would result in less then the miniaxza number of injection flow paths as required by the FSAR.

The valves will be full-stroke tested and timed on a cold shutdown fr The Justification is consistent with the guidance provided in Section 3.1.1 of HUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

CSJ-24 IHO-316 and IN-326 Safety Injection These valves are normally open valves located in the residual heat removaL and safety injection supply header to the reactor coolant system hot legs.

The valves cannot be exercised during power operation because failure in a non-conservative position would result in less than the mininua number of injection flow paths as required by the FSAR.

The valves will be full-stroke tested and timed on a cold shutdown fr enc.

The Justification is consistent with 'the guidance provided in Section 3 ~ 1.1 of HUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

CSJ-25 SI-151E and SI-151N Safety Injection These check valves are located in the residual heat removaL supply lines to either the hot or cold legs.

The valves cannot be exercised during power operation because the residual heat removaL Imps do not develop sufficient head to overcome reactor coolant system pressure.

The valves will be exercised on a cold shutdown frequency.

The Justification is consistent with the guidance provided in Section 2.4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

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IN-340 and IHO-350 These valves are located in the east and west RHR discharge headers to the suction of the charging (IN-340) and SI ( IN-350) pcs.

These valves are normally closed during po~er operation, and would be opened during the recirculation phase of a LOCA to allow the RHR pumps to provide water from the contaira>>nt sunup to the charging and SI pumps.

These valves camot be full-stroke exercised during power operation because they are interlocked with valves IN-262, -263, located in series, in the SI pump mini flow line to the refueling water storage tank (RHST).

Closing IN-262, -263 would render both SI pumps inoperable and placing the unit in T/S 3.0.3 which allows one hour to restore the SI pa<ps to operable status or begin unit shutdown.

The complicated valve and equipment lineup to perform the valve testing in one hour is highly unlikely.

Therefore, the valves will be full-stroke exercised and timed on a cold shutdown frequency.

The justification is consistent with the guidance provided in Section 2.4.5 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to cold shutdown.

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APPENDIX C REVIEW OF REFUELING OUTAGE JUSTIFICATIONS ROJ Number-Valve-Number and Function Refueling Outage Justification NRC

'omnents ROJ-01 ROJ-02 ROJ-03 ROJ-04 ROJ-05 N-102 CCII-243-25, CCII-243-72, CCN-244-25, and CCN-244-72 CS-292 CS-299E and CS-299ll CS-321 This check valve is located in the nitrogen supply header to the accumjiators for blanketing the tanks with pressurized nitrogen.

The valve cannot be full-stroke tested to the closed position during power operation or cold shutdown since the only method available to verify the valve closure is leak testing.

The valve and necessary test connections are located inside the contailvnent.

The valve is not equipped with a position indicator.

The valve will be verified closed in conjunction with A ndix J seat leakage testing on a refueling outage fr ency.

These check valves are located in the penetration cooling supply headers of the component cooling water system inside contaireent.

The valves cannot be tested during power operation or cold shutdown since cooling must be maintained to the main steam penetrations.

These valves are not equipped with external position indication.

The valves will be confirmed closed in conjunction with Appendix J seat leakage testing on a refueling outage fr ency.

This valve is in the emergency boration path from the boric acid system to the charging pump suction header.

Flow through this path is provided at power only when necessary to add negative reactivity.

This valve will be full-stroke exercised in the open position on a cold shutdown frequency.

The check valve is not equipped with position indication.

The only methods available to verify valve closure is either by non-intrusive means (radiography or other), or by disassetthiy, one which will be performed on at a refueling outage frequency when the system is not required to be operable.

These check valves located on the discharge lines of the East and liest charging Ixmps function as pressure isolation valves to protect the low pressure charging pump suction lines.

These valves cannot be full-stroke exercised during power operation because the charging ixmys cannot achieve maxisasa flow rate with the reactor at full pressure or during cold shutdown because the required flow could cause a low temperature overpressure condition.

The valves will be part-stroke exercised quarterly to the open position and full-stroke exercised on a refueling outage fr ency.

This contairment isolation check valve functions to supply borated water from the voluae control tank to the regenerative heat exchanger through the charging pumps for chemical shim control and reactor coolant makeup.

The. valve is located inside contairment and is inaccessible during reactor operation.

Isolation of this system would result in loss of control of pressurizer level which could result in a reactor trip.

This valve is tested in the open direction quarterly and is confirmed closed in conjunction with Appendix J testing during refueling outages.

The justification is consistent with Section 4'.4 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to refueling outages.

The justification is consistent with Section 4.1.4 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to refueling outages.

The justification is consistent with the guidance provided in Position 2 of Attachment 1

to GL 89-04.

Therefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

The justification is consistent with guidance in

.Section 2.4.5 of NUREG-1482.

The staff agrees with the licensee's basis for deferring valve testing to refueling outages.

The justification is consistent with Section F 1.4 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to refueling outages.

','alve Number

. and Function Refueling Outage Justification HRC-Comoents N-160 1-ESM-LLL, 1-ESM-112) 1-ESM-113, 1-ESM-114, 2-ESM-141, 2-ESM-142, 2-ESM-143, and 2-ESM-144 R-156 and R-157 CS-442-1, CS-442-2, CS-422-3, and cs-422-4 N-159 and PM.275 This contaianent isolation check valve is located in the Nitrogen Supply line to the Reactor Coolant Drain Tank.

This valve cannot be part-or full-stroke exercised due to insufficient differential pressure to back seat the valve during power operation or cold shutdown.

The only method available to verify valve closure is leak testing.

The valve will be verified closed in conjunction with Appendix J testing during refueling outages.

These check valves open to provide cooling water to various Emergency Diesel Generator loads.

In addition, these valves close to prevent back flow into the opposite emergency service water (ESM) train header.

The open safety function will be tested in accordance with the Code.

The closed safety function cannot be tested in accordance with the Code since there are no external position indicators associated with the valves and no instrtmentation or taps available at the valve to determine positive closure.

In order to determine valve closure an entire ESM header and safety train, including both Emergency Diesel Generators, est be removed from service.

These valves cannot be tested at cold shutdown frequency because ESM is at its highest Load demand (RHR operating) at this time and cannot be removed from service.

The closed safety function will be verified by disassembly (attempts to perform nonintrusive evaluation did not yield meaningful results) on a refueling outage fr ency.

These check valves are installed in parallel lines to the glycol main supply and return lines to relieve glycol thermal expansion.

These valves and necessary test connections are located inside contaiment.

The only method available to verify valve closure is leak testing.

The valves will be full-stroke exercised in the open direction quarterly and verified closed in conjunction with Appendix J seat leakage testing on a refueling outage fr ency.

These contairment isolation check valves are located on the seal water supply line to the reactor coolant pumps.

They have a closed safety function to provide contairment isolation and an open safety function to provide a backup reactor coolant system boration flowpath.

The valves cannot be part-or full-stroke exercised to the closed position during po~er operation because cooling flow is required to the reactor coolant purp seals.

During cold shutdown, seal water nest be maintained to prevent backflow through the seals with possible seal. damage from contaminants in the reactor coolant.

Part-stroke flow through the check valves will be observed and recorded quarterly.

The valves will be full-stroke exercised in conjunction with Appendix J seat Leakage testing on a refueling outage fr ency.

These contairment isolation check valves are located in the nitrogen (H159) and primary water (PM-275) supply lines to the pressurizer relief tank.

The valves cannot be full-stroke tested to the closed position due to lack of sufficient differential pressure to back seat the valve.

The valves and necessary test connections are located inside the contaianent.

The only method available to verify valve closure is leak testing.

The valve will be verified closed in conjunction with Appendix J seat leakage testing on a refueling outage frequency.

The justification is consistent with Section 4.1.4 of NUREG-1482.

Therefore, the stiff agrees with the deferral of this test to refueling outages.

The justification is consistent with the guidance provided in Position 2 of Attachment 1

to GL 89-04 'herefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

The justification is consistent with Section 4.1.4 of NUREG-1482.

Therefore, the staff agrees with the deferral of this test to refueling outages.

The justification is consistent with Section 4.1.4 of HUREG-1482.

Therefore, the staff agrees with the deferral of this test to refueling outages.

The staff agrees with the licensee's basis to defer this testing to refueling outages.

In addition, the justification to defer closure testing is consistent with the guidance provided in Section 4.1.4 of HUREG-1482.

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ROJ., Valve Number'.;.

-Nurrber a'nd Function '.'.'A V

. RefUeling Outage

-.,'ustification NRC Conrrrents ROJ-11 ROJ-12 SI-110N, SI-110SI SI-'152N, and SI-152S SI-142LI, SI-142L2, SI-142L3, and SI -142L4 These safety injection purp discharge valves cannot be exercised during power operation because the safety injection pumps cannot overcome reactor coolant system pressure.

Since the minirrxan flow recirculation lines branch off upstream of these

valves, no flow path exists to part-stroke test the valves during pump testing.

These valves cannot be exercised during cold shutdown because the safety injection pumps are required to be inoperable by TS 3/4.5.3 to protect against low temperature overpressurization of the reactor.

These valves will be full-stroke exercised on a refueling outage frequency.

These valves are located in the supply lines from the Boron Injection Tank to the reactor coolant cold legs (Loop 1 through 4).

The valves cannot be part-or full-stroke exercised during power operation or cold.shutdown because this would require injection relatively cold refueling water storage tank water with a higher boric acid concentration into the reactor coolant system, affecting reactivity and reactor coolant system inventory.

The valves will be full-stroke exercised on a refueling outage frequency.

The Justification is consistent with guidance in Section 2.4.5 of NUREG-1482.

The staff agrees with the licensee's basis for deferring valve testing to refueling outages.

The justification is consistent with guidance in Section 2.4.5 of NUREG-1482.

The staff agrees with the licensee's basis for deferring valve testing to refueling outages.

ROJ-13 S I -148 This valve is located in the refueling water storage tank supply line to the residual heat removal system.

The design flow through the valve is 6000 gpm.

Flow to the core is not possible when the reactor coolant system pressure is above the shut-off pressure of the residual heat removal purps (195 psig).

In order to full-stroke exercise this valve, both residual heat removal purps rrast be operated and the residual heat removal system manually aligned to recirculate flow back to the refueling ~ster storage tank.

This configuration makes both residual heat removal trains inoperable since neither train can provide design flow to the core.

To preclude placing the unit in an unsafe condition, a part-stroke test is performed quarterly.

The valve cannot be full-stroke exercised during cold shutdown because the reactor coolant system cannot accorrrrrodate the introduction of 6000 gpn from the residual heat removal system.

Manual aligrment to the refueling water storage tank cannot be performed because the residual heat removal system is required to be operable for reactor coolant system terrperature control.

The valve will be full-stroke exercised when the reactor vesSel head is removed, the core is offloaded and sufficient volurre exists.

The staff agrees with the licensee's basis for deferring valve testing to refueling outages;

however, if the core is not offloaded each refueling

outage, the licensee should consider whether this ROJ represents a relief request and revise it as necessary.

See Section 6.10 of this SE ROJ-14 SI-158Ll, L2, L3, L4, SI-161LI, L2, L3, and L4 These valves are located in the supply lines from the Residual Heat Removal and Safety Injection Purrps to the reactor coolant system hot legs (SI-158 series) and cold legs (S1-161 series) loops 1 through 4. The valves cannot be exercised during power operation because the residual heat removal purrps and the safety injection purps do not develop sufficient head to overcome reactor coolant system pressure.

Full-stroke of the valves individually cannot be verified at cold shutdown frequency because flow instrurrentation is not available downstream of the flow split.

The valves will be part-stroke exercised at cold shutdown frequency.

Full-stroke will be verified using portable instrunentation on a refueling outage frequency.

The Justification is consistent with the gurdance provrded rn Position 2 of Attachment 1

to GL 89-04.

Therefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

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..Valve Nimber and Funct'ion Si-185 Refueling'Outage

-.. Justification This valve performs (1) an active safety function in the open position to provide suction for the centrifugal charging pcs from the refueling water storage tank for emergency core cooling, and (2) an active safety function in the closed position to prevent diversion of injection flow when the emergency core cooling systems are operating in the recirculation phase of safety injection following a loss of coolant accident.

Exercising the valve open cannot be accomplished during power operation without introducing a high concentration of boric acid into the reactor coolant system.

Exercising the valve at cold shutdown cannot be accosplished because the only full flow path available is into the reactor coolant system, which does not have sufficient volune to accomIaodate that flow without a possible low temperature overpressure condition.

This valve is normally closed.

Exercising the valve to the closed position requires that it first be opened, which cannot be accomplished for the above reasons.

The valve will be full-stroke exercised on a refueling outage frequency.

'RC Cosments The justification is consistent with guidance in Section 2.4.5 of NUREG-

'.482.

The staff agrees with the licensee's basis for deferring valve testing to refueling outages.

1-PA-343 (Unit

1) or 2-PA-342 (Unit 2)

CCM-135 SM-1 This check valve is located in the maintenance air supply line into the contairment.

The valve cannot be tested during power operation or cold shutdown because:

(1) this line is isolated by removing a spool piece and inserting a blind flange, and (2) the valve and test connections are located inside the contaiwent.

The valve is not equipped with a position indicator.

The only method available to verify the valve closure is leak testing.

The valve will be verified closed in conjunction with Appendix J seat leakage testing on a refueling outage frequency.

This valve is the component cooling water check valve for the reactor support coolers.

The valve cannot be tested at po~er operation without securing cooling water to reactor support coolers which could cause overheating and damage of the concrete around the reactor supports.

The valve will be verified closed in conjunction with Appendix J seat leakage testing on a refueling outage frequency.

This contaiwent isolation check valve is located on the contaiment radiation monitor's sample return and cannot be full or pert stroke exercised during power operation because these monitors are required to be operable in Nodes 1, 2, 3, 4, and 6 (during fuel movement).

The line is open-ended inside contairment.

The valve will be verified closed in conjunction with Appendix J seat leakage testing on a refueling outage frequency.

This deferral is consistent with the guidance provided in Section 4.1.4 of NUREG-1482.

Therefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

This deferral is consistent with the guidance provided in Section 4 '1.4 of NUREG-1482.

Therefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

This deferral is consistent with the guidance provided in Section 4.1.4 of NUREG-1482.

Therefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

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ROJ

, Number';

Valve Nunber,

':;..;and Function'.:,

, Refueling Outage Justification

, HRC Connents ROJ-19 ROJ-20 SI.101 CS-325 This valve is the comnon suction check valve for the safety injection pumps.

The valve cannot be full-stroke exercised at power as the safety injection punps cannot overcome reactor coolant system pressure and full opening of the valve cannot be achieved with the safety injection pumps operating on mininxm flow paths.

The valve is part-stroke exercised open at power operation during punp testing and full-stroke exercised on a refueling outage frequency.

The closure capability of the valve cannot be determined by flow or differential pressure measurements since instrunentation is not available and establishment of test conditions would isolate both SI pumps from their suction source and enter the unit in TS 3/4.5.2.

The valve cannot be exercised during cold shutdown because the safety injection pumps are required to be inoperable by TS 3/4.5.3 to protect against low tenperature overpressurization of the reactor.

The closure capability of the valve will be verified by disassenhly and inspection at a refueling outage frequency.

This 2-inch check valve is in the CVCS auxiliary pressurizer spray line.

The valve is not provided with external position indication, nor does instrunentation exist to test the closed safety function of these check valves quarterly or at cold shutdown frequency.

Therefore operability will be assured via alternative means provided by OMa-1988, Part 10, paragraph 4.3.2.4(c)

(disassembly and inspection on a refueling outage frequency).

This deferral is consistent with the guidance in Section 4.1.4 of NUREG-1482.

In addition, the proposed disassembly and inspection frequency and method is consistent with the guidance provided in Position 2 of Attachment 1

to GL 89-04.

Therefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

The justification is consistent with the guidance provided in Position 2 of Attachment 1

to GL 89-04.

Therefore, the staff agrees with the licensee's basis for deferring valve testing to refueling outages.

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