ML18022A639

Rev 1 to Technical Evaluation Rept,Pump & Valve Inservice Testing Program.

ML18022A639
Person / Time
Site:	Harris
Issue date:	02/29/1988
From:	Cook T, Ransom C IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:
Shared Package
ML18022A637	List: ML18022A639
References
CON-FIN-A-6812 EGG-NTA-7492, EGG-NTA-7492-R01, EGG-NTA-7492-R1, NUDOCS 8805040063
Download: ML18022A639 (158)

Text

EGG-NTA-7492 Revision 1 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 Docket No. 50-400 C. B. Ransom T. L. Cook Published February 1988 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DOE-AC07-76ID01570 FIN No. A6812 88050400SS 8804>>H 0500040O PDR ADOCW P PD~R

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ABSTRACT This EG&G Idaho, Inc., report presents the results of our evaluation of the Shearon Harris Nuclear Power Plant, Unit 1, Inservice Testing Program for pumps and valves whose function is safety related.

FOREWORD This report is supplied as part of the "Review of Pump and Valve Inservice Testing Programs for Operating Plants (III)" Program being

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conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear

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"Reactor Regulation, Mechanical Engineering Branch, by EGKG Idaho, Inc., ~

Mechanical Systems Evaluations.

The U.S. Nuclear Regulatory Commission funded the work under the authorization B3R 20-19-05-02-2, FIN No. A6812.

Docket No. 50-400

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CONTENTS ABSTRACT... ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ \o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ balll F OREWORD.............. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ill

1. INTRODUCTION.

2 ~ SCOPE ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 3

3. PUMP TESTING PROGRAM..................... . ................... .... ~ 9

3. 1 Various Safety Related Pumps.... . 9

3. 1. 1 Pump Bearing Temperature Measurements....... .......... 9 3.2 Auxiliary Feedwater Pumps.... ...................,......,...,. 10 3.2. 1 Pump Bearing Temperature Measurements. . . . ...... .. 10 3.3 Emergency Service Water Pumps........... .. . ..... 12 3.3. 1 Pump Vibration Measurements................,........... 12 3.4 Diesel Generator Fuel Oil Transfer Pumps....................., 13 3 '.

3.4.2 1 Flow Heasurement Accuracy Requirements.............,...

Pump Bearing Temperature Measurements..................

13 14 3,5 High Head Safety Injection/Charging Pumps 15 3.5. 1 Flow Measurement Allowable Range Limits................ 15 3.6 Boric Acid Transfer Pumps.. . 16 3.6.1 quarterly Flow Measurement.....................'....,... 16 3.6.2 Temperature Measurement and Observation of Lubricant... 18 3.7 Emergency Service Water and Component Cooling Water Pumps..... 20 3.7. 1 Establishing Reference Values For Pump Flow or Differential Pr'essure......................................,.. 20 3.8 Emergency Service Water Intake Screen Wash Pumps.............. 21 3.8. 1 Establishing Reference Values For Pump Flow or Differential Pressure . 21

4. VALVE TESTING PROGRAM............................................... 25

4. 1 Verify Reverse Flow Closure for Check Valves Inside C ontainment........ ~ .... ....................................,.....

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4.1.1 Category AC Valves........... 25

.2 Main Steam System............................................. 26 4.2. 1 Category B Valves................. 26 4.2.2 Category C Valves................. 28 4,3 Containment HVAC System....................................... 30 4.3.1 Category AC Valves .. ................................. 30 4.4 Auxiliary Feedwater System.................................... 31 4.4.1 Category C Valves. 31 4 .5 Condensate System........ .. ................................. 36 4.5. 1 Category C Valves............... 36 4.6 Containment Spray System............... 39 4.6.1 Category AC Valves 39 4.7 Instrument Air System. 40 4.7. 1 Category C Valves...................................... 40 4.8 Chemical and Volume Control System. . . 42 4.8. 1 Category A Valves................. 42 4.8.2 Category C Valves............. .. 43 4.9 Safety Injection System... .. ................................ 45 4.9. 1 Category A Valves................. 45 4.9.2 Category AC Valves........ 46 4.9.3 Category C Valves.. 48

4. 10 Component Cooling Water System.........

4. 10. 1 Category A Valves................ 49

4. 10.2 Category B Valves 51 4.10.3 Category C Valves 52 APPENDIX A--VALVES TESTED DURING COLD SHUTDOWNS ....................... 57 APPENDIX B--P&ID AND FIGURE LIST ...... 67 APPENDIX C--IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW ......... 71

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TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM SHEARON HARRIS NUCLEAR POWER PLANT UNIT 1

1. INTRODUCTION Contained herein is a technical evaluation of the pump and valve inservice testing (IST) program submitted by Carolina Power and Light Company for its Shearon Harris Nuclear Power Plant, Unit l.

The working session with Carolina Power and Light Company representatives was conducted on August 5 and 6, 1986. The licensee's IST program, Revision 3 dated September 16, 1986, as amended by the changes identified in the A.B. Cutter to H.R. Denton letter dated December 31, 1986, the A.B. Cutter to U.S. NRC letter dated March 20, 1987, and the S. R.

Zimmerman to U.S. NRC letter dated December 4, 1987, was reviewed to verify compliance of proposed tests of pumps and valves whose function is safety-related with the requirements of the ASME Boiler and Pressure Vessel

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Code (the Code),Section XI, 1983 Edition through Summer 1983 Addenda. Any IST program revisions subsequent to those noted above are not addressed in this technical evaluation report (TER). The NRC staff position is that

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

In their IST program, Carolina Power and Light Company has requested relief from the ASME Code testing requirements for specific pumps and valves and these requests have been evaluated individually to determine if the required testing is indeed impractical for the specified pumps or valves.

This review was performed utilizing the acceptance criteria of the Standard Review Plan, Section 3.9.6, and the Draft Regulatory Guide and Value/Impact Statement titled "Identification of Valves for Inclusion in Inservice Testing Programs". The IST Program testing requirements apply only to component testing (i.e., pumps and valves) and are not intended to provide

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

Section 3 of this report presents the Carolina Power and Light Company bases for requesting relief from the Section XI requirements for the Shearon Harris Nuclear Power Plant pump testing program and the EGKG reviewer's evaluations and conclusions regarding these requests. Similar information is presented in Section 4 for the valve testing program.

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

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

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

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2. SCOPE The EG&G Idaho review of the Shearon Harris Nuclear Power Plant, Unit 1, inservice testing (IST) program for pumps and valves was begun in April of 1986. The program initially examined was Revision 1, dated January 27, 1986, which identified the licensee's proposed testing of safety related pumps and valves in the plant systems listed in Appendix B.

To review the licensee's proposed testing of certain pumps and valves in these systems, they were first located and highlighted on the appropriate system P&IDs. After identifying the components and determining their function in the system, the proposed testing was evaluated to determine if it was in compliance with the ASME Code requirements, based on the component type and function. For pumps, it was verified that each of the seven inservice test quantities of Table IWP-3100-1 are measured or observed as appropriate. For those test quantities that are not being measured or observed quarterly in accordance with the Code, it was verified that a request for relief from the Code requirements had been submitted. If the testing was not being performed in accordance with the Code and a relief request had not been submitted, the licensee was requested to explain the inconsistency in the Request for Additional Information (RAI) document that served as the agenda for the working meeting between the licensee, the NRC, and the EG&G reviewers. The relief requests were individually evaluated to determine if the licensee clearly demonstrated that compliance with the Code required testing is impractical for the identified system components, and to determine if their proposed alternate testing provides a reasonable indication of component condition and degradation considering the burden to the licensee if the Code requirement were imposed. Where the licensee's technical basis or alternate testing was insufficient or unclear, the licensee was requested to provide additional information or to clarify the relief request. The system P&ID was also examined to determine whether the instrumentation necessary to make the identified measurements is available.

If, based on the unavailability of adequate instrumentation or the reviewers experience and system knowledge, it was determined that it may not be possible or practical to make the measurements as described by the licensee in his IST program, a question or comment was generated requesting the licensee to clarify his position.

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

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

It was confirmed that all category A and A/C valves are leak rate tested to either the 10 CFR 50, Appendix J, and Section XI IWV-3426 and

-3427 requirements, for those valves that perform a containment isolation function, or to the Section XI, IWV-3421 through -3427, requirements for those valves that perform a pressure boundary isolation function. It was also verified that valves that perform both a containment isolation and a pressure isolation function are leak rate tested to both the Appendix J and the Section XI requirements. Furthermore, if any valve appeared to perform a containment isolation and/or a pressure isolation function but was not categorized A or A/C and being leak rate tested, the licensee was asked to verify that those valves had not been categorized improperly in the IST

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J ll ip Each check valve was evaluated to determine if the licensee's proposed testing verifies the valve's ability to perform its safety related function

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or functions. Extensive system knowledge and experience with other similar facilities were used to determine whether the proposed tests would

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full-stroke the check valve disks open or verify their reverse flow closure capability. If there was any doubt about the adequacy of the identified testing, questions were included in the RAI which required the licensee to address these concerns.

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

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

After all of the valves in the licensee's IST program had been identified on the P&IDs and evaluated as described above, the P8 IDs were examined closely by at least two trained and experienced reviewers to determine if any pumps or valves that may perform a safety related function were not included in the licensee's program. The licensee was asked to reconcile any valves that were identified by this process which had been omitted from the IST program. Also, the list of systems included in the licensee's program was compared to a system list in the Draft Regulatory Guide and Value/Impact Statement titled, "Identification of Valves for Inclusion in Inservice Testing Programs". Systems that appear in the Draft Regulatory Guide list but not in the licensee's program were evaluated and, if appropriate, questions were added to the RAI concerning safety related pumps and valves in those systems.

Additionally, if the reviewers suspected a specific or a general aspect of the licensee's IST program based on their past experiences, questions

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were written for inclusion in the RAI to clarify those areas of doubt. Some questions were included for the purpose of allowing the reviewers to make conclusive statements in this TfR.

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At the completion of the review, the questions and comments generated during the review were transmitted to the licensee. These questions were later used as the agenda for the working meeting with the licensee on August 5 and 6, 1986. At the meeting, each question and comment was discussed in detail and resolved as follows:

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

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

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

d. The item remained open for further investigation by the NRC.

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

On July 31, 1986, the licensee submitted a formal reply to the RAI.

The licensee's responses were read, but time limitations prevented a thorough review prior to the scheduled working meeting on August 5, 1986.

Revision 3 to the licensee's IST program was submitted on September 16, 1986. This program revision was compared to the previous submittal to identify any changes. The changes were evaluated to determine whether they were acceptable and if not, they were added to the items that remained open from the meeting. Several conference calls were held between the licensee, the NRC, and the reviewers to clarify the NRC positions on the open items and discuss the licensee's proposed resolutions.

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A second request for additional information was transmitted by EGM Idaho, Inc., on November 4, 1986, which identified all of the items that remained open after the review of Revision 3 as well as other items that required further clarification by the licensee prior to the preparation of this TER.

Further changes and refinements of the licensee's IST program were transmitted from the licensee to the NRC by letter No. NLS-86-482, dated December 31, 1986. This transmittal was received by the reviewers and the proposed program changes were evaluated to determine their acceptability. A conference call was held between the licensee, the NRC, and the reviewers to discuss the items that were still not satisfactorily resolved in the Shearon Harris Nuclear Power Plant, Unit 1 IST program.

By letter dated December 4, 1987, the licensee transmitted an additional cold shutdown test justification (Reactor Coolant CS-2) for inclusion in their IST program. This provides the justification for exercising the reactor coolant system high point vent valves during cold shutdowns instead of quarterly during power operations and the evaluation is included in Appendix A of this TER.

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

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3. PUMP TESTING PROGRAM The Shearon Harris Nuclear Power Plant, Unit 1, IST program submitted by Carolina Power and Light Company was examined to verify that all pumps that are included in the program are subjected to the periodic tests required by the ASHE Code,Section XI, except for those pumps identified below for which specific relief from testing has been requested and as summarized in Appendix C. Each Carolina Power and Light Company basis for requesting relief from the pump testing requirements and the reviewer's evaluation of that request are summarized below.

~iaaf 3. 1 Various Safet -Related Pum s

3. 1. 1 Pum Bearin Tem erature Measurements 3.t.t.l <<. Th 1i h 0 td 1if f th bearing temperature measurement requirements of Section XI, Paragraph IWP-3100, for the chilled water recirculation, chilled condenser water, safety injection, charging, component cooling water, spent fuel pool cooling, and emergency service water intake screen wash pumps and proposed to measure pump differential pressure, flow, and vibration to determine pump

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performance.

3. l. l. 1. 1 Licensee's Basis for Re uestin Relief--These pumps have no installed instrumentation to measure bearing temperature.

Measurement of temperature of the pump bearing housing would not be indicative of actual bearing temperature because of temperature gradients caused by operation of space coolers, pump location, pumped fluid, etc. The once a year measurement will not provide significant information about pump condition. The long pump running time required to achieve temperature stability could result in unnecessary wear on the pumps and result in increased pump maintenance and repair. Deletion of this measurement will not have significant effect on the pump monitoring program, since other required test parameters are being measured. Pump differential pressure, flow and vibration will be used to monitor pump performance.

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3. 1. 1. 1.2 Evaluation--The licensee has indicated that a yearly measurement of pump bearing temperature for these pumps is not a meaningful test for detecting pump bearing degradation. There are several factors such as the temperature of the working fluid, the ambient temperature, and the lubricant temperature that would affect the measured bearing temperature and mask any bearing condition change short of a catastrophic bearing failure.

The Code required quarterly pump vibration measurements give a much more accurate indication of pump bearing condition than the temperature measurement, and the vibration measurement is not substantially affected by any system parameter or other factor that could mask problems or result in erroneous indications of bearing degradation. A yearly bearing temperature measurement is impractical for these pumps because they do not have temperature sensors installed in the, bearings. The burden on the licensee if the Code requirements were imposed would not be justified by the limited information that would be provided about pump mechanical condition.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed and considering the quarterly pump vibration measurements that will be taken to determine pump

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mechanical condition and to detect pump bearing degradation, relief may be 3 ~ ~ t~

granted from the Section XI requirement of annually measuring bearing temperature for these pumps.

3.2 Auxiliar Feedwater Pum s 3.2. 1 Pum Bearin Tem erature Measurements 3.2.1.1 ~1i f2 <<. Tl 11 3 2 td lfff tt bearing temperature measurement requirements of Section XI, Paragraph IWP-3100, for the auxiliary feedwater pumps and proposed to measure pump differential pressure, flow, and vibration to evaluate pump condition.

3.2. 1. 1. 1 Licensee's Basis for Re uestin Relief--quarterly pump testing is performed using a pump recirculation line back to the pump suction. In this mode of operation the temperature of the pumped fluid is

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constantly increasing and operation is limited to a maximum of one hour.

IWP-3500(b) requires the pumps be operated until bearing temperature stability is achieved, but for no less than thirty minutes. Since the pumped fluid temperature is constantly increasing, bearing temperature will not reach stability in one hour. In addition, good operating procedure will limit operation of the pumps in this mode to as short a time as possible to p} eclude pump degradation. When the pumps are full flow tested at cold shutdown or refueling the length of operation is dictated by plant operating conditions and it cannot be guaranteed that plant condition will allow operation of each pump until bearing temperature stabilizes without significant impact on normal plant operations. Pump differential pressure, flow and vibration measurements will be used to evaluate pump performance.

3.2. I. 1.2 Evaluation--The licensee indicated that a yearly measurement of pump bearing temperature for the auxiliary feedwater pumps is not a meaningful test for detecting pump bearing degradation. The temperature of the pumped fluid would not stabilize sufficiently in the time that the pumps can be operated for testing to provide a measurement that would reflect bearing condition or allow the detection of bearing

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degradation. Bearing temperature measurements are affected by the working

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fluid temperature and ambient temperature to such an extent that these parameters would mask anything but an imminent bearing failure. The burden on the licensee if the Code requirements were imposed would not be justified by the limited information that would be provided about pump mechanical condition.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed and considering the quarterly pump vibration measurements that will be taken to determine pump mechanical condition and to detect pump bearing degradation, relief may be granted from the Section XI requirement of annually measuring bearing temperature for the auxiliary feedwater pumps.

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3.3 Emer enc Service Water Pum s 3.3.

~ ~ 1 Pum Vibration Measurements 3.3.l.l ~RlifR . Th ll h 3 td tiff th vibration measurement requirements of Section XI, Paragraph IWP-3100, for the emergency service water pumps and proposed to measure vibration on the pump motor upper bearing.

3.3. l. 1. 1 Licensee's Basis for Re uestin Relief--The emergency service water pumps are submerged in a pit which makes them inaccessible for measuring vibration amplitude at the pump bearings. These pumps have a shaft which is approximately 70 feet long separating pump and motor.

In their letter dated December 31, 1986, the licensee indicated that vibration measurements would be taken on these pumps. These measurements will be taken at the pump motor upper bearing because this is the accessible location that is most representative of the pump mechanical condition.

3.3. 1. 1.2 Evaluation--The emergency service water pumps are submerged and are inaccessible for direct measurement of vibration at the pump bearings. The pump shaft is enclosed such that the shaft bearings are not accessible for vibration measurements. The only pump element that is accessible for vibration measurements is the driving motor. Vibration measurements taken at the pump motor upper bearing in the radial direction are generally more indicative of the pump bearing and shaft bearing condition than measurements taken elsewhere on the pump motor. It is impractical for the licensee to take pump vibration measurements on these submerged pumps. It would be burdensome to require the licensee to make system modifications to allow them to make these measurements as required by the Code.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed and considering the quarterly pump vibration measurements that will be taken at the pump motor upper bearing in the radial direction to determine pump mechanical condition 12

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and to detect pump bearing degradation, relief may be granted from the Section XI requirement of measuring pump bearing vibration directly at the 4 ~

emergency service water pump bearing housing.

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3.4 Diesel Generator Fuel Oil Transfer Pum s 3.4. 1 Flow Measurement Accurac Re uirements 3.4.1.1 ~tft t. lh 11 h 3 td lift th requirements of Section XI, Paragraphs IWP-3210 and -4110, and proposed to evaluate the diesel generator fuel oil transfer pumps hydraulic condition by calculating the flow rate using the time required to change the day tank level a measured amount which will be used in conjunction with the measured

'pump differential pressure.

3.4. 1. 1. 1 Licensee's Basis for Re uestin Relief--There are no system design provisions for direct flow measurements. Flow rate will be calculated from measured change in day tank level during pump operation.

This method is not accurate enough to comply with the allowable ranges of 4

~t test quantities of Table IWP-3100-2.

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3.4. 1. 1.2 fvaluation--There are no installed instruments on the diesel generator fuel oil transfer system that allow a direct measurement of the flowrate when testing these pumps quarterly. The pump flowrate can be calculated by measuring the change in day tank level or volume and the pump operation time that was required to make that change. This method does yield a value for pump flowrate that can be used to evaluate pump hydraulic condition, however, it does not yield results that meet the instrument accuracy requirements of IWP-4110; also these calculated flowrates are sufficiently inaccurate to make the usage of the allowable ranges of Table IWP-3100-2 impractical. Significant system modifications would be necessary to install flow instrumentation in the diesel fuel oil transfer line in order to directly measure this Code required parameter. It would be burdensome to require the licensee to meet this Code requirement by installing flowrate instrumentation. The proposed testing of calculating flowrate by measuring the change in day tank level over a measured test time 13

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should provide information that when used in conjunction with the pump differential pressure measurement should give an indication of pump condition and allow the detection of pump degradation.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed, and considering that the pump flowrate will be calculated during quarterly pump testing to determine pump hydraulic condition and to detect pump degradation, relief may be granted from the Section XI accuracy and acceptable range requirements for measuring pump flowrate on the diesel fuel oil transfer pumps. The licensee should provide reduced range limits for these pumps as specified in Section XI, Paragraph IWP-3210.

3.4.2 Pum Bearin Tem erature Measurements 3.4.2. 1 Relief Re uest. The licensee has requested relief from the bearing temperature measurement requirements of Section XI, Paragraph IWP-3100, for the diesel fuel oil transfer pumps and proposed to measure pump bearing vibration to evaluate the condition of the pump bearing.

3.4.2. 1. 1 Licensee's Basis for Re uestin Relief--The diesel fuel oil pump running time is dictated by interlock circuitry and administrative limits corresponding to allowable day tank levels. The interlocks, which control automatic transfer pump operation, limit operation of the pumps below minimum allowable or above maximum allowable tank levels. Operation of the pumps with tank levels above maximum allowable is precluded by administrative controls and alarms. The time required to fill the tank from minimum level to maximum level is less than thirty minutes. Bearing condition will be evaluated by pump bearing vibration measurements.

3.4.2. 1.2 Evaluation--In order to obtain any useful information from yearly bearing temperature measurements, a pump must be operated long enough to allow the temperatures to stabilize, otherwise the measured temperature is arbitrary and is not indicative of pump bearing condition.

For this reason the requirements of Section XI, Paragraph IWP-3500(b), must be followed to ensure that the temperature is stabilized to provide 14

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meaningful data to evaluate pump bearing condition. The licensee has indicated that the diesel fuel oil transfer pumps cannot be operated for a

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long enough time due to interlocks, alarms, and administrative limits, to

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allow the bearing temperatures to stabilize. Also, bearing temperature

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measurements are affected by the working fluid temperature and the ambient temperature to such an extent that it would mask any degradation short of an imminent bearing failure. In order to run these pumps long enough to meet the requirements of IWP-3500(b), the licensee would have to override system interlocks and violate administrative controls or make significant system modifications. It is not practical to override system interlocks to measure pump bearing temperature and it would be burdensome to require the licensee to make system modifications to perform this testing. Heasuring the pump vibration quarterly as required by the Code will provide an indication of pump mechanical condition and degradation.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed, and considering the licensee's proposal to measure pump vibration during quarterly pump testing to determine pump mechanical condition and to detect pump degradation, relief may be granted from the Section XI requirement to measure pump bearing temperature yearly for the diesel fuel oil transfer pumps.

3.5 Hi h Head Safet In 'ection Char in Pum s 3.5. 1 Flow measurement Allowable Ran e Limits 3.3.1.1 ~R1i 1' Th 11 h 3 t 3 11 f f th allowable range requirements of Section XI, Paragraph IWP-3210 and Table 3100-2, and proposed to make a study to establish appropriate acceptable ranges based on the installed flow measuring instruments.

3.5. 1. 1. 1 Licensee's Basis for Re uestin Relief--Pump flow rate is determined by summing the measured flow rates from four branch line flow indicators. Because of the combined errors associated with summing four separate measurements, using the table specified ranges could result in 15

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false indications of pump performance. A study is being prepared to establish appropriate acceptable ranges based on the installed flow measuring instruments.

3.5.1.1.2 fvaluation--Section XI, Paragraph IWP-3210 states that if the ranges of Table IWP-3100-2 cannot be met, the owner shall specify in the record of tests the reduced range limits to allow the pump to fulfill its function. If it is shown that summing the outputs of four separate flow indicators results in flow values that routinely exceed the acceptable ranges of Table IWP-3100-2 when the charging pumps are known to be in good operating condition, then the licensee should specify reduced range limits for these pumps as provided for in the Code.

The licensee's proposal to perform a study to determine if the Code supplied ranges of Table IWP-3100-2 can be met and, if they can not, to specify appropriate alternate ranges, is acceptable. Interim relief may be granted from meeting the allowable ranges of Table IWP-3100-2 until the study is complete; at that time relief should not be necessary, for the licensee should be complying with the Code supplied ranges or they should be using appropriate owner supplied ranges to evaluate these pumps. The tt 6 licensee should complete this study and have the owner specified ranges, if appropriate, in place by the end of the first refueling outage.

3.6 Boric Acid Transfer Pum s 3.6. 1 uarterl Flow Neasurement 3.6.1.1 ~1i f << lh 11 h .6 <<6 11 1 f h flow measurement requirements of Section XI, Paragraph IWP-3100, for the boric acid transfer pumps and proposed to determine pump hydraulic condition by quarterly measuring inlet and differential pressures while running the pumps in a recirculation flow path through the minimum flow lines and to measure flow, inlet pressure, and outlet pressure while pumping to the chemical and volume control system when borating on the way to cold shutdown.

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3.6.l.l.l Licensee's Basis for Re uestin Relief--There are no system design provisions for measurement of flow rate in the flow path used for quarterly pump testing. To utilize the system flowmeter would require a test flow path which would transfer highly concentrated boric acid from the boric acid tank to the CVCS. The addition of large amounts of concentrated boric acid during power operations would result in undesirable reactor power transients and possibly in a plant shutdown. The pumps will be run quarterly using the pump minimum flow line and both inlet and differential pressure will be measured.

The licensee indicated in their letter dated December 31, 1986, that a full flow pump test will be performed by establishing flow into the CVCS on the way to cold shutdowns.

3.6. 1. 1.2 Evaluation--The only flow path that currently allows measurement of boric acid transfer pump flowrate is the path that establishes flow to the suction of the charging pumps. This flow path should not be used quarterly during power operations because it results in the addition of high concentrations of boric acid to the RCS which causes power fluctuations and could lead to a plant shutdown. The boric acid transfer pumps are operated in a recirculation flow path during power operations and pump inlet and differential pressures are measured, but there are no flow measurement capabilities in that flow path. Lack of installed instrumentation is not a generally acceptable justification for not performing Code required measurements, however, in this situation where the licensee is measuring pump inlet and differential pressures in a fixed T

resistance recirculation flow path quarterly and measuring those parameters plus pump flowrate when entering cold shutdowns, sufficient information will be available to determine pump hydraulic condition and detect degradation.

I f the flow resistance is known for a flow path, the pump flowrate can be determined from the pump differential pressure. Therefore, if the flow resistance is truly fixed or constant, pump hydraulic condition and degradation can be adequately determined by evaluating changes in the measured pump differential pressure. However, since the constancy of the system flow resistance cannot be readily verified and changes could mask 17

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pump degradation if only differential pressure is measured, it is necessary

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to measure both flowrate and differential pressure in order to monitor pump hydraulic condition. The licensee's proposal to measure both of these

~

parameters on a cold shutdown frequency should provide additional verification that the boric acid transfer pumps are not degraded, thereby making the quarterly measurement of pump inlet and differential pressures in the recirculation flow path acceptable. For these quarterly tests, the pump flowrate will be assumed to be constant, therefore, any differential pressure variations would be attributed to changes in pump condition and appropriate corrective actions will be taken if the measured parameters are outside of the "Acceptable Range" of Table IWP-3100-2. It would be I

burdensome to require the licensee to install the necessary flow measurement instrumentation to allow measurement of pump flowrate quarterly.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed, and considering the licensee's proposal to measure pump inlet and differential pressures during quarterly pump testing and these two parameters in conjunction with pump flowrate on a cold shutdown frequency, relief may be granted from the Section XI requirement to measure pump flowrate quarterly for the boric acid transfer pumps.

3.6.2 Tem erature Measurement and Observation of Lubricant Level l.d.l.l ~R1R t. Th 11 h R td 1 ff th temperature measurement and lubricant level observation requirements of Section XI, Paragraph IWP-3100, for the boric acid transfer pumps and proposed to determine pump mechanical condition by quarterly measuring pump vibration while running the pumps in a recirculation flow path through the minimum flow recirculation lines.

3.6.2. 1. 1 Licensee's Basis for Re uestin Relief--These pumps are Hodel GVHS-IOK made by the Chempump Division of the Crane Company. This type of pump has no bearings in the pump and is an integral unit with the motor. The pump bolts directly onto the integral motor end housing flange, such that the motor bearings are completely .enclosed. The motor bearings 18

4' are cooled and lubricated by diverting a portion of pump flow through the motor and back to the pump suction. Since the motor bearings are cooled and lubricated by the process fluid, the lubricant level cannot be observed and

~

the bearing temperature measurement would not be indicative of the pump

~

mechanical condition.

The licensee indicated in their letter dated December 31, 1986, that vibration measurements will be taken on these pumps to determine their mechanical condition.

3.6.2. 1.2 Evaluation--The licensee indicated that the boric acid transfer pumps are constructed in such a manner that the motor bearings are cooled and lubricated by the process fluid. The bearing lubrication is provided by an internal recirculation of water from the impeller back to the pump suction, therefore, the lubricant level or pressure is a meaningless parameter for these pumps. The motor bearings are inaccessible for temperature measurements and since they are cooled by the process fluid, the temperature would be influenced by the fluid temperature and would not provide an indication of bearing condition unless a catastrophic failure was

~ ~ ~

imminent. A quarterly vibration measurement would provide a much better

~

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indication of pump mechanical condition and degradation than would a yearly

~ ~ ~

measurement of the bearing temperature for these pumps. Significant system modifications would be necessary in order to allow the measurement or observation of these Code parameters.

Based on the impracticality of complying with the Code and the burden on the licensee if the Code requirements were imposed, and considering the licensee's proposal to measure pump vibration during quarterly pump testing, relief may be granted from the Section XI requirement to measure pump bearing temperature and observe pump lubricant level or pressure for the boric acid transfer pumps.

19

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3.7 Emer enc Service Water and Com onent Coolin Water Pum s 3.7. I Establishin

~ ~ Reference Values For Pum Flow or Differential Pressure t.f T.l .~R1if' Th 11 h q td llff th inservice test procedure requirements of Section XI, Paragraph IWP-3100, for the emergency service water and the component cooling water pumps and proposed to measure the Code required parameters with the pumps operating in the as-found condition and to use a pump curve with identified bands to determine if flow and differential pressure are in the acceptable range.

3.7.1. l. I Licensee's Basis for Re uestin Relief--These systems do not have an installed pump test .line and system operating conditions will not allow adjusting system resistance without significant impact on plant operations. These are variable resistance systems that experience a wide swing in loads and configuration. Depending on plant operating conditions and climatic conditions the cooling requirements can range from minimum cooling loads to 100 percent and many of the loads are automatically placed in operation in response to local temperature requirements. Because of these normal operating requirements it is not possible to specify a particular flow path that can be repeated for each pump test.

Pump testing will be performed with the system in the as-found operating configuration and the test results compared with a curve of reference values which establishes the relationship between flow and differential pressure in a band around the design point.

3.7. 1. 1.2 Evaluation--The nature and design of these systems prevent the licensee from varying system resistance to establish a reference pump flowrate or differential pressure. Plant and ambient conditions may vary significantly from one test to another which will affect the heat loads, the heat exchanger efficiencies, and the cooler efficiencies, which in turn affects the flowrates to the various cooled components. With these conditions, it is impractical to establish a reference flow or differential pressure and doing so could result in equipment damage. Using the as found conditions and comparing pump flowrate to differential pressure on the pump 20

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curve should give a good indication of pump hydraulic condition and allow the detection of pump degradation. Significant system modifications would be necessary in order for the licensee to establish a reference pump flowrate or differential pressure for these pumps.

IWP-3100 requires that either the flowrate or differential pressure be adjusted to its reference value and then the other parameter can be measured and compared to its reference value. Flowrate and differential pressure are interrelated parameters and this test methodology allows the determination of pump degradation if the measured parameter deviates from its reference value by more than the amount allowed by Table IWP-3100-2. If the system resistance cannot be varied to establish the reference flowrate or differential pressure, the reference values cannot be used to evaluate the pump condition, however, by using the pump characteristic curve the licensee can make a similar comparison. The licensee's proposal measures both pump flowrate and differential pressure as variables and uses one of the measurements to fix a point on the pump characteristic curve. That point can be used as the reference value of the other parameter and using the allowable ranges from Table IWP-3100-2, the other measurement can be evaluated to determine the pump hydraulic condition. Therefore, the licensee's proposed testing is essentially equivalent to the Code required testing and using it would not diminish the licensee's ability to monitor pump condition and detect hydraulic degradation.

Based on the impracticality of establishing a reference value for flowrate or differential pressure for these pumps and the licensee's proposed testing of comparing the measured values to the pump curves, relief may be granted from the Code requirement of establishing a reference pump flowrate or differential pressure.

3.8 Emer enc Service Water Intake Screen Wash Pum s 3.8. 1 Establishin Reference Values For Pum Flow or Differential Pressure 3.8. 1. 1 Relief Re uest. The licensee has requested relief from the inservice test procedure requirements of Section XI, Paragraph IWP-3100, for 21

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the emergency service water screen wash pumps and proposed to measure the Code required parameters with the pumps operating in the as-found condition and to use a pump curve with identified bands to determine if flow and differential pressure are in the acceptable range.

3.8.1.1.1 Licensee's Basis for Re uestin Relief--These pumps provide flow to back-flush the traveling screens. The pump flowrate is a function of the traveling screen velocity and the amount of screen clogging during pump operations. Under these operating conditions the pump flowrate will vary constantly during pump operation, therefore, it is not possible to establish a repeatable set of pump test conditions.

The licensee indicated in their letter dated December 31, 1986, that they would test these pumps by measuring flowrate, using an ultrasonic flow instrument, and pump differential pressure and compare these values to the pump curve to determine pump hydraulic condition.

3.8. 1. 1.2 Evaluation--The design of this system prevents the

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licensee from varying system resistance to establish a reference pump

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flowrate or differential pressure. Plant conditions may vary significantly

~

from one test to another which will affect the flowrate to the emergency

~

service water intake screens. With these conditions, it is impractical to establish a reference flow or differential pressure and doing so could result in equipment damage. Using the as found conditions and comparing pump flowrate and differential pressure to the pump curve should give a good indication of pump hydraulic condition and allow the detection of pump degradation. Significant system modifications would be necessary in order for the licensee to establish a reference pump flowrate or differential pressure for these pumps.

IWP-3100 requires that either the flowrate or differential pressure be adjusted to its reference value and then the other parameter can be measured and compared to its reference value. Flowrate and differential pressure are interrelated parameters and this test methodology allows the determination of pump degradation if the measured parameter deviates from its reference value by more than the amount allowed by Table IWP-3100-2. If the system 22

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resistance cannot be varied to establish the reference flowrate or differential pressure, the reference values cannot be used to evaluate the pump condition, however, by using the pump characteristic curve the licensee

~

can make a similar comparison. ~ The licensee's proposal measures both pump flowrate and differential pressure as variables and uses one of the measurements to fix a point on the pump characteristic curve. That point can be used as the reference value of the other parameter and using the allowable ranges from Table IMP-3100-2, the other measurement can be evaluated to determine the pump hydraulic condition. Therefore, the licensee's proposed testing is essentially equivalent to the Code required testing and using it would not diminish the licensee's ability to monitor pump condition and detect hydraulic degradation.

8ased on the impracticality of establishing a reference value for flowrate or differential pressure for these pumps and the licensee's proposed testing of comparing the measured values to the pump curves, relief may be granted from the Code requirement of establishing a reference pump flowrate or differential pressure.

23

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4. VALVE TESTING PROGRAM The Shearon Harris Nuclear Power Plant Unit 1 IST Program submitted by Carolina Power and Light Company was examined to verify that all valves included in the program are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. The reviewer found that, except as noted in Appendix C or where specific relief from testing has been requested, these valves are tested to the Code requirements and established NRC positions. Each Carolina Power and Light Company basis for requesting relief from the valve testing requirements and the reviewer's evaluation of that request are summarized below and grouped according to system and valve category.

4. 1 Verif Reverse Flow Closure for Check Valves Inside Containment 4.1.1 Cate or AC Valves 4.1.1.1 Relief Re uest. The licensee has requested relief from the exercising requirements of Section XI, Paragraphs IWV-3411 and -3521, for the following Category AC valves that are located inside containment, and proposed to verify reverse flow closure of these valves by performing a leak test during each refueling outage.

S stem Valve S stem Valve Service Water 1SW-233 Instrument Air 1IA-220 Demineralized Water 1DW-65 Fire Protection 1FP-349 Service Air 1SA-82 Fire Protection 1FP-357 Reactor Coolant 1RC-164 Safety Injection 1SI-182 Chemical and Volume Control 1CS-344 Safety Injection 1SI-290 Chemical and Volume Control 1CS-385 Component Cooling Water 1CC-211 Chemical and Volume Control 1CS-426 Component Cooling Water 1CC-250 Chemical and Volume Control 1CS-471 Component Cooling Water 1CC-298 Chemical and Volume Control 1CS-477 25

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4.1.1.1.1 Licensee's Basis for Re uestin Relief--The only method

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available to verify reverse flow closure is by valve leak testing. These ~

valves will be verified closed during Appendix J, Type C leak rate testing

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at refueling.

4. 1. 1. 1.2 Evaluation--These are simple check valves which are located inside primary containment and are not equipped with position indication. The only method available to verify closure of these valves is to perform a leak test. The test connections to leak test these valves are inside containment and, therefore, it would require a containment entry in order to verify valve closure. Routine containment entry cannot be made quarterly during power operations because of high radiation levels and potentially harsh environment inside containment. Performing this testing during cold shutdowns would subject the plant personnel to increased radiation dosages and other potential hazards, and could result in delaying returning the plant to power. These valves receive an Appendix J, Type C, leak rate test during refueling outages and it would be impractical to require the licensee to make a containment entry quarterly during power operations or during cold shutdowns in order to verify closure of these valves.

Based on the impracticality of complying with the Code requirements, the burden on the licensee if he Code requirements were imposed, and the licensee's proposed alternate testing of verifying valve closure by the performance of leak rate testing during reactor refueling outages, relief may be granted from the exercising interval requirements of Section XI for these valves.

4.2 Main Steam S stem 4.2.1 Cate or B Valves 4.4.t.h ~R1ifR <<. Th 11 h 4 td 1 ff th i~

stroke time measurement requirements of Section XI, Paragraphs IWV-3413 and

-3417,j for 1MS-T,r the auxiliary feedwater turbine steam trip and throttle valve, and 1MS-G,j the auxiliary feedwater turbine governor valve, and 4 ~

26

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proposed to verify operability of these valves

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by observing their operation during the quarterly turbine testing.

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4.2. l. l. 1 Licensee'.s Basis for Re uestin Relief--The purpose of these valves is to regulate steam flow to the AFW steam driven turbine.

Operability is adequately demonstrated by proper turbine oper ation. Valve position is steam line pressure and turbine speed dependent and therefore will not repeatedly throttle to the same position. During turbine operation these valves move in response to control signals.

In their letter dated March 20, 1987, the licensee stated that valve-1HS-T, the turbine trip and throttle valve, will be full-stroke exercised and have its stroke time measured quarterly during power operations. They also provided the additional justification that the governor valve is hydraulically operated, drawing the hydraulic fluid from the AFW pump. The AFW pump must be running for the governor valve to operate. The governor valve controller senses steam line pressure and turbine speed and automatically adjusts over a limited travel range to maintain AFW pump speed

~ ~ ~ ~

constant. Full-stroking of the governor valve (independent of the speed

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control function) while the pump is running can lead to overspeed of the

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pump.

4.2. 1. 1.2 Evaluation--Since the turbine trip and throttle valve, 1MS-T, is being tested to the Code requirements, relief is not required for 1HS-T. The turbine governor valve, 1HS-G, does not have controls that permit it to be cycled from the fully closed to the fully open position, and the turbine must be in operation in order to provide hydraulic pressure to operate this valve. During turbine operation, this valve is designed to modulate to control turbine speed and will change position in response to changes in steam pressure and turbine speed, therefore, any exercising performed would only be a partial-stroke and measurement of a partial-stroke time would not provide any meaningful information to assess valve condition. Forcing this valve fully open when the turbine is running, to provide hydraulic pressure for the valve operator, could cause a turbine overspeed which could, result in damage to the turbine or the pump, therefore, it is not practical to fully open this valve in order to measure 27

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its full-stroke time. Observing the proper operation of this valve during the quarterly pump tests should demonstrate that it can perform its safety related function.

Based on the impracticality of full-stroke exercising the turbine governor valve 1HS-G and considering the licensee's proposal to evaluate proper valve operation during the quarterly pump test, relief may be granted from the stroke time measurement requirements of Section XI for 1HS-G.

Relief is not required for 1HS-T because it is being tested in accordance with the Code. The licensee should delete 1HS-T from the relief request and add the additional justifications for 1HS-G.

4.2.2 Cate or C Valves 4.2.2. 1 Relief Re uest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for 1HS-71 and 73, the main steam to auxiliary feedwater pump turbine check valves, and proposed to partial-stroke exercise these valves quarterly and to

~

disassemble these valves and manually exercise them using a sampling program during refueling outages.

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4.2.2. 1. 1 Licensee's Basis for Re uestin Relief--The only possible method to verify forward flow operability is by running the auxiliary feedwater pump turbine at full flow conditions. The quarterly pump test is performed with flow through a minimum flow line which is not a full flow test. These check valves are also safety-related to prevent cross-flow between the main steam lines when the upstream motor operated valves are open (both motor operated valves open on initiation of auxiliary feedwater). To verify reverse flow closure would require blanking (the turbine stop valve is not a leak tight valve) the turbine line, injecting fluid into the line and monitoring upstream of the valves for evidence of gross leakage. Upstream of these valves are the main steam lines and steam generators. Because of the long time to perform this test and the large volume of waste water involved, it is not a practical test method.

28

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Both valves will be partial flow exercised in, the .forward direction quarterly during auxiliary feedwater pump testing and one of the check valves will be disassembled at refueling and visually inspected. Alternate valves will be inspected at each refueling, unless the inspected valve fails to pass inspection. If either valve fails to pass inspection the other valve will also be disassembled and inspected.

4.2.2. 1.2 Evaluation--These valves cannot be full-stroke exercised with flow quarterly during power operations because establishing design accident steam flow through these valves would require that full auxiliary feedwater flow be established, and the only flow path that could handle the necessary auxiliary feedwater flow is into the steam generators which could result in thermal shock to the feedwater piping and nozzles.

During shutdown periods when thermal shock is not likely to occur, steam is not available to drive the auxiliary feedwater pump turbine. The normal method to verify reverse flow closure of check valves is to perform a leak test on the valves, however, due to the design of this system, leak testing these valves would require the installation of blank flanges and filling a substantial portion of the steam supply header with liquid, which is not

~ ~

considered to be practical. The licensee's proposal to disassemble,

~

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inspect, and manually full-stroke exercise these valves on a sampling basis

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during refueling outages would verify that the valve disks will move freely and that the valves are not degraded.

Compliance with the Code required testing method is impractical due to system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of verifying valve full-stroke capability and reverse flow closure by disassembly, inspection, and manually exercising the valve disks on a sampling basis during reactor refueling outages, relief may be granted from the Code requirements as requested for IHS-71 and 73.

29

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I 4.3 Containment HVAC S stem 4.3.1 Cate or AC Valves t.t.l.l ~R1ifR . Rh 11 h d td ltff th exercising requirements of Section XI, Paragraphs IWV-3400 and -3500, for 1CB-3 and 7, the containment vacuum relief isolation check valves, and ICM-T, the hydrogen purge makeup isolation valve, and proposed to full-stroke exercise these valves open manually during each refueling outage and verify valve closure by visual observation of the valve disks and seats during refueling outages.

d 4.3. 1. 1. 1 Licensee's Basis for Re uestin Relief--These are RR inside containment simple check valves and do not have position verification capability. To verify forward flow operability using system fluid would require injecting large quantities of air into the containment and would result in a containment overpressurization condition. The only practical I

method to verify forward flow operability is by mechanically exercising the

~ ~ ~ ~ ~ d valve disk through a complete cycle by hand and measuring d

I~ the torque

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required to open the valve using a spring scale. Entry into containment

~ ~ ~

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during cold shutdown is limited by plant procedures to perform only

~ ~ ~

necessary repair and maintenance work. In cases of short shutdowns caused by problems external to the containment there may be no entry made into the containment.

Valve forward flow operability will be verified by using a manual exercising procedure at refueling outages. The torque required to open the valves will be measured by a spring scale. Valve reverse flow closure will be verified by visually observing that the valve disk closes against the seat during refueling and by Appendix J, Type C, testing at refueling.

4.3. 1. 1.2 Evaluation--These valves are located inside containment and have no remote position indication. The only methods available to verify valve closure are leak testing and visual observation that the valve disk will properly engage the valve seat. These valves will be visually observed to close and Appendix J, Type C, leak rate tested during reactor refueling outages. To full-stroke exercise these valves open with flow 30

~ ~

would require establishing design accident flowrates into the primary

~ ~

containment which could result in an overpressurization of the containment, therefore, an alternate means should be used to full-stroke exercise these valves. The licensee proposed to manually exercise these valves open during refueling outages. The Code allows for the use of a mechanical exerciser (Paragraph IWV-3522) to exercise a check valve when flow through the valve is not used. A containment entry is required to manually exercise these valves and, therefore, they cannot be exercised quarterly during power operations or during cold shutdowns of short duration when the containment is not opened. These valves should be exercised during cold shutdowns when the containment is opened and during refueling outages.

Compliance with the Code required testing method is impractical due to system design. Compliance with the. Code required testing frequency would be burdensome since this would require quarterly shutdown and containment entry. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of

~

verifying valve full-stroke capability by manually exercising them open utilizing a spring gage to measure torque during cold shutdowns when the containment is opened and during refueling outages and verifying valve

~

closure by visual observation of the valve internals and Appendix J, Type C, leak rate testing during refueling outages, relief may be granted from the Code requirements as requested for valves 1CB-3, 1CB-7 and ICH-7.

4.4 Auxiliar Feedwater S stem 4.4.1 Cate or C Valves 4.4.4.1 ~Ri 4' 4 Th 1 4 h 4 4 14 f f h exercising requirements of Section XI, Paragraph IWV-3520, for 1AF-54, 73, and 92, the check valves in the motor driven auxiliary feedwater supply to the steam generators, and proposed to full-stroke exercise these valves during cold shutdowns and verify their reverse flow closure by using an acoustical detection technique.

31

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4.4. 1. 1. 1 Licensee's Basis for Re uestin Relief--The only way to

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verify forward flow operability is by operating the motor driven auxiliary

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feedwater pumps and injecting relatively cold condensate water directly into

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The introduction of cold water into the hot steam

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the hot steam generators.

generators during normal operation would result in large thermal shock to the feedwater nozzles and could cause cracking of the nozzles. In addition, to test the auxiliary feedwater during normal operation would require starting the auxiliary feedwater pump and securing the normal feedwater system flow, which would have an adverse effect on steam generator water level control and could cause a forced plant shutdown.

Each flow path from the auxiliary feedwater pumps to the feedwater lines includes two check valves in series. Each two check valve set functions to prevent reverse flow from the feedwater line back through to the suction of the auxiliary feedwater pumps. Each line is continuously monitored and alarmed by temperature sensors, which will give an indication if both series valves fail to close.

In their letter dated December 31, 1986, the licensee indicated that these valves will be full-stroke exercised on a cold shutdown frequency as the plant is being taken to the cold shutdown condition. An acoustic detection technique will be used to verify each individual valve in the closed position.

4.4. 1. 1.2 Evaluation--The only flow path to exercise these check valves with flow would result in the injection of relatively cold condensate storage tank water into the feedwater lines and steam generators. If this flow path were used to exercise these valves quarterly during power operations it could result in thermal shock to the feedwater piping and nozzles which could lead to their premature failure. Therefore, valves IAF-54, 73, and 92 should not be exercised quarterly during power operations but should be full-stroke exercised on a cold shutdown frequency.

Significant system modifications would be necessary in order to allow these valves to be tested to the Code requirements.

32

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that at least one of the two valves is closed but does not verify that the

.individual valves can perform their safety function in the closed position

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as required by the Code. An acoustic detection technique was proposed'in order to provide an indication that the individual check valve disks come in contact with the valve seats. This method may indicate metallic contact within the valve but may not provide a positive indication of valve closure. The licensee has not provided the NRC staff with sufficient details about this proposed testing method for the reviewer to make a determination if this acoustic detection can provide a reasonable assurance of valve closure.

Based on the impracticality of complying with the Code requirements, the burden on the licensee if the Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves open with flow at cold shutdowns as the plant is being taken to the cold shutdown condition, relief may be granted from the Code requirement to full-stroke exercise these valves open quarterly during power operations.

~

~

The licensee's proposed test to verify reverse flow closure of iaaf 1AF-54, 73,and 92 has not been described in sufficient detail for a

~ ~ ~ ~

determination to be made if it can provide a reasonable assurance of

~

individual valve closure, therefore, relief should not be granted from the Code requirement to verify closure of these valves. The licensee should test these valves by some method that provides a positive indication of the closure of each individual valve.

4.4.1.2 ~1i f Th li h .q <<d exercising requirements of Section XI, Paragraph IWV-3520, for lAF-65, 84, f h and 103, the check valves that isolate the auxiliary feedwater lines from the main feedwater headers, and proposed to verify reverse flow closure of these valves by performing a sample disassembly program on a refueling outage frequency.

4.4. 1.2. 1 Licensee's Basis for Re uestin Relief--The system has no design provision for verification of reverse flow closure. The only possible test method involves pressurizing the downstream section of pipe 33

0) L I'\l g" J Yi

and monitoring an upstream tap for evidence of gross leakage., This method j .

involves filling and draining large segments of the system. Because of the time involved, ALARA considerations and large amounts of wastes, it is not practical to perform testing except at refueling. The only alternative testing is to disassemble and visually inspect each valve.

4.4. 1.2.2 Evaluation--These valves are in the auxiliary lines from the main feedwater header to the steam generators. During normal power operations, a portion of the main feedwater flow to the steam generators passes through these lines. Verification of reverse flow closure for these valves can only be accomplished by leak testing or disassembly. The system design does not permit performing either of these tests during power

'perations because it would require isolation of the normal feedwater flow through this line which could result in steam generator level fluctuations and possibly in a reactor trip. Leak testing these valves during cold shutdowns is not practical because there are no isolation valves between 1AF-65, 84, and 103 and the associated steam generators and no test connections are available between these valves and the upstream isolation

~

valves, therefore, to leak test these check valves it would require depressurizing and draining portions of the main feedwater header and

~

pressurizing the steam generators and portions of the main steam headers.

The NRC staff position is that valve disassembly and inspection is an acceptable alternate method to verify valve closure and the appropriate frequency for this testing is during reactor refueling outages.

Compliance with the Code required testing method is impractical due to the system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of verifying valve reverse flow closure by disassembly, inspection, and manually exercising the valve disks on a sampling basis during reactor refueling outages, relief may be granted from the Code requirements as requested for valves 1AF-65, 84, and 103.

34

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exercising requirements of Section XI, Paragraphs IWV-3520, for lAF-117,

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136,t 142 and 148,r check valves in the turbine driven auxiliary feedwater supply to the steam generators, and proposed to full-stroke exercise these valves during cold shutdowns and verify their reverse flow closure by use of an acoustic detection technique.

4.4. 1.3. 1 Licensee's Basis for Re uestin Relief--The only way to verify forward flow operability is by operating the motor driven auxiliary feedwater pumps and injecting relatively cold condensate water directly into the hot steam generators. The introduction of cold water into the hot steam generators during normal operation would result in large thermal shock to the feedwater nozzles and could cause cracking of the nozzles. In addition, to test the auxiliary feedwater during normal operation would require starting the auxiliary feedwater pumps and securing the normal feedwater system flow, which would have an adverse effect on steam generator water level control and could cause a forced plant shutdown.

Each flow path from the turbine driven auxiliary feedwater pump to the feedwater lines includes two check valves in series. Each two check valve set functions to prevent reverse flow from the feedwater line back to the auxiliary feedwater pump. The common line is continuously monitored and alarmed by temperature sensors which will give an indication if both series valves fail to close.

In their letter to the NRC dated December 31, 1986, the licensee stated that these valves will be full-stroke exercised on a cold shutdown frequency. An acoustic detection technique will be used to verify each individual valve in the closed position.

4.4. 1.3.2 Evaluation--The only flow path to exercise these check valves with flow would result in the injection of relatively cold condensate storage tank water into the feedwater lines and steam generators. If this flow path were used to exercise these valves quarterly during power operations it could result in thermal shocking the feedwater piping and nozzles which could lead to their premature failure. Therefore, valves 35

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1AF-117, 136, 142 and 148 should not be exercised quarterly during power operations but should be full-stroke exercised on a cold shutdown

.frequency. Leak testing two series check valves as a pair can only

~

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demonstrate that at least one of the two valves is closed but does not verify that the individual valves can perform their safety function in the closed position as required by the Code. An acoustic detection technique was proposed in order to provide an indication that the individual check valve disks come in contact with the valve seats. This method may indicate metallic contact within the valve but may not provide a positive indication of valve closure. The licensee has not provided the NRC staff with sufficient details about this proposed testing method for the reviewer to make a determination if acoustic detection can provide reasonable assurance of valve closure.

Based on the impracticality of exercising these valves open quarterly during power operations, the licensee's proposed alternate testing of exercising these valves open during cold shutdowns is acceptable as permitted in Section XI, IWV-3522. The licensee's proposed test to verify o reverse flow closure of 1AF-117, 136, 142 and 148 has not been described in sufficient. detail for a determination to be made that it can provide reasonable assurance of individual valve closure, therefore, relief should not be granted from the Code requirement to verify closure of these valves.

The licensee should test these valves by some method that provides a positive indication of the closure of each individual valve.

4.5 Condensate S stem 4.5.1 Cate or Valves 1'.

C R.l.l.l ~Rli lh 11 h 4 t 4 11 4 f th exercising requirements of Section XI, Paragraph IWV-3520, for 1CE-36, 46, and 56, the check valves in the lines from the condensate storage tank to the auxiliary feedwater pump suctions, and proposed to partial-stroke exercise these valves open quarterly, full-stroke exercise them open on a cold shutdown frequency, and to verify reverse flow closure of these valves by disassembling and inspecting them on a sampling basis during refueling

~ ~ ~

outages. ~

36

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Licensee's Basis for Re uestin Relief--These valves

~ ~ ~

4.5.1.1.1

~ ~ ~ ~

are in the line from the condensate storage tank to the auxiliary feedwater

~ ~

,,pump, inlet and are upstream from the cross-tie with the service water

~ ~ ~

In this location the valves prevent back-flow from the service

~

system.

water system into the condensate storage tank. The only possible method to verify reverse flow closure would be by monitoring for an increase in tank level. This technique is not possible in this case because of the volume of the tank and the normal level changes which occur during normal operation.

The only way to verify full forward operability is by operating the auxiliary feedwater pumps and injecting relatively cold condensate water directly into the hot steam generators. The introduction of cold water into the steam generators during normal operation would result in large thermal shock to the feedwater nozzles and could cause cracking of the nozzles. In addition, to test the auxiliary feedwater during normal operation would require starting the auxiliary feedwater pumps and securing the normal feedwater system flow, which would have an adverse effect on steam generator water level control and could cause a forced plant shutdown. These valves will be partial-stroke exercised during quarterly pump testing with flow through the small pump recirculation lines and back to the condensate storage tank. These valves will be full-stroke exercised on a cold shutdown frequency, either when going into cold shutdown or during the shutdown when the steam generator water level has been reduced sufficiently to allow full flow.

One valve will be disassembled and visually inspected at refueling and alternate valves will be done during subsequent refuelings. Only one valve will be inspected at a refueling unless it fails to pass inspection.

Failure to pass inspection will initiate disassembly and inspection of the other two valves.

4.5. 1. 1.2 Evaluation--The only full flow path through these valves is from the condensate storage tank into the feedwater headers and steam generators. Injecting this relatively cold condensate storage tank water into the feed header and steam generators quarterly during power operations could thermal shock the feedwater piping and nozzles and cause premature failure of these components. These valves can be partial-stroke 37

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exercised quarterly and full-stroke exercised open on a cold shutdown frequency. A valve disassembly and inspection can verify that the valve

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.disks will move to the valve seats,and that the valve internal's are in good

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condition.

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It is the NRC staff position that in order to group valves together in a sample disassembly and inspection program that the valves be of the same manufacturer, size, model, materials of construction, and have the same service conditions. Valves 1CE-36, 46, and 56 meet these criteria except for valve size with 1CE-36 and 46 being 6 inch valves and 1CE-56 being an 8 inch valve. Since all other factors are identical for these valves, the reviewer feels that even with the size disparity, these valves should be allowed to be grouped together because any failure mechanisms should be common for all three valves.

Revision 3 of the licensee's IST program, dated September 16, 1986, indicates that 1CE-56, the suction check valve for the turbine driven auxiliary feedwater pump, cannot be full-stroke exercised during cold shutdowns, however, the licensee stated in their letter dated Harch 20, 1987, that 1CE-56 will be full-stroke exercised on the way to cold shutdowns when the turbine driven auxiliary feedwater pump is being tested.

~ ~ ~

The licensee should modify the appropriate relief request to more accurately indicate the testing to be performed on this valve.

Compliance with the Code required valve exercising at power is impractical due to the system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of partial-stroke exercising valves 1CE-36, 46, and 56 during the quarterly pump test and full-stroke exercising them on a cold shutdown frequency and verifying valve closure by disassembly, inspection, and manually, exercising the valve disks on a sampling basis during reactor refueling outages, relief may be granted from the Code requirements as requested.

38

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4.6 Containment S ra S stem 4.6.1

~ ~ Cate or AC Valves h.d.l.l. ~R1i 1' . Th 11 h R t d 11 f f th exercising requirements of Section XI, Paragraphs IWV-3410 and -3520, for 1CT-53 and 91, the containment spray header check valves inside containment, and proposed to verify the open function of these valves by disassembling, inspecting, and manually exercising the valve disks during refueling outages on a sampling basis and verifying valve closure by leak rate testing in conjunction with the Appendix J, Type C testing at refueling outages.

4.6. 1. l. 1 Licensee's Basis for Re uestin Relief--Since there is no test recirculation line the only way to verify forward flow operability would be by using the pumps and injecting a large quantity of water into the containment. Spraying the containment would result in extensive damage to safety-related equipment located inside containment. Using air as a test I

medium is not practical since large segments of the system would have to be

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~d drained and high pressure air pumped into the system through a small test I

connection. The amount of air that could be injected using this method

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would be insufficient to verify full stroke opening and could result in an

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overpressurization of the containment structure. The only method available to verify reverse flow closure is by valve leak testing during Appendix J, Type C, testing at refueling.

One of the valves will be disassembled and visually inspected at refueling. Valve inspections will alternate with subsequent refuelings.

failure to pass inspection will initiate disassembly and inspection of the other valve. Reverse flow closure will be verified during Appendix J, Type C, valve leak testing at refueling.

4.6. 1. 1.2 Evaluation--Due to the system design, the only method available to exercise these containment spray header check valves with flow would establish spray flow into the containment which could result in damage to both safety-related and non-safety-related equipment inside containment and require extensive cleanup. Valve disassembly, inspection, and manual 39

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full-stroke exercising to verify freedom of movement. of .the valve disk is an acceptable alternate testing method and is the only method currently available to the licensee to verify the forward flow ability of these valves. The reverse flow closure of these valves can be verified by leak testing, which will be performed in conjunction with Appendix J, Type C, leak rate testing at refueling outages.

Compliance with the Code required testing method is impractical due to the system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of verifying valve forward flow operability by disassembly, inspection, and manually exercising the valve disks on a sampling basis during reactor refueling outages and verifying their reverse flow closure by conducting the Appendix J, Type C, leak rate test at refueling outages, relief may be granted from the Code requirements as requested for valves 1CT-53 and 91.

4.7 Instrument Air S stem 4.7.1 Cate or C Valves q.i.l.l ~RlifR <<. Rh ii h q <<d if if hh exercising requirements of Section XI, Paragraph IWV-3520, for lIA-784, 785, 786, 787, 788, and 789, the instrument air supply check valves to the accumulators for the air operated valves inside containment, and proposed to verify valve closure by disassembly and inspection of one of the upstream and one of the downstream check valves during each refueling outage.

4.7. 1. 1. 1 Licensee's Basis for Re uestin Relief--Each fill line to the accumulators contains two simple check valves in series and there are no system provisions for individual valve closure verification. Only one automatic actuating valve is required to isolate the non-classed instrument air system from the accumulators. The two valves function as a single unit I

40

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and if either

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of them close proper operation of the accumulators is assured. To verify reverse flow closure of the unit requires isolating and y ~

depressurization of a large segment of the Instrument Air System for an

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extended length of time. Loss of instrument air during operation would cause loss of instrumentation needed for normal operations. "Because of the time required to perform testing, performing verification at cold shutdown could cause delays in returning the plant to normal operations. These valves will be tested to verify reverse flow closure at refueling when the instrument air system can be taken out of service.

4.7. 1. 1.2 Evaluation-- Isolating instrument air to verify valve reverse flow closure during plant operation is not practical because this would cause a loss of instrument air to plant equipment that is required for normal plant operations, which could lead to a plant trip. The current system configuration does not provide a means to individually verify the reverse flow closure capability of these series check valves. Although the licensee proposed to test each pair of series valves together as a single check valve in Revision 1 of their IST program, when informed that each

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valve must be individually verified to close, the licensee proposed to

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verify the reverse flow closure capability of these valves by using a sample

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disassembly and inspection program with the upstream valves forming one

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group and the downstream valves forming a second group. This proposal was made in the A. B. Cutter to H. R. Denton letter dated December 31, 1986, but the staff has not received a revised relief request for these valves.

Disassembly and inspection of these valves would provide an indication that the valve disk moves freely to the seat and that the valve internals are free from wear and corrosion and are in good mechanical condition, therefore, this testing method would provide a reasonable assurance of the reverse flow closure capability of these check valves. The licensee has proposed to disassemble these valves in accordance with the NRC staff's positions and guidelines for sample disassembly and inspection of check valves.

Compliance with the Code required testing method is impractical due to the system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown 41

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the impracticality of complying with the

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and valve disassembly. ~ Based on Code required testing method, the burden to the licensee of complying with

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.the Code required testing frequency, and the licensee's proposed alternate

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testing of disassembly, inspection, and manually exercising the valve disks

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on a sampling basis during reactor refueling outages, relief may be granted from the Code requirements as requested for valves lIA-784, 785, 786, 787, 788, and 789.

4.8 Chemical and Volume Control S stem 4.8.1 Cate or A Valves 4.8. 1. 1 Relief Re uest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3410, for 1CS-341, 382, 423, 470 and 472, the reactor coolant pump seal water flow containment isolation valves, and proposed to exercise and measure the full-stroke time at cold shutdowns when the reactor coolant system is open to the atmosphere and during refueling outages.

4.8. 1. 1. 1 Licensee's Basis for Re uestin Relief--Exercising these valves during normal operation or at cold shutdown results in a loss of normal seal water to the RCS Pump Seals. If seal water is terminated, Reactor Coolant is forced from the high pressure RCS into the seals.

Reactor Coolant normally contains a high particulate matter concentration which is carried with RCS inleakage and contaminates the seals.

Westinghouse has studied this problem (see Westinghouse Document NSD TB-7515, 1978) and recommends that seal flow be maintained at cold shutdown as well as during normal operations.

These valves will be exercised and timed during those cold shutdowns when the reactor coolant system is open, vented, and drained to the top of the vessel flange and at refueling when the RCS pressure is low enough to minimize particulate intrusion into the seals.

42

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4.8.1.1.2 Evaluation--Exercising these normally open valves closed would interrupt seal water flow to the reactor coolant pump seals.

Loss of seal water flow during power operations could result in damage to the reactor coolant pump seals and possible seal failure. A failed reactor coolant pump seal could result in unisolable leakage of reactor coolant from the reactor coolant system. Exercising these valves during cold shutdowns would secure reactor coolant pump seal flow and if the reactor coolant system were pressurized, the higher pressure in the reactor coolant system could cause flow across the pump seals which could introduce particulate suspended in the coolant into the pump seals which could accelerate seal wear and result in premature seal failure. Testing these valves during refueling outages and those cold shutdowns when the reactor coolant system is vented or opened to the atmosphere would not result in damage to the pump seals since there would be insufficient differential pressure across the seals to result in the flow of suspended particulate into the seals.

Based on the impracticality of exercising these valves quarterly or during cold shutdowns when the reactor coolant system is not vented to the atmosphere, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves during each reactor refueling outage and those cold shutdowns when the reactor coolant system is vented or open to the atmosphere, relief may be granted from the Section XI requirements as requested for valves 1CS-341, 382, 423, 470, and 472.

4.8.2 Cate or C Valves 4.8.2. 1 Relief Re uest. The licensee has requested relief from the exercising requirements of Section XI, Paragraph IWV-3520, for 1CS-178, 192, and 206, the charging pump discharge line check valves, and proposed to partial-stroke exercise these valves quarterly and full-stroke exercise them open during each refueling outage.

4.8.2. 1. 1 Licensee's Basis for Re uestin Relief--These charging pump discharge check valves cannot be verified for full flow operability quarterly. Normal operating charging flow is automatically controlled by

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flow control valve (1CS-231) in response to RCS operating

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downstream conditions. To inject full flow into the RCS during normal operation would

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,result in undesirable RCS boron concentrations and system pressure,

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temperature and level transients.

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Full-stroke exercising these valves at

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cold shutdown would result 'in RCS pressure and level transients due to limitations on letdown capability. These valves will be partial-stroke exercised quarterly and verification of full forward flow operability performed at refueling.

4.8.2. 1.2 Evaluation--The only full flow path through these valves is into the RCS through the injection headers since design accident flow cannot be established through the normal charging line. Establishing design accident flow through these valves quarterly during power operations would inject relatively cold water that may have a high concentration of boric acid into the RCS. Pumping this water into the RCS during power operations could thermal shock the system piping and nozzles which could result in premature component failure due to metal or weld fatigue induced by thermal cycling. Injecting into the RCS could also cause reactivity and

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pressurizer level transients which could lead to a plant trip. Therefore,

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these valves cannot be full-stroke exercised quarterly during power operations unless extensive system modifications, such as installing full

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flow test loops, are made to permit this testing. It would be burdensome for the licensee to make such modifications because of the cost involved.

Additionally, reduced system reliability could result from failures that could divert injection flow away from the RCS.

During cold shutdowns there is inadequate expansion volume to establish full centrifugal charging pump flow into the RCS through these valves without possibly resulting in a low-temperature overpressurization of the RCS. Because of this concern and administrative controls to prevent its occurrence, it is impractical to full-stroke exercise valves ICS-178, 192, and 206 during cold shutdowns. The only time that there would be a sufficient expansion volume to establish design accident flow through these valves is during refueling outages when the reactor vessel head is removed.

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Based on the impracticality of full-stroke exercising these valves quarterly or during cold shutdowns, the burden on the licensee if these Code

.requirements were imposed, and the licensee's proposed alternate testing of partial-stroke exercising quarterly and full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested for valves 1CS-178, 192, and 206.

4.9 Safet In 'ection S stem 4.9.1 Cate or A Valves t.f.l.l ~RiifR <<. Th ll h d td tiff th exercising requirements of Section XI, Paragraph IWV-3410, for 1SI-52, 86, and 107, the isolation valves in the safety injection lines to the reactor coolant system hot legs, and proposed to full-stroke exercise and measure the stroke times for these valves during refueling outages.

4.9. 1. 1. 1 Licensee's Basis for Re uestin Relief--Exercising these valves during normal operation would result in injecting charging water flow directly into the RCS. This diverted charging water bypasses the regenerative heat exchanger which could cause thermal shocking to RCS piping and could also cause an overtemperature condition in the normal CVCS letdown line. At cold shutdown one charging pump is running (Technical Specification 3.5.3 states that a maximum of one charging pump shall be operating when RCS temperature is less than or equal to 335 F). This pump is supplying both reactor coolant pump seals and required charging water.

Seal water flow is maintained during cold shutdown to preclude damage to the pump seals, thus if these valves were exercised at cold shutdown charging water would be injected into the RCS and a cold overpressurization of the RCS could result. These valves will be exercised and timed at refueling outages.

4.9. 1. 1.2 Evaluation--Exercising these valves open during power operations would result in flow through the injection flow paths into the RCS hot legs. Injecting this relatively cold water into the RCS hot legs would thermal shock the piping and nozzles which could result in premature

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due to thermally induced fatigue of the metal and welds.

Opening these valves would also increase the charging flow into the RCS and could cause temperature, pressure, and pressurizer level control disturbances which could result in a reactor trip. These valves should not

~ ~

be exercised during cold shutdowns when a charging pump is running and the RCS is not vented or open to atmosphere, because this would result in an increased flow into the RCS when there is not an adequate expansion volume which this increased flow could cause a low-temperature overpressurization of the RCS. A charging pump is maintained in operation during most cold shutdowns to provide makeup flow and flow to the reactor coolant pump seals. The RCS is very seldom vented or open to the atmosphere during cold shutdowns, therefore, there would be very few cold shutdowns when conditions would allow exercising these valves.

Based on the impracticality of exercising these valves quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of exercising and measuring stroke times of these valves during reactor refueling outages,

~

relief may be granted from the Section XI requirements as requested for valves 1ST-52, 86, and 107. ~

4.9.2 Cate or AC Valves R.l.l.l ~RiifR <<. Th 11 h 4 4 11 1f h exercising requirements of Section XI, Paragraph IWV-3520, for 1SI-249, 250, 251, 252, 253, and 254, the accumulator discharge check valves, and proposed to partial-stroke exercise these valves at cold shutdowns and to disassemble, inspect, and manually exercise the valves during refueling outages on a sampling basis.

4.9.2.1.1 Licensee's Basis for Re uestin Relief--The accumulator tanks are isolated from the RCS by these normally closed check valves. Each accumulator is charged with a nitrogen blanket at approximately 650 psig, which is insufficient to inject into the RCS during normal operation. To exercise these valves to their full open position at cold shutdown would inject approximately 925 cubic feet of high boron content water into the 46

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RCS, which could cause a cold overpressurization of the RCS. Dumping the full accumulator inventory into the RCS at refueling could flush large amounts of crud into the RCS and cleanup systems. High particulates in the RCS at refueling reduces visibility for refueling operations and generates large amounts of contaminated wastes, which could lengthen the outage and increase personnel exposures.

Partial forward flow operability will be verified at cold shutdown by performing an accumulator partial dump test. In addition one valve will be disassembled and visually inspected at refueling. Valve inspections will alternate with subsequent refuelings. Failure of a valve to pass inspection will either initiate inspection of the remaining valves or initiate verification of the remaining valves by accumulator injection into the RCS.

4.9.2. 1.2 Evaluation--The only flow path through these accumulator discharge check valves is into the reactor coolant system and flow cannot be established into the reactor coolant system quarterly during power operations because accumulator pressure cannot overcome reactor coolant system pressure. Therefore, these valves cannot be full or

~

partial-stroke exercised quarterly during power operations unless extensive system modifications, such as installing full flow test loops, are made to

~ ~

permit this testing. It would be burdensome for the licensee to make such modifications because of the cost involved. Additionally, reduced system reliability could result from failures that could divert the injection flow away from the RCS.

Establishing design accident flow through these valves during cold shutdowns could result in a low-temperature overpressurization of the reactor coolant system because there is insufficient expansion volume to accommodate this flow. Full-stroke exercising these valves with flow during refueling outages when the reactor vessel head is removed to provide an adequate expansion volume could damage reactor vessel internal components and stir up crud and particulates in the reactor vessel due to excessive flow rates. These valves are partial-stroke exercised during cold shutdowns by performing a partial accumulator dump test at reduced pressures.

Disassembling, inspecting, and manually full-stroke exercising the valves on 47

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a sampling basis during refueling outages would verify that the valve disks will move freely and that the valve internals are not degraded.

Compliance with the Code required valve exercising at power is impractical due to the system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of partial-stroke exercising 1SI-249, 250, 251, 252, 253, and 254 open during.,cold shutdowns and verifying valve full-stroke capability by disassembly, inspection, and manually exercising the valve disks during reactor refueling outages, relief may be granted from the Code requirements as requested.

4.9.3 Cate or C Valves 4.9..t

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h check valves in the safety injection lines to the reactor coolant system and

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proposed to full-stroke exercise these valves during refueling outages when the reactor vessel head is removed to provide an adequate expansion volume for the required flow.

1SI-8 1SI-72 1SI-104 1SI-127 1SI-138 1SI-9 1SI-73 1SI-105 1SI-128 1SI-10 1SI-74 ISI-I06 1SI-129 4.9.3.1.1 Licensee's Basis for Re uestin Relief--Verification of forward flow operability can only be performed by injecting charging water into the RCS. The charging pumps have insufficient head to overcome normal RCS operating pressure for a full flow test. Partial testing using the charging pumps would inject CVCS water which has bypassed the regenerative heat exchanger and could result in thermal shocking to the RCS piping.

Forward flow verification at cold shutdown could result in a cold overpressurization of the RCS. These valves will be tested by verifying

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forward flow operability at refueling when the reactor vessel head is removed and full charging pump flow can be injected into the RCS.

4.9;3. 1.2 Evaluation--Design accident injection flowrate cannot be established through these valves quarterly when the reactor coolant system is at normal operating pressures, because the only full flow path is into the reactor coolant system and the normal operating pressure would prevent the flowrates that can be achieved when the RCS is depressurized as it would be in the case of a large break LOCA. Therefore, these valves cannot be full-stroke exercised quarterly during power operations. Partial-stroke exercising these valves during power operations would inject relatively cold water into the RCS which could thermal shock the injection piping and nozzles and cause premature failure of these system components. Also, establishing injection flow into the RCS could cause reactivity, temperature, pressure, and pressurizer level control transients which could result in a reactor trip.

These valves should not be exercised during cold shutdowns when the RCS is not vented or open to the atmosphere because injecting into the RCS when there is not an adequate expansion volume could result in low-temperature

~

overpressurization of the RCS. These valves can be full-stroke exercised

~

during refueling outages when the reactor vessel head has been removed.

Based on the impracticality of full or partial-stroke exercising these valves 'quarterly or during cold shutdowns, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of full-stroke exercising these valves during reactor refueling outages, relief may be granted from the Section XI requirements as requested.

4. 10 Com onent Coolin Water S stem 4.10.1 Cate or A Valves tl.ll ~1i f4

~ ~ <<. Th lt h 4 td lfff exercising requirements of Section XI, Paragraph IWV-3410, for ICC-208, 249,

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251, 297, and 299, the containment isolation valves for the component cooling water supply and return for the reactor coolant pumps, and proposed to exercise these valves during those cold shutdowns when the RCS drops below 200 F and all reactor coolant pumps are stopped and during refueling outages.

4. 10. l. 1. 1 Licensee's Basis for Re uestin Relief--These are the containment isolation and block valves in the RCP thermal barrier and bearing oil coolers lines. A loss of cooling water for more than a few minutes could result in extensive damage to the reactor coolant pumps.

Westinghouse Document 1B5710-100-07A states that cooling water must be provided to the pumps at all times when the RCS temperature is above 200 F. Because of local temperature variations in the RCS at RCS temperatures near 200 F, at least one RCP may be kept in operation during short duration cold shutdowns where the RCS temperature is maintained near 200 F. It is felt that under these conditions stopping cooling water to the operating pump could contribute to pump degradation and require pump repair.

4. 10. 1. 1.2 Evaluation--Exercising these valves would isolate cooling water flow to the reactor coolant pumps which could damage the pumps if they are operating, thereby, causing their premature failure. Pump failure during power operations would result in a plant trip, therefore, it is not practical to exercise these valves quarterly during power operations. During shorter cold shutdowns, the RCS temperatures may remain above 200 F and system conditions may not permit securing all of the reactor coolant pumps. Exercising these valves during cold shutdowns when the RCS temperature is >200 F or when one or more reactor coolant pump is operating could damage the pumps which are major plant equipment that are required for plant operation even though they are not safety-related.

Therefore, it is not practical to exercise these valves during those cold shutdowns when the RCS temperature remains above 200 F and one or more reactor coolant pump remains in operation. These valves will be exercised during each refueling outage and during those cold shutdowns when the RCS temperature is <200 F and all reactor coolant pumps are secured.

50

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s horter cold shutdowns, the RCS temperatures may remain above 200 F and system conditions may not permit securing all of the reactor coolant pumps.

Exercising this valve during cold shutdowns when the RCS temperature is

>200 F or when one or more reactor coolant pump is operating could damage the pumps which are major plant equipment that are required for plant operation even though they are not safety-related. Therefore, it is not practical to exercise this valve during those cold shutdowns when the RCS temperature remains above 200 F and one or more reactor coolant pump remains in operation. This valve will be exercised during each refueling outage and during those cold shutdowns when the RCS temperature is <200 F and all reactor coolant pumps are secured.

Based on the impracticality of exercising this valve quarterly or during cold shutdowns when the RCS temperature is >200 F or when one or more reactor coolant pump is operating, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of exercising and measuring stroke times of this valve during reactor refueling outages and during those cold shutdowns when the RCS temperature is <200 F and conditions allow all reactor coolant pumps to be stopped, relief may be granted from the Section XI requirements as requested for valve 1CC-207.

4. 10.3 Cate or C Valves 4.14.t.h ~Ri1 f <<. Th 11 h 4 t 4 11 f f th exercising requirements of Section XI, Paragraph IWV-3520, for 1CC-216, 227, and 238, the component cooling water to reactor coolant pump check valves, and proposed to disassemble and inspect these valves on a sampling basis during refueling outages.

4. 10.3. 1. 1 Licensee's Basis for Re uestin Relief--The Westinghouse RCS pumps must have cooling water to the bearing oil coolers and thermal barriers at all times when the RCS temperature is above 200 F, and there are no installed taps or position indicators that could be used to verify reverse flow closure. Any possible test involves verification of these and associated upstream non-safety-related check valves as a single unit. To verify reverse flow closure at cold shutdown would involve 52

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Based on the impracticality of exercising these valves quarterly or during cold shutdowns when the RCS temperature is >200 F or when one or more reactor coolant pump is operating, the burden on the licensee if these Code requirements were imposed, and the licensee's proposed alternate testing of exercising and measuring stroke times of these valves during reactor refueling outages and during those cold shutdowns when the RCS temperature is <200 F and conditions allow all reactor coolant pumps to be stopped, relief may be granted from the Section XI requirements as requested for valves ICC-208, 249, 251, 297, and 299.

4. 10.2 Cate or B Valves 4.10.2.1 ~III'fR << Th ii I q td lifF tl exercising requirements of Section XI, Paragraph IWV-3410, for 1CC-207, an isolation valve in the component cooling water supply to the reactor coolant pumps, and proposed to exercise this valve during those cold shutdowns when the RCS temperature drops below 200 F and all reactor coolant pumps are stopped and during refueling outages.

4. 10.2. 1. 1 Licensee's Basis for Re uestin Relief--This is a block valve in the RCP thermal barrier and bearing oil coolers supply line. A loss of cooling water for more than a few minutes could result in extensive damage to the reactor coolant pumps. Westinghouse Document 1B5710-100-07A states that cooling water must be provided to the pumps at all times when the RCS temperature is above 200 F. Because of local temperature variations in the RCS at RCS temperatures near 200 F, at least one RCP may be kept in operation during short duration cold shutdowns where the RCS temperature is maintained near 200 F. It is felt that under these conditions stopping cooling water to the operating pump could contribute to pump degradation and require pump repairs.

4. 10.2. 1.2 Evaluation--Exercising this valve would isolate cooling water flow to the reactor coolant pumps which could damage the pumps if they are operating, thereby, causing their premature failure. Pump failure

. during power operations would result in a plant trip, therefore, it is not practical to exercise this valve quarterly during power operations. During 51

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draining large segments of the system and providing an alternate source of

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pressurized water inside the containment which may not be accessible during

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cold, shutdowns. Also, this test would involve waste processing of the water

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removed for testing and of the water used for testing. This type of testing

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would involve an excessive amount of time and personnel and could cause delays in plant startup.

One valve will- be disassembled and visually inspected at refueling and alternate valves will be done during subsequent refuelings. Only one valve will be inspected at a refueling unless it fails to pass inspection.

Failure to pass inspection will initiate disassembly and inspection of the other two valves.

4. 10.3. 1.2 Evaluation--Securing cooling flow to the reactor coolant pump bearing oil coolers and thermal barriers during power operations or anytime the RCS temperature is above 200 F could result in damage to the reactor coolant pumps and cause premature failure. Due to system design, there is no practical method of verifying closure of these valves during cold shutdowns. The draining and refilling of portions of the system to test these valves during cold shutdowns could delay plant startup. Disassembling, inspecting, and manually assuring that the valve disk will move freely to the valve seat can show that a valve can perform its safety function and that it is not degraded. The licensee proposes to disassemble and inspect these valves on a sampling basis during refueling outages.

Compliance with the Code required valve exercising at power is impractical due to the system design. Compliance with the Code required testing frequency would be burdensome since this would require quarterly shutdown and valve disassembly. Based on the impracticality of complying with the Code required testing method, the burden to the licensee of complying with the Code required testing frequency, and the licensee's proposed alternate testing of disassembly, inspection, and manually exercising the valve disks during reactor refueling outages, relief. may be granted from the Code requirements as requested for valves 1CC-216, 227, and 238.

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Relief uest. The licensee has requested relief from the

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4. 10.3.2~ Re ~

exercising requirements of Section XI, Paragraph IWV-3520, for 1CC-118 and

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,1,19, series check valves in the sample return line to the component cooling water system, and proposed to make a system modification that will permit individually verifying reverse flow closure of these valves or removing the internals of one valve so a leak test can verify closure of the remaining valve.

4. 10.3.2. 1 Licensee's Basis for Re uestin Relief--These are series check valves in the sample return line to the component cooling water (CCW) system. Only one check valve is required to isolate the non-classed sampling system from the CCW. If either valve closes on flow reversal, the system requirements are satisfied. The second valve has been installed as a backup to the safety-related valve as an operating convenience. The current system design only permits a leak test of both valves as a pair which does not verify closure of each individual valve.

In their letter dated December 31, 1986, the licensee indicated that

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a plant modification will be made to either allow verifying closure of the

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individual valves by installing a test tap between them, or removing the

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internals of one valve so the remaining valve can be verified to close.

4. 10.3.2.2 Evaluation--The current system design does not facilitate verification of reverse flow closure of valves 1CC-118 and 119.

Valve disassembly, inspection, and manual exercising would be the only method to verify individual valve closure with the current system configuration. There is no test tap between these valves, therefore, they can only be leak tested as a pair, which can only determine that at least one of the two valves is closed, but provides no information about which valve is closed or about the condition of the other valve. The installation of a test tap between these valves would permit each valve to be leak tested to verify closure, which would meet the Code requirement of a positive indication that these valves will stroke to the position required to perform their safety-related function. The licensee has stated that only one check valve is required to perform the safety function in the closed position, therefore, removing the internals of one valve so the remaining valve can be 54

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verified closed, will also allow the licensee to meet the Section XI testing

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requirements but is considered to be less preferable than the installation

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of a test tap. ~

The licensee's proposal to make system modifications in order to allow the Section XI testing to be performed is acceptable, however, in the interim period until the modifications are made, the closure of these valves must be verified by some alternate testing method. Valve closure can be individually verified by disassembly and inspection of these valves during refueling outages. Therefore, the licensee should disassemble and inspect these valves on a refueling outage frequency until a modification is made that permits the Code required testing to be performed.

Based on the impracticality of individually verifying the reverse flow closure of these valves due to the system design and the burden that would be imposed on the licensee if they were required to immediately make modifications that allow this testing to be performed, interim relief may be granted from the Section XI requirements to individually verify the reverse flow closure of valves ICC-118 and 119.

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APPENDIX A VALVES TESTED DURING COLD SHUTDOWNS 57

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

1. CONTAINMENT HVAC SYSTEM 1.1 Cate or A Valves Valves 1CP-1, 4, 7, and 10, the containment building purge and vent containment isolation valves, cannot be exercised during power operations

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because the valves are sealed closed and required to remain closed and sealed closed during plant operating modes 1, 2, 3, and 4 by plant Technical Specification 3.6. 1.7. These valves will be exercised, fail-safe tested, and have their stroke times measured during cold shutdowns and refueling outages.

2. HAIN STEAN SYSTEM 2.1 Cate or B Valves Valves 1HS-58, 60, and 62, the steam generator atmospheric dump valves, cannot be exercised during power operations because opening these valves at power would dump steam to the atmosphere which would increase steam flow, increase reactor power, and decrease steam line pressure, thereby, resulting 59

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in a plant transient which could lead to a plant trip. These valves will be exercised, fail-safe tested, and have their stroke times measured during cold shutdowns and refueling outages.

1HS-80, 82, and 84, the main steam isolation valves, cannot be full-stroke exercised during power operations because closing one of these valves would isolate the steam supply from one of the three steam generators to the main turbine resulting in a severe pressure and power transient which could cause a plant trip. These valves will be partial-stroke exercised quarterly during power operations and will be full-stroke exercised, have their stroke times measured, and be fail-safe tested during cold shutdowns and refueling outages.

3. FEEDWATER SYSTEM 3.1 Cate or 8 Valves 1FW-159, 217, and 277, the main feedwater header isolation valves, cannot be full-stroke exercised during power operations because'losing one of these valves would isolate all feedwater flow to a steam generator, except for the small amount of flow through the auxiliary feedwater header, resulting in a loss of steam generator water level control which could cause a plant trip. These valves will be partial-stroke exercised quarterly during power operations and will be full-stroke exercised, have their stroke times measured, and be fail-safe tested during cold shutdowns and refueling outages.

3.2 Cate or C Valves 1FW-158, 2l6, and 276, the main feedwater header check valves, cannot be exercised during power operations because to verify reverse flow closure of these valves would require isolation of the appropriate main feedwater header and initiating auxiliary feedwater flow into the steam generator which would result in loss of steam generator water level control and cause thermal shock to the feedwater nozzles. Loss of level control could result 60

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n i due to technical specification restrictions, the downstream isolation valves cannot remain closed for extended periods, therefore, testing these valves could result in establishing auxiliary feedwater flow into the steam generators which could thermal shock feedwater piping and nozzles and result in premature failure of these components. These valves will be exercised, fail-safe tested, and have their stroke times measured during cold shutdowns and refueling outages.

4.2 Cate or C Valves IAF-16 and 31, the motor driven auxiliary feedwater pump discharge check valves, cannot be exercised quarterly during power operations because the only flow path through these valves is into the steam generators and injecting relatively cold condensate storage tank water into the hot feedwater piping and steam generators would thermal shock the feedwater piping and nozzles which could cause premature failure of those components.

These valves will be full-stroke exercised on a cold shutdown frequency and during refueling outages.

5. INSTRUMENT AIR SYSTEM 5.1 Cate or A Valves lIA-216, the isolation valve for the instrument air supply to equipment inside containment, cannot be exercised during power operations because instrument air supplies many components inside containment which are necessary for normal plant operation and loss of air pressure to these components could result in operating transients and a possible forced plant shutdown. This valve will be exercised, fail-safe tested, and have its stroke time measured during cold shutdowns and refueling outages.

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6. REACTOR COOLANT SYSTEM 6.1 Cate or B Valves 1RC-114, 116, and 118, the pressurizer power operated relief valves, will be exercised during cold shutdowns. This exercising frequency is consistent with the NRC guidelines for pressurizer power operated relief valves.

1RC-900, 901, 902, 903, 904, and 905, the reactor coolant system high point vent valves, cannot be exercised during power operations because exercising them could result in venting out some RCS coolant. This testing could damage the valve seat and lead to excessive leakage which would require valve repairs. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

7. CHEMICAL AND VOLUME CONTROL SYSTEM

7. 1 Cate or A Valves 1CS-11 and 238, the letdown line and normal charging line containment isolation valves, cannot be exercised during power operations because closing these valves would isolate letdown flow or charging flow which would cause pressurizer level control transients which could result in a reactor trip. Closing 1CS-238 would stop charging flow to the regenerative heat exchanger which could result in high letdown temperatures and restarting this flow could thermal shock the regenerative heat exchanger and result in premature failure. These valves will be exercised and their stroke times measured during cold shutdowns and refueling outages.

7.2 Cate or B Valves 1CS-231 and 235, the normal charging line isolation valves, cannot be exercised during power operations because closing either of these valves would isolate normal charging flow which could cause a loss of pressurizer water level control resulting in a plant trip. Stopping charging flow would 63

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also affect letdown temperature and restarting flow could thermal shock the regenerative heat exchanger which could result in premature failure.

Failure of one of these valves in the closed position during testing would also cause a loss of control of RCS boron concentration. These valves will be exercised and have stroke times measured during cold shutdowns and refueling outages.

1CS-165, 166, 291, and 292, isolation valves in the charging pump suctions from the volume control tank and the refueling water storage tank, cannot be exercised quarterly during power operations because these two sets of block valves are interlocked such that both sets of valves cannot be open at the same time, therefore, exercising these valves would result in refueling water storage tank water, with its high concentrations of boric acid, being injected into the reactor coolant system and reactor coolant pump seals which would cause power fluctuations and possibly result in a plant shutdown. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

7.3 Cate or C Valves 1CS-279, the check valve in the line from the boric acid filter to the charging pump suction header, cannot be exercised quarterly during power operations because the only flow path available to exercise this check valve with flow would result in supplying water with high concentrations of boric acid to the charging pump suction and from there into the reactor coolant system which would cause power fluctuations and possible shutdown of the reactor. This check valve will be full-stroke exercised when borating on the way to cold shutdowns and during refueling outages.

1CS-294, the check valve in the line from the refueling water storage tank to the charge pump suction header, cannot be exercised quarterly during power operations because the only flow path to exercise this check valve with flow would supply refueling water storage tank water with high concentrations of boric acid to the charging pump suction and from there into the reactor coolant system resulting in power fluctuations and possible plant shutdown. This valve will be full-stroke exercised during cold shutdowns and refueling outages.

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8. SAFETY INJECTION SYSTEM 8.1 Cate or A Valve ISI-359, the isolation valve in the RHR recirculation line to the RCS hot leg, cannot be exercised during power operations because the valve is required to remain closed with electrical power removed from its operator by Technical Specification 4.5.2.8 during power operations to prevent overpressurization of the low pressure RHR system piping by the high pressure reactor coolant system. This valve will be exercised and have its stroke time measured during cold shutdowns and refueling outages.

8.2 Cate or AC Valves The following pressure boundary isolation check valves, which protect the low-pressure residual heat removal (RHR) system piping from the high pressure reactor coolant system, cannot be exercised during power operations because the RHR pumps do not produce sufficient head to overcome normal RCS operating pressure and using the charging pumps could cause a loss of

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pressurizer level control which could lead to a plant trip. These valves

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will be exercised open during cold shutdowns and refueling outages.

1SI-134 1SI-137 1SI-356 1SI-135 1SI-346 1SI-357 1SI-136 1SI-347 1SI-358 8.3 Cate or C Valves 1SI-81, 82, and 83, the check valves in the low pressure safety injection line to the RCS cold legs, cannot be exercised during power operations because the RHR pumps do not produce sufficient head to overcome normal RCS operating pressure and using the charging pumps could cause loss of pressurizer level control which could lead to a plant trip. These valves will be exercised during cold shutdowns and refueling outages.

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9. CONTAINMENT SPRAY SYSTEM 9.1 Cate or B Valves 1CT-102 and 105, the containment recirculation sump isolation valves in the containment spray pump suctions, cannot be exercised quarterly during power operations because opening these valves would allow some system water to drain into the containment sump and this highly oxygenated stagnant water could cause corrosion of the sump structure. No provisions exist for removing this water and drying the sump from outside of containment, therefore, a containment entry would be required in order to remove this water. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

10. RESIDUAL HEAT REMOVAL SYSTEM 10.1 Cate or A Valves 1RH-1, 2, 39, and 40, the pressure boundary isolation valves on the RHR suction lines from the RCS hot legs, cannot be exercised during power

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operations because these valves are interlocked with RCS pressure and cannot

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be opened when RCS pressure is greater than 425 psig to prevent overpressurization of the low pressure RHR system by the high pressure reactor coolant system which could lead to an inter-system LOCA. These valves will be exercised and have their stroke times measured during cold shutdowns and refueling outages.

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APPENDIX B PAID AND FIGURE LIST 67

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APPENDIX B PAID LIST The PRIDs listed below were used during the course of this review.

S stem P&ID Revision Hain Steam System S-0542 Feedwater System S-0544 Condensate and Air Evacuation Systems S-0545 Circulating and Service Water Systems S-0547 Containment Spray System S-0550 Steam Generator Blowdown System S-0551 Sampling System--Nuclear S-0552 Diesel Fuel 'Oil System S-0563 .

Radiation Honitor Systems S-0605 Diesel Generator Systems S-0633 Diesel Generator Systems S-0633S01

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Drainage System--Containment S-0685

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Primary and Demineralizer Water Systems S-0799 Service Air System S-0800 Instrument Air System S-0801 Fuel Pools Cooling System S-0805 Cooling Tower Systems S-0808 Fire Protection System--Sh. 4 S-0888 Intake Structures Pump Support Systems S-0936 HVAC Essential Services Chilled Water System S-998 HVAC Essential Services Chilled Water System S-998S02 HVAC Essential Services Chilled Water System S-998S03 HVAC Essential Services Chilled Water System S-998S04 HVAC Essential Services Chilled Water System S-999S HVAC Essential Services Chilled Water System S-999S02 HVAC Essential Services Chilled Water System S-999S03 HVAC Essential Services Chilled Water System S-999S04 Reactor Coolant System--Sh. 2 S-1301 69

S stem PAID Revision Chemical and Volume Control System S-1303 Chemical and Volume Control System S-1303S01 Chemical and Volume Control System S-1303S02 Chemical and Volume Control System--Sh. 2 S-1304 Chemical and Volume Control System--Sh. 3 S-1305 Chemical and Volume Control System--Sh. 4 S-1306 Chemical and Volume Control System S-1307 Safety Injection System--Sh. 1 S-1308 Safety Injection System--Sh. 2 S-1309 Safety Injection System--Sh. 3 S-1310 Waste Processing System S-1313 Component Cooling Water System--Sh. 1 S-1319 Component Cooling Water System--Sh. 2 S-1320 Component Cooling Water System--Sh. 3 S-1321 Component Cooling Water System--Sh. 4 S-1322 Component Cooling Water System--Sh. 5 S-1322S01 Residual Heat Removal System S-1324 HVAC Air Flow Diagram--Containment Bldg. G-517 HVAC Air Flow Diagram--Auxiliary Bldg. G-517S03 HVAC Air Flow Diagram--Control Room G-517S04 HVAC Air Flow Diagram--Switchgear Room G-517S05 HVAC Air Flow Diagram--Fuel Handling Bldg. G-533 70

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APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW 71

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APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW Inconsistencies and omissions in the licensee's program noted during the course of this review are summarized below. The licensee should resolve these items in accordance with the evaluations, conclusions, and guidelines presented in this report.

1. The licensee identified many changes to the Shearon Harris Unit 1 IST program in their A.B. Cutter to H.R. Denton letter dated December 31, 1986, however, they have not submitted the necessary program modifications, such as revised relief requests etc., to support these identified changes. This TER addresses the affected components as if the identified program modifications were in place and in many cases recommends the granting of relief from the Section XI requirements based on these identified changes even though the relief request in the September 16, 1986, IST program is not judged to be acceptable. In order to make the Shearon Harris Unit 1 IST program correct and complete, the licensee should make the following modifications to the program and submit them to the NRC for review:

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a. Auxiliary feedwater relief request RV-1 should be changed to a cold shutdown justification for valves 1AF-16 and 31 and these valves should be identified as being tested on a cold shutdown frequency on the valve listing table.

b. Auxiliary feedwater relief request RV-2 should be changed to a cold shutdown justification for valves lAF-19 and 34. The IST program should also be modified to exercise, fail-safe test, and measure the stroke times of these valves on a cold shutdown frequency. In addition the licensee should provide an augmented justification for not exercising these valves during the quarterly auxiliary feedwater pump tests.

c. Auxiliary feedwater relief request RV-3 should be changed to a cold shutdown justification for valves lAF-49, 50, 51, 129, 130 and 131. The IST program should also be modified to exercise, fail-safe test, and measure the stroke times of these valves on a cold shutdown frequency.

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In addition the licensee should provide an augmented justification for not exercising these valves during the quarterly auxiliary feedwater pump tests.

d. Auxiliary feedwater relief request RV-6 should be modified to indicate that valves lAF-65, 84, and 103 will be tested using a sample disassembly and inspection program on a refueling outage frequency (refer to Section 4.4. 1.2 of this report).

e. Auxiliary feedwater relief request RV-7 should be changed to a cold shutdown justification for valves lAF-117, 136, 142, and 148.

f. Auxiliary feedwater relief requests RV-4 and RV-5 for valves 1AF-54, 73, and 92 should be combined and modified to indicate that these valves will be exercised during each cold shutdown as the plant is being taken to the cold shutdown condition.

g. Condensate system relief requests RV-1 and RV-2 for valves 1Cf-36, 46, and 56 should be combined into one relief request that addresses all three valves being tested in both the open and the closed positions. In addition, a discussion should be provided that justifies grouping 1CE-56 with the other two valves in a sampling disassembly and inspection program (refer to Section 4.5. 1. 1 of this report).

h. Containment spray system relief request RV-2 should be changed to a cold shutdown justification for valves 1CT-102 and 105.

i. Since the containment spray additive tank vacuum breaker valves are tested in accordance with the Code requirements for relief valves, containment spray relief request RV-3 is not necessary and should be deleted from the IST program and Note 10 should be augmented to indicate the type of testing that is being performed.

j. Instrument air system relief request RV-2 should be modified to indicate that valves 1IA-784, 785, 786, 787, 788, and 789 will be 74

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4 individually verified to close by a sample disassembly and inspection program on a refueling outage frequency (refer to Section 4.7. 1. 1 of this report).

k. Chemical and volume control system relief request RV-1 should be modified to indicate that valves 1CS-341, 382, 423, 470, and 472 will be exercised during those cold shutdowns when the reactor coolant system is open, vented, and drained to the top of the reactor vessel flange (refer to Section 4.8. 1.1 of this report).

l. Chemical and volume control system relief request RV-3 should be changed to a cold shutdown justification for valves 1CS-165, 166, 231, and 292 because these valves will be exercised during cold shutdowns.

m. Chemical and volume control system relief request RV-5 should be changed to a cold shutdown justification for valve 1CS-279 because this valve will be exercised when borating on the way to cold shutdown.

n. Chemical and volume control system relief request RV-6 should be changed to a cold shutdown justification for valve 1CS-294 because this valve will be exercised during cold shutdowns.

o. Safety injection system cold shutdown justification CS-1 should be augmented to include the reasons that the high head safety injection/

charging pumps cannot be used to exercise valves 1SI-81, 82, 83, 134, 135, 136, 137, 346, 347, 356, 357, and 358 quarterly during power operations.

p. Component cooling water cold shutdown justification RV-1 should be modified to indicate that valves 1CC-207, 208, 249, 251, 297, and 299 will be exercised during those cold shutdowns when the reactor coolant system temperature is 200 F or lower and all reactor coolant pumps are secured (refer to Sections 4. 10. 1. 1 and 4. 10.2. 1 of this report).

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q. Containment HVAC system relief request RV-1 for valves 1CB-3, 1CB-7, and 1CH-7 should be modified to indicate that these valves will be verified closed by a visual inspection of the valve disk closing against the valve seat and are manually tested open, using a spring gage to measure the valve operating torque, during those cold shutdowns when the reactor containment is opened and during reactor refueling outages (refer to Section 4.3. 1. 1 of this report).

r. Pump relief requests PR-7 and PR-8 for the boric acid transfer pumps should be modified to indicate that the flowrates will be measured for the boric acid transfer pumps on a cold shutdown frequency when borating on the way to cold shutdown. They should also be modified to indicate that vibration measurements will be taken on these pumps during the quarterly pump tests (refer to Sections 3.6. 1 and 3.6.2 of this report).

s. Pump relief request PR-2 for the emergency service water pumps should be modified to indicate that the vibration measurements will be made on the upper motor bearings to give an indication of the pump mechanical condition.

t. Pump relief request PR-5 for the emergency service water screen wash pumps should be modified to indicate that the pump flowrate measurements will be made using an ultrasonic flow measurement technique and these flowrates will be compared to the measured pump differential pressures utilizing the pump characteristic curve to give an indication of the pump hydraulic condition (refer to Section 3.7. 1 of this report).

2. Auxiliary feedwater system relief request RV-2 for valves lAF-19 and 34 should be changed to a cold shutdown justification. The justification submitted does not provide adequate information to warrant using the cold shutdown test frequency instead of the required quarterly frequency, however, additional information was provided to the reviewers by the licensee in their December 31, 1986 submittal and in a telephone conversation, and the added justification is judged to be satisfactory. The licensee should modify their 1ST program to include an appropriate cold shutdown justification for these valves.

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3. The licensee's basis for relief in component cooling water relief request RV-1 for valves 1CC-118 and 119 is not acceptable and, therefore, the licensee should verify the reverse flow closure of these valves by valve disassembly and inspection during refueling outages until such time that appropriate system modifications can be made that allow these valves to be tested in accordance with the Code (refer to Section 4. 10.3.2 of this report).

4. The licensee proposed to verify the reverse flow closure of auxiliary feedwater check valves IAF-54, 73, 92, 117, 136, 142, and 148 by using acoustic detection (refer to Item 3. in the licensee's submittal of December 31, 1986). Insufficient information was provided by the licensee for the reviewer to determine that this method would provide a positive indication of valve closure as required by the Code. Relief should not be granted from the Code requirement of individually verifying closure of these valves (refer to Sections 4.4. 1. 1 and 4.4. 1.3 of this report).

5.~ By the end of the first refueling outage the licensee should determine if the

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ranges of Table IWP-3100-2 can be met for the flowrate measurements of the high head safety injection/charging pumps. If the Code specified ranges cannot be met, the licensee should specify appropriate alternate ranges as provided for in the Code (refer to Section 3.5. 1 of this report).

6. The licensee should provide reduced range limits for the flowrate measurements on the diesel generator fuel oil transfer pumps as specified in Section XI, Paragraph IWP-3210 (refer to Section 3.4.1 of this report).

7. In their letter dated Harch 20, 1987, the licensee indicated that 1HS-T would be exercised in accordance with the Code and they provided a more detailed justification for not measuring the full-stroke time for 1HS-G.

Hain steam system relief request RV-1 should be modified to remove valve 1HS-T and to include the additional justifications for 1HS-G.

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