ML19240B998

Inservice Testing Program for Pumps & Valves at Beaver Valley Power Station Unit 1 (Docket 50-334) for Period 800130-810929 Revision 1 to Safety Evaluation

ML19240B998
Person / Time
Site:	Beaver Valley
Issue date:	03/31/1981
From:	Fehringer J, Rockhold H EG&G IDAHO, INC., EG&G, INC.
To:	Nerses V Office of Nuclear Reactor Regulation
References
CON-FIN-A-6258 EGG-EA-5254, TAC-6363, NUDOCS 8104170707
Download: ML19240B998 (71)

Text

EGG-EA-5254,Rev. 1 March 1981 SAFETY EVALUATIDN REPORT, INSERVICE TESTING PROGRAM, BEAVER VALLEY POWER STATION UNIT 1 - DOCKET NO. 50-334 J. M. Fehringer H. C. Rockhold [6'

/, \,)

r kg 9 v

7 9 f

. , d ~GL L o j -s BC Rescarch anc Tec,1nica 3 J;gsw,

~ Assistcoce Report

%~'A Neyswo U.S. Department of Energy 5 '$Y

!aho Operations Office

• Idaho National Engineering Laboratory n -

2'

\ . ,.I ( lg 4 O,El 2 dh0j(k9q}r@k#

e'9

.A o,, tpy ,e&

y p;Q w t - .gf.

&a. ,. '

! Vji.:

s b N O.' $ W Q}$$h 22 ~

4 c

, #g

>9- y ' .,v t :s

- f9ceaQ NE rrra marcr; % =

v b-yh .fj,C A

, ug,?g.;y;/.._imAy .gzqr ,,,,e-;P@. c. p ggqrC+gg t:jr El h l ,.c

' ~

' 4

[Iy P~i p. warww rsay arr= unarm, rama g. e-j y N anl i Ibem weagr r ww ur r==rr tr wr-rcr rwarr rmrr i gme b.. 6

- .,,,. O W.&-MW5 i'*:W j ..~w:" v- - ,,rw $;" QQ~* ' .'.' _ "'"#~""'~~~~~ %._ py n

_& >p;,lh m, ._

~ -

2 -

,p m( itQw ...

a .- , .-..ehhq@h q y"4::E M U _ , .

m s W vk&mm*f ene_s p ~g%h , m . _1 _ - .. r s &>p ~%m ew m mu?,,kee nm..

mW;34=6 m.5 w:s  :. Q ' Qs&.

~. .U s.g ,. > L. n gng4m y &.,i: '

kh W Wi~w?3+ % 1,=..,;m wjg,y.,.m 2

$ h a A Jgr k,,+iy

%w.me.+gvyzedecess - -w vnx*A .gy -mk t @, a qag?.pr,w %p -"i%WyM, % ,, 3>7W-W. s

.w. ~r w -

%g%W8&+ x.a sw.sw.Mc Y:n m

This is an informal report intended for use as a preliminary or working document

\lRC Researcil anc ecanica Prepared for the U.S. Nuclear Regulatory Commission Assistance Repor~./ -

Under DOE Cortract No. DE- AC07-761D01570 [l FIN No. A6258 4g E b E b idaho F104170'2

h E G c G ,~... -,

f Or.M i n AG w-me It Ne, INTERIM REPORT Acces sion N o .__ _. . __ _ . __

Report No EGG-E A-5254, Rev. 1 Contract Program or Project

Title:

Systems Engineering Support Subject of this Document:

Safety Lvaluation of the Inservice Testing Program for Pumps and Valves at the Beaver Valley Power Station Unit 1 (Docket No. 50- 33?) for the Period 1-30-80 through 9-29-81 Type of Document:

Safety Evaluation Report Author (s):

J. M. Fehringer H. C. Rockhold Date of Document: m ..

no,cn 3g33 Al7C NeSe2fCi and B) C EIC8 it .

Assistance Repor: ~/

Responsible NRC Individual and NRC Office or Division:

Vic t o r Ne rses , N"-DE T his documer:t was prepared primanty for preliminary or internal use it has not receas ed f ull res iew and approvat Since there may be substantive channes, thG document shou!d not be considered fin:il EG&G Idaho inc Idaho Fatis. Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission

, Washington, D.C.

Under DOE Contract No. DE- AC07-761001570 NRC FIN No. M238 INTERIM REPORT

CONTENTS

!. I NT RODU' 110N . . ......... .. .................................... 1 II. P L M P T E S T I N G P R O GR AM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  ?

11!. VA'_ kE IEST ING PROGRTd . . ............................ .......... 8 IV. ATIACHMENT I ........ ......................................... 55 V. ATTACHMENT II ................................................... 66 VI. A I I A C H 'A T. N T I I I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 NRC Research and Technica Assistance Report i

1. Introduction Contained herein is a saf ety evaluation of the pump and valve inservice testing (IST) program submitted by the Duquesne Light Company on 5-2-79 f or its Beaver Valley Power Station Unit 1 nuclear pl ant . The program anplies to Beaver Valley for the geriod 1-30-80 th:augh 9-29-81. The working session with Duquesne Light and Beaver Valley Power Station Unit I representatives was conductea on 12-13-79 and 12-14-79. The licensee resubmittal was issued cn 3-17-80 and was rev,ewed by EG&G Idaho Inc., to terify compliance at propoced tests of saf ety related Class 1, 2, and 3 pumps and valves with requircents of the ASME Boiler and Pressure Vessel Code,Section XI,1974 Edition, through the Summer of 1975 Addenda. Duquesne Light Company has also requested r 21ief f rom the ASME Code f rom testing specified pumps and valves because of practical reasons. These requests have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed impr ac ti c al .

The evaluation of the pump test ing program and associated relief requests is cnntained in Section 11; the evaluation of t he valve testing program and associated relief requests is contairid in Section Ill. All evaluations f or Sections II and III are the recommendations of EG&G Idaho, Inc.

C at egory A, B, and C volves that meet the requirements of tne ASME Coce Section X1 end are not exercised every 3 months are cont ained in Attachnent 1.

A listing of P&ID's used f or this review are contained in Attachment II.

Valve <, that are never f ull stroke exercised or that have a testing interval great er than each ref ueling ?utage and relief requests with NC Research and ~ec1nica; 1

Assistance Report

insuf ficient technical basis where relief is not recommended are su n;acized in Attachment III.

II. Pump Testing _ Program .

The IST program subn.itted by Duquecne Light Company f or its Beaver ~

Valley Power Ctation Unit I was examined to verify that Class 1, 2, and 3 saf ety related pumps were included in the program and that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that Class 1, 2, and 3 safet.,

related punas were included in the IST program and, except for those purrps iientified below f or which specific relief f rom testing has been recuested, the pump tests and f requency of testing comply with the code. Each Duquesor Light Company basis for requesting specific relie: f rom testing pumps and the EG&G evaluation of that request is sumarized (P through F) below and grouped according to the system in which the pump 3 reside: ,

A. Code Requirement ,

En inservice test shall be conducted on all saf ety related pumps, nominally once each month during normal pl3nt operation. Each inservice test shall it.clude the measurement, oboervation, and recording of all quantities in Table IWP-3100-1, except bearint, temperature, which shall be measured during at least one inservice test each year.

o. Boric Acid Transf er Pumps (CH-P-2A and CH-P-2B)

1. Re1ief Requeg The licensee has requested specific relief from measuring bearing temperature (Tb) and vibration velocity (V) on the -

boric acid transf er pumps in accordance with the requirements of Section XI.

2

C_od_ Raquirement Ref er to pump testing paragraph II. A.

Licc Lee's Basis for Requesting Relief These pumps are located in a heat traced box. Removal of the box can cause teat trace damage and thus degrade system integrity (cold spots could occLr on the heat trace box).

Evaluation We agree with the licensee's basis and therefore feel that temporary relief should be granted for the boric acid transfer pumps from the testing requirments of Section XI.

The licensee has demonstrated that these pumpc are inaccessible and T b and V cannot be aieasured. Removal of the box could cause heat trace damage that could result in boron precipitation and crystallization that would result in system degradation. We concluce that with the present plant design V and T h c nnot be measured on these pumps.

However, will feel the licensee should further investigate some r ethod to determine the mechanical characteristics of the boric acid transfer pumps.

C. Residual Heat Pemoval Pumps (RH-P-1A and RH-P-1B)

1. Relief Request The licensee has requested specific relief for the residual heat removal pumps f rom the testing requirerrents of Section XI and proposed to measure all required parameters during cold shut doven.

3

yode Requirement Ref er to pump testing paragraph II. A.

Licensee's Basis for Requesting Relief The pumps and associated instrumentation are located inside the subatmosphere contoinment missile barrier where a high radiation area exists. Radiation levels are approximately 200 mR/hr and an operator work time of 30 minutes is required to perform each pump test at power and this would violate ALARA guidelines. The pumps are not required to be run at power or f ulfill any saf ety f unction to mitigate the consequences of en accident.

E v al uati on We agree with the licensee's basis and theref ore f eel that relief should be granted f or the residual neat removal pumps ,

from the testing requirements of Section XI. The licensee has demonstrated that these pumps are inaccessible and are not required to function during power operation. We conclude that the proposed cold shutdown testing f requency should demonstrate pump operability.

D. Inside Recirculation Syray Pumps (RS-P-1A and RS-P-1B)

1. l Rjtjief Request The licensee has requested specific relief for the inside recirculation spray pumps f rom the testing requirements of .

Section XI and preposed to run these pumps dry monthly up to 100 rpm then stop the pumps.

Code Requirement Ref er to pump testina paragraph II. A.

Licensee'c Basis f or Requesting Relief for monthly surveillance requirement, the pump is run dry and then st opped vhcn it reaches 100 rpm as indicated by a blue light in t he corttrol room. All other monitored parameters re not obtained in any plant mode due to the inf easibility m f looding the containment basement.

Evaluation We agree with the licensee's basis and therefore feel that

'empor ary col i ef t.4:ald be grantert f or the inside recirculat mn ters v pumps from the testing requirements of Section X1. The licensee nas demonstrated that with the present plant i .i gn they are performing the only testing possible. f H lira the containment sump f or pump testing would res u lt in + . qe to electrical equipment located i n s i de t he c < n t i n:r e nt . Howeser, we conclude thtt the licensee < x ulo fuither investigate other methods and possible pl;nt ~odifications that would enable the licensee t o detero: tm hydr Sulic and mechanical characteristics and any dMr " :t i on of these pumps.

E. Out side Rec ircu l" ico Spr a v Pumps ( RS-P-2A and RS-P-28)

1. Rellef Reauest The license, c a :- requested specific relief for the outside ret ircul at , m ' : r ay pu'r.ps f rom the testing requirr cents of Section XI <f p- .m ed to run these pumps dry monthly for 60 second: V rur ihem on wet recirculation during refuellng o;tav b

Code Requirement Refer to pump testing paragraph II. A.

Licensee's Casis for Requesting Relief T hese pumps are started and stopped immediately during power operation and cold shutdown. During this test the pumps are run dry and cannot be run raore than 60 seconds, thus no par ameters are measured. During refueling outages the pumps are isolated f rom the system, filled, vented, and run approxin,ately 2 minutes (to prevent pump overheatirig and pump damage) so that speed (N), inlet pressere (P5 ),

dif f erential pressure (dP), and flowrate (Q) can be measured. These pumps cannot be run long enough to n>eosure vibration velocity (V) and bearing temperature (T,0).

Evaluation We agree with the licensee's basis and therefare feel that temporary relief should be granted f or the outm de recirculation spray pumps f rom thc testing requirements of Section X]. The licensee has demnnstrated t hct with the present plant design they are perf orming th sly testing t

possible. However, we conclude that the licernee should f urther investigate other riethods and possible plant modifications that would eneble t he licensee to det.:rmine the mechanical characteristics mid any pump cmchanical degracation.

F. Radiation Monitoring Pumps .

1. Relief Request .

The licensee has requested specific relief for t he. radiation monitoring pumps t hat monitor river water li& P-RW)DO, ret ircul at ion sprays heat exchanger 1Rf? "-niODA 6

through 100D, CCR/RW heat exchanger 1RM-P-RW101, and S/G blowdown 1RM-P-BD103, f rom the testing requirements of Section XI and proposed to observe radiation monitor system operation to determine each pumps operability.

Code Requirement Refer to pump testing paragraph II. A.

Licensee's Basis for Requesting Relief R lief f rom all monthly testing of all applicable in plant Radiation Monitor Pumps is requested for the following reasons:

a. These pumps are a integral part of a Radiation Monitor.

b. R adiation Moni tor Pumps with an emergency power source serve no automatic safety-related f unction.

c. There are high and low flow alarms associated with the applicaiale radiation monitors that alarm in the Control R oom . There is no other installed instrumentation.

Evaluation We agree with the 1;censee s basis and therefore feel that relief should be granted f or the radiation monitoring pumps 1RM-P-RW100, 1RM-P-RW100A through D. IRM-P-RW101, and 1RM-P-BD100 f rom the testing requirements of Section XI. We conclude that the litersee's prq m l of observing proper system operc tion shoul( demonstrdte proper pump operation.

I

111. Valve Testing Program Evaluati_on The IST program submitted by Duquesne Light Company was examined to verif y that Class 1, 2, and 3 saf ety related valves were included in .

the progrdm and that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the t;RC positions and -

guidelines. Our review f ound that Class 1, 2, and 3 safety related valves were included in the IST program and, except f or those valves identified below f or which specific relief from testing has been requested, the valve tests and f requency of testing comply with the code requirements and the NRC positions and guidelines listed in Ger,eral Section A. Also, included in the General Section A is the NRC position and valve listings f or the leak testing of valves that perf orm a pressure isolation f unction and a procedure for the liccnsee's use to incorporate these valves 1nto the IST program. Each Duquesne Light Company basis f or requesting specific relief f rom testing valves and the EG&G evaluation of that request is summarized ,

(B through K) below and grouped according to each specific system.

A. General Considerations

1. Testing of Valves which Perf orm ; Pressure Isoletion Functicn Several saf ety systems connected to the reactor coolmt pressure boundary have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class 1 boundary f orming the interf ace between these high and low pressure systems prevent the low pressure systems from pressures which exceed their design limit. In this role, the valves perf orm a pressure isolation function. The NRC considers the redundant

• isolation provided by these valves to t e importa':t. The t;RC considers it necessary to assure that the condition of each 8

of these valves is adequate to maintain this redundant isolation and system integrity. For these reasons, EG&G believes that some method, ' ach as pressure monitoring, leak testing, radiography or ultrasonic testing, should be used to assure the ccadition of each valve is satisfactory in maint aining this pressure isolation f unction.

If leak testing is selected as the appropriate method for achieving this objective, the NRC and EG&G 1daho, Inc.,

believe that the following valves should be categorized as A or AC and leak tested according to IWV-3420 of Sec+ ion XI of the applicabic edition of the ASML code. These valves are:

1RH-720A and 0 1RH-700 and 701 IS?-48, 51, 49, 52, 50 and 53 151-850B, D and F 151-15, 16 and 17 151-20, 21 and 22 151-10, 11 and 12 151-23, ?4 arti 25 151-100, 101 and 102 151-83 and 84 1CH-170

]CH-170 1RC-556A, B and C The f;RC and E3&G Idaho, Inc., have discussed this mat hr with the licensee and identified the valves listed above.

The licensee agreed to consider testing and categorizing each of these valves with the appropriate designation depending on the testing method selected. Whatever method the licensee selects f or oetermining the condition of each

• valve, the licensee will provide to the NRC for evaluation

't details of the testing method which clearly demonstrates the condition of each valve.

9

2. ASME Code Section XI Requirements Subsection IWV-3410(a) of the Section XI Code (which discusses f ull stroke and par tial stroke) requires that Code ,

Category A and B valves be exercised once every 3 months, with the exceptions _ as defined in IWV-3410(o-1), (e), and .

(f). IWV-3520(a) requires that Code Category C valves be exercised once every 3 months, with the exceptions as defined in IWV-3570(b). IWV-3700 requires no regular testing f or Code Category E valves. Operational checks, with appropriate record entries, shall record t he position of these valves bef ore operations are perf crmed and af ter operations are completed and shall verify that each valve is locked, or sealed. The limiting value of full stroke time f or each power operated valve shall be identified by the owner and tested in accordance with IWV-3410(c). In the above exceptions, the code permits the valves to be tested at cold shutdown where:

a. It is not practical to exercise the valvet, to the position required to f ulf ill their f unction or to the par t i al posi t i on during_py wer opgrMion.

b. It is not practical to observe the operation of the valves (with f ail-saf e actuators) upon los'. of ettuator power.

3. 5troke Testing of Check Valves The NRC stated its position to the licensee that check valves whose saf ety f unction is to open are expected to be .

f ull-stroked. If only limited operation is po W ble (and it has been demonstrated by the licensee and agreed to by the NRC) the chunk valve shall be partial strob;d. Since disk position is not always observable, the NPC staff stated that 10

verification of the plant's safety analysis design flow rate through the check valve would be an adequate demonstration of the f ull-stroke requirement. Any flow rate less than design will be considered part-stroke exercising unless it can be shown that the check valve's disk position at the l ower f l ow rt .e would be equivalent to or greater than the design flow ra'.e thr:agh the valve. The licensee agreed to conduct flow test to satisfy the abova po3. tion.

4. Stroke Testina of Motor Operateo Valves The licensee has requested elief from the part-stroke requirement of Section XT for all power operated valves.

The licensee has stated that none of the Category A or B power operated valves identified can be part-stroked because of the design logic of the operating circuits. These circuits are such that when an oper or close signal is received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other direction. We find that the above relief request f rom part-stroking is warranted and should be granted because the required f unction of the valves involves only full open or full closed positions.

5. Test Freauency of Check Valves Tested at Cold Shutdowns The Code <,tates that, in the case of cold shutdowns, valve testing need not be perf ormed more of ten than once every three months f or Category A and B valves and oncc every nine months f or Category C valves. It is NRC's positior. that the Code is inconsistent end that Category C valves should be tested on the same schedule as Category A and B valves. The licensee has agreed to modify his procedures on cold

- shut downs t o read, "In t he case of f requent cold shutdowns, valve testing need not t e perf ormed more of ten than once every three (3) nonths for Category A, B and C valves."

11

6. Licensee Request for Relief to Test Valves at Cold Shutdown The Code permits valves to l'a tested at cold shutdown, and the Code conditions under vnich this is permitted is noted .

in Appendix A. These valves are specifically identified by the licensee and are f ull stroked exercised during cold

~

shutdowns; theref ore, th( licensee is meeting the requirments of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verif ied that it was not practical to exercise these valves during power operation and that we agree with the licensee's basis. It should be acted that the NRC differentiates, for valve testing purposes, between the cold shutdown mode and the ref ueling mode. That is, f or testing purposcs the ref ueling mode is not considered as a cold shutdown.

7. c.hanges to the Technical Specif ication .

In a November 1976 letter to the licensee, the NRC provided an attachment entitled, "NRC Guidelines for Excluding Exercising (Cycling) lests of Certain Volves During Plant Operation." The attachment stated that when one train of a redundant system such as the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not be cycled if their f ailure in a nnn-safe posit ion would cause a loss of total system function. For ex ample, during power operation in some pl ants , there are stated minimum requirements for systems which allow certain Iimi ting conditions f or operation to exist at any one time and if the system is not restored to meet the requirements within the time period specified in a plant's Technical Specifications (T.S.), the reactor is required to be put in 12

some other mode. Furthermore, prior to initiating repairs all valves and interlocks in the system that provide a duplicate f unction are required to be tested to demonstrate operability immediately and periodically thereaf ter during power operation. For some plants this situation could be contrar- to the NRC guideline as stated in the document menticoed above. It should be noted that a reduction in redundancy is not a basis f or a T.S. change nor is it by itself a basis for relief from exercising in accordance with Section XI. The licensee has agreed to review the plant's T.S. and to consider the need to propose T.S. changes which would have the effect of precluding such testing. After making this review, if the licensee determines that the T.S.

should be changed because the guidelines are applicable, the licensee will submit to the NRC, in conjunction with the proposed T.S. change, the inoperable condition for each system that is af f ected which demonstrates that the valve's f ailure would cause a loss of systen f unction or if the licensee determines that the T.S. should not be changed because the guidelines are not applicable or cannot be f ollowed, the licensee will submit the reaso- that led to their determination f or each potentially affected section of the T.S.

8. Safety Related Valves This review was limited to saf ety-related valves.

Saf ety-related valves are defined as those valves that are needed to mitigate the consequences of an accident and/or to shutdown the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically

- include cert ain ASME Code Class 1, 2 and 3 valves and could include somr non-code class valves. It should be noted that

- the licenser : 2y have included non-safety related valves in their Inter < ice lest Program as a decision on the licensee's part to expand t he scope of their program.

13

9. jfalve Testing at Cold Shutdown Inservira valve testing at cold shutdown i.s accept alde when the f ollowing conditions are met: It is understood that the .

licensee is to comr ence testing as soon as the cold shutdown condition is achaved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> af ter

• shutdown and continue until complete or plant is ready to return tc power. Completion of all valve testing is not a prerequisite to return to power. Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to meet the Code specified testing f requency. For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.

10. Category A Valve Leak Check Requirements for Containment Isolation Valves (CIV)

All CIVs shall be classified as Category A valves. The Category A valve leak rate test requirements of IWV-3420(a-e) have been superseded by Appcndix J requirements for CIVs. The NRC has concluded that the applicable leak test procedures and requirements for CIVs are determined by 10 CFR 50 Appendix J. Relief f rom paragraph IWV-34-20 (a-e) for CIVs presents no safety problem since the intent of IWV-3420 (a-e) is r~et by Appendix J requirements.

The licensee shall comply with Sections f and g of IWV-3420 until relief is requested from these paragraphs. It should be noted that these paragraphs are only applicable where a Type C Appendix J leak test is performed. Based on the considerations discussed above the NRC concludes that the 14

dlternate testing proposed above will give the reasonable assurance of idh t operability intended by the Code and that the relief thus ar:nted will not endanger life or property of the common def ense and security of the public.

11. Application of Appendix J Testing to the IST Program The Appendix J review f or this plant is a completely separate review from the IST program review. However, the determinations made by that review are directly applicable to the IST program. Our review has determined that the current IST program as submitted by the licensee correctly reflects our interpretation of Section XI vis-a-vis Appendix J. The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.

B. Reactor Coolant System

1. Category A and A/C Valves

a. Relief Request The iicensee has requested specific relief from exercising Category A/C Valves RC-68, N2 make-up to PRT and RC-7?, primary water supply to PRT in accordance with the requirements of Section XI and proposed to verify valve closure (their safety related position) ouring ref ueling outages.

Cnde Requi rement Ref er to valve testing paragraph A. 2.

15

Licensee's Bas. for Requesting Relief During normal plant operation RC-68 anu RC-72 are closed and only require opening upon nitrogen or water .

makeup to the Pressurizer Relief Tart. Dcr ing an accident condition (DBA) the required position of these valves is shut as is the normal op(rational )osition thereby reducing the possibility of the valve being open at the time of the accident. In addition, no installed instrumentation exists to detect makeup flow or check valve position. No alternate stroke testing is proposed in addition to the 18 month leak test.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted f or Category A/C Valves RC-68 and RC-72 f rom the exer cising requirements of Section XI. The licensee has demonstrated that due .

to plant design the only method available tr verify valve closure (their safety related position) is during leak testing. These valves are not equipped with valve pocition indicators and some of the required test connectinns are located inside the containment. We conclude that the proposed alternate testing frequency of verif ying valve closure during the perf ormance of leak rate testing at ref ueling out ages should demonstrate proper valve operability.

b. Relief Request The licensee has requested spec ific relief from exercising Category A Valves RC-277 and RC-278, containment isolations f or pressure celit; ration -

instruments, in accordance with the requirements of Section XI and proposed to leak test these valves during refueling outages.

16

tade Requirement Refer to valve testing paragraph A. 2.

~

Licensee's Basis for Requesting Relief

~

These valves are closed during normal plant operation and were designed for use in emergency conditions only to open a path to determine RCS pressure, with loss of normal pressure indication, from outside the containment. These are passive valves not required to change position in an accident condition. No alternate stroke testing is proposed in addition to the 18 month leak test.

Eyaluation We agree with the licensee's basis, and therefore feel relici should be granted for Category A, passive Valves RC-277 and RC-278 from the requirements of Section XI . These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the pl ant. Therefore, the operability of these valves is inconsequcntial with regard to tne safety f unction which they perf orm. We conclude that the quarterly st roke ant' stroke time measurements are meaningless for passive valves.

a 17

C. C3mical and Volume Control

1. Category A and A/C Valves

a. Relief Request The licensee has requested specific relief from exercising Category A/C Valve 1CH-31, charging header inside containment isolation check, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety related position) during refueling outages.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for P.equesti_ng Relief This check valve is a normally oper, valve and valve closure can only be checked by leak test. The safety related position of tnis valve is closed. There is no instrumentation to monitor upstream pressure dJring nonnal oper at ion. Therefore, relief is requested f rom Quarterly and Cold Shutdown Stroke tests. f40 al ternate seating check is proposed in addition to the refueling l eak test.

Evalu? tion We agree with the licensee's basis, and therefore feel ,

that relief should be granted f o- Category A/C Valve 3-CH-31 f rom the exerc ising requir ement s of .

Sec t ion XI . The licensee has demonst cated that due to 10

plant design the only method available to verify valve closure (its saf ety related position) is during leak testing. lnis valve is not equipped with valve position indicators and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of veritying valve closure during the performance of leak rate testing at refueling autages should demonstrate proper valve operabi~ity.

b. Relief Request The licensee has renuested specific relief from exercising Category A/C Valves ICH-181, ICH-182, and ICH-183 PCP seal injection isolation checks, in accordance with the requirements of Section XI and proposed to verify valve closure (their safety related position) during ref ueling outages.

Code Reg _ui rement Refer to valve testing paragraph A. 2.

.L_icens(e's Basis f or Requesting Relief These check valves are normally open during power operation and are required to close to fulfill their safety function. Closure of these valves would stop seal injectioi and compromise pump operation. In addition, seal injaction flow is required ::nytime the system is pressurized greater than 100 psig.

lherefore, relief f rom quarterly and cold shutdown full stre'.o exercising is requested. These valves are full

- stroke exercised during leak rate testing done at ref neling oer 051 1.47.28.

19

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted f or Category A/C ,

Valves ICH-181, ICH-182, and ICH-183, from the exercising requirements of Section XI. The licensee .

has demonstrated that due to plant design the only method available to verify valve closure (their saf ety related position) is during leak testing. These valves are not equipped with valve position indicatorn and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing f requency of verif ying valve closure during the perf ormance of leak rate testing at refueling outages should demonstrate proper valve operability.

c. Relief Request The licensee has requested specific relief 1 om exercising Category A/t Valve ICH-170, reaci2r coolant system fill line isolation check, in accord nce with the requirements of Section XI and propos'J to verify valve closure (its saf ety related position) during refueling outages.

Co.de Requi renient Ref er to valve testir.g paragraph A. 2.

L icensee'<, Basis f or Requestina Relief .

This check valve is normally closed during power operation and is required to remdin closed to f ulfill its safety function. Relief from quarterly exercising 20

of this check valve at power is requested because exercising would thermal shock the RCS piping. Also due to a lack of installed instrumentation, relief is requested f rom cold shut exercising. This valve is full stroke cxercised at refueling per OST 1.47.37.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C Valve ICH-170 f rom the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (its safety related position) is during leak testing. This valve is not equipped with valve position indicators and some of the required test connections are located inside the containment. We (onclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at ref ueling outages should demonstrate proper valve operability.

d. Relief Pequest The licensee has requested specific relief from exercising Category A/C Valve ICH-369, pressuce relief chect around MOV-CH-378, in accordance with the requirements of Section XI and proposed to verify valve closure (its saf ety related posit:en) during ref ueling outages.

~

Eode Reauirement

- Refer to valve testing paragraph A. 2.

21

Licensee's Basis f or Requesting Relief This valve is nonnally closed at power operation and required to remain closed to fulfill its safety f unct i on . Since it is a passive valve with no permanently installed instrumentation, relief f rom ,

quarterly and cold shutdown f ull stroke exercising is requested. This valve i' f ull stroke exercised during leak rate testing done a. refueling per OST 1.47.18.

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted f or Category A/C passive Valve ICH-365 f rom the requirements of Section XI.

This valve is in its safety related position and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

Therefore, the operability of this valve is inconsequential with regard to t he saf ety f unction which it performs. We conclude that verif ying valve closure dJring leak testing at ref ueling shoJld demonstrate proper valve operability.

e. Relief Request The licensee has requested specific relief from exercising Category A valves MOV-lCH-30BA, B, and C and MOV-lCH-378 and 381 (RCP seal water isolations) in accordance witn the requirements of Section XI, and proposed to full stroke exercise these valves during .

cold snutdowns that RCPs are secured and et least once ea.h refueling outage. .

22

Code Requi rement Refer to valve testing paragraph A.2.

Licensee's Basis f or Requesting Relief These valves are open during power operation but are required to close to perf orm their safety f unction.

Closing either of these valves during power operation would secure seal injection water to the RCP seals resul:ing in seal damage. Therefore, relief from quarterly stroke exercising and timing is requested.

These valves will be stroke exercised and timed during cold shutdown and ref ueling when RCPs are secured per OST 1.1.10.

Evaluation

. We agree with the licensee's basis and, therefore, feel thet relief should be granted f or Category A val ves MOV-1CH-30BA, B, and C and MOV-1CH-378 and -381 t rom the exercising requirements of Section XI. The licensee has demonstrated that f ailure of either of these valves in the closed position during power operation or cold shutdowns that RCPs are running would res ul t in seal damage resulting in loss of the RCP until repairs could be perf ormed. We conclude that exercising these valves during cold shutdowns that RCPs dre secured a'id at least once eacn ref ueling outage should demonstrate proper valve operability.

23

2. Category B Valves

d. Relief Reques t The licensee has requested specific relief f rom exercising Category B Valves HCV-lCH-105 and HCV-lCH-110, boric ac id recirculation hand control valves, in accordance with the requirements of S ec t i on X I .

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief Triese are passive Category B valves and are not .

required to change position to perf orm tht ir intended saf ety f unction. Nonnal position is shut during power ,

operation.

Ev.aluation We agree with the licensee's basis, and theref cre feel relief should be granted f or C ategory B, passive Valves HCV-lCH-105 and HCV-1CH-110 f rtra the requ i rements of Sec t i on X I . These valves are in their saf ety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequeritial with regard to the safety function which tney perform. We conclude that the quarterly stroke and stroke time measurements are meaningless f or passive valves.

24

3. Category C Valves;

a. Relief Re_ quest The licensec has requested specific relief from exerc ising m a tegory C Valves 1CH-22, ICH-23, and 1CH-24, charging pump discharge checks in accordance wIth the requirements of SecLion XI and proposed to f all st roke exercise these valves during ref ueling outeges and pertial stroke exercise these valves during power operation.

Code Requirement Refer u valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief Ttie design function of this check valve is to prevent reverse flow daring pump shutdown and to stroke full open f or saf ety analysis f'i'cw. Relief from quarterly exerc ising is requested because no flow paths exist but the design path to f acilitate the 500 gpm design flow.

Relief is al sc requested f rom cold shutdown exercising due to the generation of additional radioactive waste f run the Doration to verify f ull flow conditions. A f ull flow t e s t. cf thew valves is conducted at rcf ueling to verify f all stroke exercise open per OSI 1.11.14 6

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted f or Category C .

Valves ICH-22, ICH-23, and ICH-24 f rom the exercis ing requirements of Section XI. The licensee has ,

demonstrated that the only available path for full stroke exercising tnese valves is through the safety injection / BIT into the RCS. During power operation injecting highly borated water would cause power transients that could result in a reactor trip. During cold shutdown, injecting highly borated water could result in a delay of reactor startup due to the ex tensive boron cleanup i equirement to return plant water chemistry to startup specifications. We c')nclude that full stroke exercising these valves during refueling outages should demonstrate proper valve operaDility.

D. Residual Heat Removal

1. Categor_y A/E Valves Relief Request The licensee has requested specific relief f rom exerc ising C ategory A/E Valves 1RH-14,1RH-15, and 1RH-16, inside and outside RHR :.;r,tainment isol at i ons , in accordance with the requ i rements of Section XI .

Code Requirement ,

Refer to valve testing paragraph A. 2.

26

Licensee's Bas is f or Requesting Relief These valves are passive normally shut containment isolations that are not required to change their position to f ulf ill their saf ety f unction. In addition, the valves are adminir,t;atively controlled with respect to the "as left" position. Theref ore, relief is requested from quarterly and cold snutdown e>.ercising. A valve full stroke verification

- completed at refueling per leak te st OST 1.47. 20.

Evaluation We agree with the licensee's basis, and therefore feel re l i ef should be granted f or Category A/E passive Valves 1RH-14, IRH-lb, and 1RH-16, f rom the requirements of Sec ti nn XI . These valves are in their safety related

. position and are rot required to open or close to mitigate tne consequences c' a accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which tney perf orm. We conclude that the quarterly stroke and c.trose time measurements are meaningless f or passive valves.

L' . C a tygory B Va l vt s Re I i e f Rgu- s t The lic.nse. nos reqx s ted spec if ic relief f rom exercising C a tegory U Val ves WJV-It!H-700, MOV-lRH-701, MOV-!RH-720A, and MOV-lRH-7?OB, RHR inlet and outlet isolations, in accordante with ths requirements of Section XI and proposed to exercise tncs valves during refueling outages.

27

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis f or Requesting Relief Cycling these valves cauld subject the Residual Heat Removal System to pressure greater than design. These valves are normally clcsed ano de-energized during power operat ions and required to 'a closed during an accident condition.

Tnerefore, relief is requested during power operations and ruld shu tdown.

NOTE: esa valves ar+ exercised but not timed each siint cooldown or heat up f rom colo shatdor or aoplicable plant startup and sh,itdown L.

Ybese valves are exercised and timed i. o. e wi th OST 1.10.4 Res i dual Heat Re<r.ov 31 5, refueling "alve exe cise testing. -

Evaluation We egree with the licencee's basis, and therefore feel relief should be granted f or Category B, passive Valves MOV-lRH-700, MOV-lRH-701, and MOV-1RH-726 A and B f run t he req a i rem en t s of S ec t i on XI . These valves are in tneir safety related position and are not required to open rr close to mitigate the censequences of an accident or safely thut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly .

stro(e and stroke time measuremtnts are mearingless f or passive valves. ,

23

E. Saf ety Inj ec tion

1. Category A/C and A/E Valves Re lief Request

a. Tne licensee has requested specific relief from exercising Category A/C Valves 151-10, 151-11, and 15I-12, LHSI neader cnecks, and 151-13 and ISI-lo, i t.s i de c on t a i nm en t isolation header checks, in

.:cordance with the requirements of Section XI and proposed to full stroke exercise these valves at ref ue ling ou t ages.

C ae Requ ement Refer i J salve testing paragraph A. 2.

. Licensee's B_ asis f or Requesting Relief Thest v a l v e r, tre normally shut during power operation L:u t required to open to f ulfill their saf ety f unction.

Due to tne lack of installed instrumentation and rel at ive system pressures, relief f rom quarterly f ull or part stroke exercising is requested. In addition, relief is requested f rom f ull or partial stroke exercising at cold snutdown due to the generation of adjitional red waste by the additional boration required to verify a full flow condition through the LHS1 inj e: tion flow path. A full flow stroke exercise

, for tnese valve , will be perf ormeJ at ref ueling per OST 1.11.10

Evaluation We agree with the licensee's basis and therefore ' eel e

relief should be gro .ted f or Category A/C Valves 151-10, 151-11, 151-12, 15:-13, and 151-14, from the exercising requirements 'Section XI. The licensee has demonstrated that these valves cannot be exercised during power operation because the LHSI pumps cannot overcome RCS operating pressure. During cc,d shutdown exercising these valves would inj ect highly borated water into the RCS that could result in a delay of rear tor startup due to L..e extensive clednup required to r eturn RCS watei chemistry to startop sp ec i f ic a ti ons . We conclude that full stroke exercis ing these valves during ref ueling outages should demcnstrate proper valve operability. ,

b. Retief Reauest The licensee has requested spec ific relief f rom exercising Category A/C Valve 15!-02, inside containment isolation on accumulator fill line, in accordance with the requirements of Sec tion XI and proposed to verify valve closure (its safety related pasition) d; ring refueling outages.

Code Requi rement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief

• This valve is shut during power operation and is

• required to be shut to fulfill its saf ety f un_ tion which is contai' nent isolation. It is not required to 30

change position at all except when filling S.I.

fccumulators. Relief is requested from quarterly and cold shJtdown f ull or part stroke ele #cising beCause testing would be meaningless. In acdition, no ins t alled instrumentation ex ists. This valve will be

. exercised at refueling during leak rate tes ting per O ST 1. 4 7 .19.

Evaluation We agree with the licensee's basis and therefore feel relief should bc granted for Category A/C Valve 151-42 f run the exercising requirements of Section XI. The licensee has demonstrated t,1at due to plant des! the only method .wailable to verify valve closure (its saf ety related position) is dJring leak testing. This valve is not equipped with valve position indicators and sar,e of the required test connections are located inside the containment. We conclude that the proposed al ternate testing f requency of verifying valve closure during the perfonnance of leak rate testing at refueling outages should demonstrate proper valve operability.

c. R ' l i et Request The licen'2e has requested specific relief from exerc ising C. tegory A/C Valves 151-43, 15I-49, and 151-50, accumJ ator dische ge checks, in accordance wit h the requirem5nts ;f Section XI and proposed to part i .1 st roke exercise these val;es during cold snutloen 3nd leak test these VSlves during refueling oJtales.

31

Code Requiroment Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief This valve at power operation is shut but required to be open f or a low pressure accident requiring passive injection for core cooling to fulfill its safety f unc t i on. Relief from full stroke t xercising at any mode of op; ration and cart stroke exercii n3 at power is requested due to high differential pressure, lack of installed instrumentation and an uncontrolled test volume change required to simulate saf ety analysis flow. These valves will be part stroked at extended cold shutdowns per OST 1.11.15 and leak tested per OST ,

1.11.4.

Evaluation We agree with the licensee's basis and tnerefore feel that temporary relief should be granted for Category A/C Valves 151-48, 15I-49, and 151-50 from the exerc ising requirements of Section XI during power operation and cold shutdown. The licensee has demonstrated that dJring power operation these valves cannot be exercised because accumulstor pressure cannot overcome RCS operating pressure. During cold shutdown, exercising these valves with accumulator flow could resul t in a low temperature over-pressur izati 7n of the We also agree that full stroke exercising these RCS.

valves with accumulator flow dJring refueling outages with the vessel head removed to provide an adequate -

expansit volume could resul t in internal core damage 32

bec ause of t he exc essive flow rates. h'e conclude that with the present piping configurations, only partial stro<e exercising of these valves is possible.

However. we reccamend that the utility further investigate a method to full stroke exercise these valves (i.e. manual exercising during refueling

. outages).

d. Relief Request The licensee has requested spec ific relief from exerc ising Category A/C Valves 151-51, 151-52, and 15I-53, reverse flow preventers f rom the RCS to the accumulators, in accordance with the requirements of Section XI and proposed to partial stroke exercise these valves dJring Cold shutdown and leak test daring refueling outages.

Code Requi remerg Refer tu velve testing paragraph A. 2.

Licens c's Basis for Requesting Relief These valves at power operation a e shut but required to be apen f or a low pressure passive injection for core c ; ling to fulfill it s safety f unction. Relief from full s tr. < e e(erc is ing at any mode of opera tion anJ partial stroke exercising at [ower is requested dJe to differential pressure considerations, lack of installed instrumentation required to simulate safety coalysis flow and uncontrollable test volume changes.

These valves are part stroke exercised with operation of the RHR nt cold i hut downs. These valves ar e also leak checked at a refueling frequency per OST 1.11.4.

33

Evaluation We agree with the licensee's basis and therefore feel temporary relief should be granted for Category A/C .

Valves 15I-51,151-52, and 15I-53 f rom the exercising requirements of Section XI. The licensee has demonstrated that the valves cannot be exercised during power operation because accumulator pressure or LHSI flow cannot overcome RCS operating pressure. During cold shutdowa these valves are partial stroke exercised with RHR flow. These valves cannot be full stroke exercised during cold shutdown because accumulator flow could result in a low temperature overpressurization of the RCS. We also agree that f ull stroke exercising these valves with accumulator flow during refueling outages with the vessel head removed to provide an adequate expansion volume could result in internal core .

damage because of the excessive flow rates. We conclude that with the present piping configurations, .

only partial stroke exercising of these valves is possible. However, we recommend that the ut ility further investigate a method to full stroke exercise these valves (i.e. manual exercising curing ref ueling ou t ages ) .

e. Relief Request The licensee has rcquested specific relief f rom exercising Category A/C Valves 151-33 and 15I-84, HHSI recirculation to hot leg inside containment isolation checks, ia accordance with t he requirements of Section XI and proposed to full stroke exercise enu leak test at ref ueling outages.

34

Code Requi rement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief These valves are normally shut during power operation but are requirec to open to fulfill their safety function. Due to the lack of installed instrumentation and relative system pressures, relief from quarterly full or part stroke exercising is requested. In addition, relief f rom cold shutdown full or partial stroke exercising is requested due to the increased RCS noration required that would necessitate processing a large volume of RCS water. Waste processing could result in ;ncrased dcwn time and more generation of red waste. A full flow stroke exercise for these valves will be perf ormed at ref ueling per OST 1.11.14.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted f or Category A/C 151-83 and 151-80 f rca the exercising requirements of Sec t ion XI . The licensee has demonstrated that these valves cannot be full stroke exercised during power operation Decuse the HHSI pumps cannot overcome RCS operating pressure. Partial struke exercising would resul t in thermal shocking of the injection nozzles.

Exercising these valves during cold shutdown with highly borated water could delay reactor startup due to the extensive cleanup required to return the RCS water t o st art up spec if ications. We conclude that full

. stroke exercising these valves during refueling outages should Jemonstrate proper valve operability.

35

f. Relief Request The licensee has requesteo specific relief from exerc ising Category A/C Valves 15I-94 and 151-95, ,

inside containment isolation checks for the BIT and fill header, in accordance with the requirements of .

Section XI and proposed to full stroke exercise and leak test these valves during ref ueling outages.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief These valves are normally At during power operation but are required to open to f ulfill their safety function. Due to the lack of installed instrumentation and relative system pressures, relief from quarterly ,

full or part stroke exerzising is requested. In addition, relief from cold shutdown full or partial stroke exercising is requested due to the increased RCS boration required that would necessitate processing a large volume of RCS water. Waste processing could result in increased down time and more generation of rad waste. A full flow stroke exercise for these valves will be perf onned at ref ueling per OST 1.11.14.

Evaluation We agree with the licensee's basis and therefore feel ,

that relief should be granted f or Category A/C 151-94 and 15I-95 fran the exercising requirements of S ec t i on X I . The licensee has demonstrated valves 36

cannot ce f ull s roke exercised during power operation beCduse tne HHSI pum's cannot overcome RCS operating pressure. Partial stroke these valves exercising would result. in reactivity excursions from BIT injection nozzles that could result i a reactor trip.

Exercising these valvet during cold shutdown with highly borated water could delay reactor startup due to the estensive cleanup required to return the RCS water to s t art up specifications. We conclude that full stroke exercising these valves during refueling outages shoulc demonstrate proper valve operability,

g. Relief Request The liccnsee has requested specific relief from exerc ising Category A/E Valve 151-41, accumulator fiil

, line isolation in accordance witn the requirements of Sectico XI and proposed to leak test this valve at refueling outages.

Code Requi rement Refer to valve testing paragraph A. 2.

Litensee's Basis for Requesting Relief Relief from qaarterly ano cold shutdown full or part stroke exercising is requested because this is a manual pr,sive valve and its normal position is closed. Also its safety related position is closed and testing would be meaningless.

This valve will be leak rate tested at refueling per 05T 1.47.19.

37

Evaluation We agree with the licensee's basis, and therefore feel relici should be granted for Category A/E, passive .

Valve 151-41 fran the requirements of Section XI. This valve is in its safety related position and is not ,

r -;uired to open or close to mitigate the consequences of an accident or safely shut down the plant Therefore, the operability of this valve is inconsequential with regard to the saf ety function which it perfocms. We conclude that the quarterly stroke and stroke time measurements are meaningless for a passive valve.

2. Category C Valve

a. Relief Request The licensee has requested specific relief f)om .

exercising Category C Valves 151-1 and 151-2, LHSI pump suction checks from the containment sump in a'_co,Udnce with the requirements of Section XI and proposed to physically inspect ano manually exercise the check valve discs during ref ueling outages.

C ode R_e_q_u i rem en t Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief These check valves, at power operation, are in their intended design position and ranain closed. Any type ,

of stroke testing would violate containment integrity.

To fulfill its saf ety f unction f or long term core 33

cooling the valve must open. Due to the lack of test instrument tap off s and the feasibility of simulating actual saf ety injection long term cooling water flow f rom the containment sump because of physical limitations, relief from quarterly and cold shutdown exercising is requested.

A maintenance inspection to ohysically inspect these check valves will be performed at refueling to verify proper stroke.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted f or Category C Valves 151-1 and 151-2 from the exercising requirements

. of Sec tion XI. The licensee has demonstrated that due to present piping configuration and test taps that these valves cannot be exercised during power operation or cold shutdown. In addition, flooding the containment sump to provide adequate LHSI pump suction would result in damage to elect-ical equipment inside the con t ainment. We conclude that valve disassembly and manually f ull stroke exercising these valves during ref ueling outages should denonstrate proper valve operability.

b. Relief Reques_t The licensee has requested specific relief froT exerc ising Cr cegory C Valve 151-5, LHSI pumps suction from the RWET, 151-6 and 151-7, LHSI pump discharge checks, and 151-21, LHSI to charging pump suction in 3ccordance with the requirements of Section XI and 39

proposed to partial stroke these valves quarterly and full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A. 2.

License 2's Basis for Requesting Relief These valves are normally shut out to fulfill their saf ety f unction they must open permitting flow f rom the RWST to the LHSI pump suctions. Quarterly the valve is part stroked through surveillance checks bJt full stroke verification requires safety analysis flow.

Theref ore, relief f rom quarterly full stroke exercising

~

is requested due to the lack of test flow capability to simulate safety analysis flow and actual LHSI injectior flow path inaccessability dt.a to pressure differentials. In addition, relief from cold shutdown full stroke exercising in requested dJe to the generation of additional radioactive waste by the additional boration required to verify a full flow condition through the LSHI injection flow path.  ; full flow stroke exercise for these valves will be performed at refueling per OST 1.11.14.

Evaluation We agree with the licensee's basis ind therefore feel that relief should be granted f or Category C .

V al ves 151-5,151-6,151-7 and 151-27 f rom t he exercising requirements of Se: tion XI. The licensee ,

has demonstrated that the only full flow test path is into the RCS and that the LHSI pumps cannot overcome 40

RCS operating pressure. Partial stroke exercising during power operation is accomplished during the LHSI pump testing on a recirculation flow path. During cold

. shutdown exercising these valves would inject highly borated water into the RCS which could result in a delay of reactor startup due to the extensive cleanup requirements to return the RCS water to startup specifications. We conclude that full stroke exercising these valves during refueling outages should demonstrate proper valve operability.

c. Relief Request The licensee has requested specific relief from exerc ising Category C Val ves 151-15, ISI-16,151-17, 151-20, 15I-21, 151-22, 151-23, 1S1-24, 151-25, 151-100, 151-101, and 151-102, safety injection to RCS header checks, in accordance with the requirements of

, Section XI and proposed to f sll stroke exercise these valves during refueling outages.

C odejleq u i rem en t Refer 1 valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief These valves are normally shut during power operaticn but are required to open to fulfill their safety function. Due to the lack of installed instrurmotation and relative system pressures, relief f rom quarterly full or nart stroke exercising is requested. In addition, relief from cald shutdown f ull or partial stroke exercising is reqJested due to tne increased RCS boration required that would neccssitate processing a 41

large volume of RCS water. Waste processing could result in ;ncreased downtime and more generation of rad waste. A full flow strcke exercise for these valves ~

will be performed at refueling per OST 1.11.14.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted f or Category C Valves 151-15, 151-16, 151-17, 151-21, 15I-22, 151-23, 151-24, 1SI-25, 151-100, ~51-101, and 151-102, from the exercising requirements of Section XI. The licensee has demonstrated that these valves cannot be exercised during power operation because the safety injection pumps cannot overcome RCS operating pressure.

Exercising these valves during cold shutdown would .

inject highly borated water into the RCS and could result in a delay of reactor startup due to the extensive cleanup required to return the RCS water to startup sp9cifications. We conclude that full stroke exercising these valves daring ref ueling outages should demonstrate proper vaive operability.

F. Containment Vacuum and Leakage _

1. Category A and A/E Valves

a. Relief Request The licensee has requested specific relief from

+

exercising Category A/E Valses HCV-1CV151 and HCV-1CV151-1 inside and outside containment isolations f or vacuum air ejectors, in accordanco with the ,

requirements of Section XI.

42

Code Requi rement Refer to valve testing paragraph A. 2.

L icensee's Basis f or Requesting Relief These valves are shut at power and are passive manual valves not required to change position to fulfill their s af ety f unc tion.

Evaluation We agree witn the licensee's basis, and therefore feel relief should be granted f or Category A Valves HCV-lCV151 and HCV-1CV151-1 from the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless f or passive valves.

b. Relief Request The licensee has requested specific relief from exercising Categery A/E Valves 1CV-35 and ICV-36, i ns i de and ou ts i &_ con t a i n:r en t isolations for the sealed pressure system in accc 2nce with the

, requirements of Section XI.

C oJe Requ i rem er[t_

Refer to valve testing paragraph A. 2.

43

Licensee's Basis f or Requesting Relief These valves are manual passive valves shut at power and are required to be shut to fulfill their safety f unc tion. Relief, theref ore, is cequested f rom f uli or parti al st, ' exercising at power or cold shutdowns.

• Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A Valves ICV-35 and ICV-36 f rom tne requirements of Section XI. These valves are in their saf ety related p asition and are not required to open or close to mitigate the consequer.ces of an accident or safely shut down the plant.

Theref ore, the operability of these valves is ,

inconsequential with regard to the saf ety f unction which they perform. We _onclude that the ruarterly stroke and stroke time measurements are meaningless for nattivo valves.

G. Component Cooling

1. Cat _egorLA and A./E Valves

a. Relief Request The licensee has requested specific relief from exercising C+tegory A/E Valves ICC-247, ICC-243, ICC-251 and ICC'252, component cooling water to and f rom RHR heat exchangers, in accordance with the requirements of Section XI.

44

Code Requi rement Ref e: to valve testing par ? graph A. 2.

Licensee's Basis for Requestirlg Relief These cassive valves are not required to change positior to f ulf ill their safety f unction. These valves are exercised during cold shutdowns.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted f or Category A Valves 1CC-247, ICC-248, ICC-251 and ICC-252, from the requirements of S ec t i on X I . These valves are in their safety related pos i t ion ana are not required to open or close to mitigate the consequences of an accidnet or safely shut down the plant. Therefore, tho operability of these val ve s is inconsequential with romard to the safety function whicn they perform. We conclude '. hat the quarterly streke and stroke time measurements are meaningless for passive valves.

ti . Relief Pgquest The licen,w has requested specific relief from exerc is ma C ategory A valves TV-1CC103A, TV-1CC103A1, TV-1CC10JD, TV-1CC103B1, TV-1CC103C, TV-lCC103C1, TV-1CC105A, lV-lCC105b, TV-lCC105D1, TV-1CC105D2,

, TV-1CCIO5El, TV-1CC105E2, TV-1CC107D1, TV-1CC107D2, TV-1CC107El, TV-1CC107E2, component cooling supply and

, ret urn to RCPs cont ainment isolations, in accordance wit h t he requirements of Section XI and proposed to 45

full stroke exercise these valves during cold shu; downs that RCPs are secured and at least once each refueling octage.

_ Code Requi rement 4

Reter to valve testing paragrpah A.2.

L_iconsee's Basis f or RequestinL R elief Stroking any of these valves with the associated RCP running would cause severe 4 mage to the pump bearings, stator, and thermal barriers if the affected valve would f ail to reopen. Therefore, relief is requested from f ull or partial stroke e>:eccising these valves during power operation and cold shutdowns when RCPs are ,

running.

s Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted f or Category A salves TV-1CC103A, TV-1CC10?A1, TV-1CC103B, TV-1CC103B1, TV-1CC103C, TV-1CC103C1, TV-1CC105n, TV-1CC105B, TV-1CC105D1, TV-1CC105D2, TV-1CC105E1, TV-1CC105E2, TV-1CC107D1. TV-1CC107D2, TV-1CC107E1, TV-1CC107E2, component cooling supply and return to RLPs cont ainment isolations, f rom the exercising requirements of Section XI. The licensee has demonstrated that f ailure of any of these valves in the closed position dt: ring power operation or cold shutdowns that RCPs are running would result in severe damage to the RCP bearings, stator, and/or thermal barriers resul ting in loss of the RCP until repairs could be perf ormed. We conclude 46

that exercising these valves during cold shutdawns that RCPs are secured and at least once each refueling outage should demonstrate proper valve operabilit3 .

2. Categery B Valves e

a. ne'ief Request Thc licensee has requested specific relief from exerc ising Category B valves TV-1CC107A, TV-1CC1078, and TV-1CC10iC, component coolin.1 to RCPs trip valves, in accordance with the requirements of Section XI and proposed to full stroke exercise these valve. dur.ng cold shutdowns that RCPs are secured and at least ance

>ach refueling outage.

Code Requi reme_nt

' Ref er to valve tes ting paragraph A.2.

Licensee's Basis ;or Requesting Relief 5trokirig any of these valves with the associat ed RCP running would cause severe damage to the pump bearings, stator, on t thermal barriers if the af f ected valve would f ail to reopen. Theref ore, relief is requested from f ull or partial stroke exercising these valves during pon2r operation and cold shutdowns when RCPs are running.

Evaluatior; We agree '.vith the licensee's basis end, therefor , feel

': h a t relief should be granted f or Category B valves TV-lCC10/A, TV-1CC107B, anJ TV-1CC10/C, component 47

cooling to RCPs trip valves, f rom the exercising requirements of Section XI. The licensee has demonstrated that f ailure of either of these valves in the closed position during power operation or cold ,

shutdowns that RCPs are running would result in severe damage to the RCP bearings, stator, and/or thermal barriers resulting in loss of the RCP until repairs could be performed. We conclude that exercising these valves during cold snutdowns that RCPs are secured and at least once each refueling outage should demonstrate proper valve operability.

H. Fuel Pool Cooling and Purification

1. Category A/E Valses Relief Request 9

The licensee has requested specific relief from exercising Category A/E Valves 1PC-9, IPC-10,1PC-37, and IPC-38, f uel

• pooling cooling and purification containment isolations, in accordance witn the requirements of Section XI.

Code Requi rement Refer to valve testing paragraph A. 2.

L icensee's Bas i s f or Requesti ng_ Relief Relief is requested f rca power and cold shutdown f ull or part strose testing because these are nonmally shut, manual passise containment isolation valves and tneir safety p us i t i on is shut. T1ese valves will be leak tested during ref uel ing out ages.

43

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted f or Category A/E Valves IPC-9, IPC-10, IPC-32 and IPC-38 f rom the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate tne consequences of an accident or safely shut down the plant. Theref ore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stronc and stroke time measurements are meaningless for passive valves.

I. M3in Stegn

1. C_at_egory C Valves

a. R_el i ef _R_eque s t e

The licensee has requested specific relief fron exercising Category C Valves 1MS-80, IMS-81, and IMS-82, Icop A, B, and C residt,1 heat release reverse flow chec(s, in accordance with the requirements of Section XI and proposed to manually disassemble and exerc ise t hese valves during ref ueling outages.

Code Requi rement Refer to valve testing paragraph A. 2.

Licensee's_ Bas is _f or Reques ti ng Rel ief Reliaf is requested f rom at power and cold shutdown full stroke testing because there is no installed 43

instrtrnentation to check f or reverse flow and the headers are normally cross connected and pressurized.

No way exists to isolate and systematically check operat ion of these valves. A maintenance inspection to -

di-; assemble and check f ull stroke exercising will be perf ormed at refueling outages. ,

Evaluation We agree wi th t he licensee's twis and theref ore f eel relief shoald be granted f or Category C Valves IMS-SD, IMS-81, and IMS-82 f rom the exercising requirements of Section XI. These valves are not eqJipped with position indicators and no other instrumentation is installed thit could indicate valve position. The licensee has demonstrated that due to plant design the only met ho.1 availaole to verity valve position and exerc ising is visually and manually. We conclude t hat valve Jisassembly with a visual inspection and a manual f ull stroke exercise during ref ueling outages should verify valve operability.

J. R i ver Water

1. Cat gory C Valves

a. R.liet Requqt.

The licensee has reqwsted specif ic relief from exerc is ing C ategory C Valves 1RW-197, and 1RW-193, r er wat er reverse flow d.acks, in x.cordance with the requiremcnt' :f Sec ti on /I and proposed to partial stroke er,ercise these valves during refueling catages.

50

Code Requi rement Ref er to valve testing paragraph A. 2.

. Licensee's Basis for Requesting Relief These valves are nonnally shut at power operation but are required to open to f ulfill their safety f unction.

Relief from quarterly and cold shutdown full stroke exercising is requested due to rendering the entire river water system inoperable to f acilitate maintenance to renove t he checks for visual inspection. There is no existing instrumentation to verify check valve position. These valves are partial stroked at ref ueling outages through flow chacks on the

, rec ircul ation spray heat exchangers.

Evaluation e

We ag: ce with the licensee's basis and therefore feel temporary relief should be granted f or Category v Valves 1RW-197,. and 1RW-198 f rom the exercising requi rements of Sec tion XI. The licensee has demonstrated that due to present plant design these redundant parallel valves cannot be individually exercised. In addit ion, no instrumentation is installej that could assure each valve is f ull stroke exercised. Tneref ore, only parti al stroke exercising is possible. The river water system is required for reactar power operation, cold shutdown and refueling e

outages. Thus, these valves cannot be removed from the system and manually exercised. We conclude that due to present plan; design the only available test is partial 5 troke exercising through the recirculation spray heat e (c n an gers . However, we f eel the licensee shouid 51

further investigate a method to f ull stro:e exercise each valve.

K. Po i j2l DBA Control _

l. Cat _eg1ry A/C Valy;s ,

a. Relief Request The licensee has requested specific relief from exercising Category A/C Valves 1HY-119 and 1HY-120, recombiner containment isolation checks, in accordance with the requirements of Section XI and proposed to f ull stroke exercise these valves during refueling outages.

Code Requi rement .

Ref er to valve testing paragraph A. 2.

L icensee's Basis f or Requesting Reliet These check valves are shut at power and are required to remain shut at the onset of the postulated accident to fulfill their safety function. Relief from quarterly and cold shutdown f ull or part stroke exercising is requested due to inaccessibility of tn-valves inside containment and the need f or extensive rigging t o get near the val ve. These valves are full stroke exerc ised dJring ref ueling out ages.

E v al u a t i on ,

We agree wi t h t he licensee's basis and theref ore f eel ,

relief should be granted f or Category A/C Valves 1HY-119 and 1HY-120 f rom the exercising 52

requi rements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (their safety related position) is during leak testing. These valves are not equipped with valve position indicators and some of the required test connections are located inside the containment. We conclude that the proposed al ternate testing f requency of verifying valve closure during the perf ormance of leak rate testing at ref ueling outages should demonstrate proper valve operability.

?. Category B Valves

a. Relief Request The licensee has requested specific relief f rom exercising Category B Valves MOV-1HY201A and

, MOV-1HY201B, 2 H recombiner flow regulating valves, in accordance with the requirements of Section XI and proposed to exercise these valves every 6 months.

Code Requi rement Ref er to val ve tes ting paragraph A. 2.

L ic_ensee's Bas i s f or Reques ti ng Rel ief Relief is requested from quarterly f ull or part stroke testing of these valves because they are an integral part of the HyJrogen Recombiner. It is presently

, tested every six months during normal operation. These valves cannot be physically observed, but operation is

, checked by virtue of the valve maintaining a specific f1ow. Inese valves will - exercised every six months.

53

E val ua t i on We do not agree with the licensee's basis and therefore feel relief should not be granted for Category B Valves M3y-lHY201 A and MOV-1HY201B from the exercising requirements of Section XI. The licensee has not provided a specific technical basis for not exercising these valves quarterly. We conclude that these valves a should be exercised quarterly and this test methon

. should dtmonstrate proper valve operability.

E i

54

V. A t t a chm en t__I_

The f ollowing are Category A, B, and C valves that meet the require mts of the ASME Code Sec tion XI and are not f ull stroke exercised every three montns durir.g plant operation. These valves are specifically identified by the owner and are f ull stroke exercised

> during cold shutdow;s and ref ueling outages. EG&G has reviewed all val ves in t h is att actrnent and aarEes with the licensee that testing tnr -

valves during power operation is not possible dJe to the v31.2 type and location, systim design, or because. this action would place t he pl ant in an uns af e condi ti on. We feel these valves should not be exercised d ring power operation. These valver, are listed below at,d grouped accarding to the system in which they are located.

A. Chemicli and Volume Control I. Category A Valse MOV-CH-142, residua; heat removal letdown

, to cnemical and volume centrol isolation, cannot be exercised curing power operation. Daring power operation

, this velve is snut and is not required to change position to f ulf il l its saf ety f unction. It is a passive valve and opening it during normal operation of the plant would divert riorm ai letdcwn back into tne RHR system and cause an overpressure condition to exist. Therefore, relief frvi norm al three month excrcising is being requested. This calve aill be stroke exercised sad timed at each cold shutdown per OST 1.1.10.

2. C atennry A Val ve FCV-lCH-160, reac t or coolant system fill heeder isolat ion, need not be exercised daring power operation. This valve is a normally closed passive cont a i nment isol at i on val ve and i s r,0! required to change

, position to f ulfill its saf ety f unction. During cold shutdown this vilve will be strol.ed and timed per OST 1.1.10.

55

3. Category B Valves MOV-lCH-115C and E, volume control tank it.olations cannot be exercised during power operation.

lhose valves are normally open during power operation and shutting them would isolate the Volume Control Tank f rom the Charging Pumps This would result in a loss of normal

~

Reactor Coolant System makeup and Reactor Coolant Pump seal injection water causing possible punp damage and system j~ gradation. These valves will be exercised and timed per a OST 1.1.10 during cold shutdowns.

4. Category B Valve MOV-lCH-311, pressurizer alternate spray valve, cannot be exercised durir.g power operation. At power operat ;on this valve is shut and is required to be shut to perfona its saf ety 'unc tion. Opening this valve at power operat ion would thermally shock the spray nozzles, exceed tne 320F T, and c ause =n uncantrolled pressure transient.

Therefcre, relief from quarterly stroke exercising and timing is requested. This vaile will be f ull stroke e>:ercised anc timed at each cold shutdown and ref ueling per

• 05T 1.1.10.

E Category r. Valve ICH-141, emergency osration line non-return check, cannot be exercisea during power operation. Dur'.ng power operation thic valve is shut and the only means to ver if y val ve op.'c ot i on, due to the lack of i ns t alled instrumentation, would be to initiate flow through the emer gency carat i on path. Tnis would cause an undesired power transient that could result in a reactor trip.

T hert:f Ore, relief f rom quarterly f ull strc : testing is requested. This valve will be f Lil stroke tested at eatn told shutdoet per OST 1.1.10.

W

B. Saf ety Inj ec tion

1. Category A V lve 151-91, BIT manual bypass, cannot be exerc ised during power operation. This is a manual passive valve not required to change position to f ulfill its safety f unc tion. This valve is shut at power operation and opening

' f ully or partially would thennal shock the cold leg saf ety injection line nozzles. Theref ore, relief is requested f rom f ull as well as partial stroke exercising at power. This valve will be f ull stroke exercised at cold shutdown and leak tested at refueling per OST 1.1.10 and OST 1.47.70.

2. Category A Valves MOV-1SI-860A and MOV-ISI-860B, LH51 containment suctions, cannot be exerc'.ned during power operation. These valves are containment isolation valves open to containment atmospnere. Failure of tnese valves in the open position dJring power operations testing wndld com prom i so containment integrity. Therefore, relief is requested f rom testing during power operation. These valves

> will be stroked and timed during cold shutdown and leak tested during refueling.

3. vategory A Valves MOV-1SI-857C and MOV-ISI-S67D, BIT outlet containmtet isolations cannot te exercised nJring power operation. These valves are shut at power but required to open to f ulf ill their ;cfety f unction. Opening these valvcs at power would require isolating the recirculation system to prevent possible overpressucization of lowi pressurc piping due to the lack of i ns t r umen t a t i on . With isolation of t he recirculation system the possibility of f ailure to reopen t ne isolation valves could render the BIT inoperable.

Therefore, relief f rom f ull or par'. stroke exercisirig at e power i: 4 crested. These valves will be f ull s t r o t.e merc ised a c old shutdawns and leak tested at ref uelirig.

57

4. Category A /alve MOV-15?-869B, charging header BIT by-pass and MOV-lSI-869A, RCS ho: leg fill, cannot be exe-cised during power operation. This valve is shut at power and is no' required to change position to fulfill its safety f unction at the onset of the accident. Only during the simul;aneous coif and hot leg recirculation phase is the valve opened. In addition, thermal stressing of the hot leg e injection nozzles would occur. Theref ore, relief f rom f ull or part stroke exercising of this valve at power is requested. This valve will be full stroked at cold shutdowns per OST 0.1.10 and leak tested at refueling per OST 1.47.9.

5. Category A Valves MOV-1SI-890A and MOV-1SI-890B, LHSI to RCS hot legs, cannot be exercised during power operation. These v3lves are shut at power and remain shut to f ulfill their

,af ety f unc tion. Relief f rom f ull or partial stroke exerc is iag at power is requested due to the possibiiity of overpressurizing the LHSI system caused by f ailure of the up,tream check valve and lack of positive pressure ,

inJication. These valves wi,1 be f ull stroke exercised at cold shutdown per OST 1.1.10 and leak tested at refueling par OST 1.47.52.

6. Category A Valve M3V-1SI-890C, LHSI to RCS cold legs, cannot be exert ised ducing power operat ion. This valve is open during plant operat ion and is required to be open to f ulf iil its saf ety f unction at the onset of the accident. Relief t ram f ull or parti al stroke exercising of this val ve at power is requested Decause f ailure of this vaive to reopen would renJer LHSI cold leg injection from both trains i nop e rab l e. This valve will be f ull stroked at cold snutdown per OST 1.1.10 and refueling leak tested per .

O ST 1.47.53.

58

7. Category B Valves MOV-151 A67A and MOV-1SI-867B, Bli inlet isolationi, cannot be exercised during power operation.

These valves are shut at power operation but are required to open to f ulf ill their safety f unction. Opening partially or f ully at power would dilute the concentration and lower the operating temperature of the (BIT) rendering it inoperabl e per technical specification requirements. Therefore, relief is requested f rom f ull or partial stroke exercising at power. These valves will be full stroke exercised at extended cold shutdowns and ref uelings.

8. Category B Valves TV-1SI-884A, TV-1SI-884B, and TV-1S;-884C, BIT recirculation isolations, cannot be exercised during power operation. These valves are normally open during power operation for boric acid recirculation. Their safety position is shut and closing this valve with subsequent failure to reopen could degrade the Boron Injection System due to acid solidification. Relief from exercising is requested f or the abovc reason during power operation.

• These valves will be exercised and timed during cold shutdown per OST 1.1.16 C. Containment Depressurization

1. Cat egory A/C Valves 1Q5-3 and 1Q5-4, ins ide containment isolation checks f or quench spray headers, cannot be exercised during power operation. These valves are shut at power and open with initiation of quench spray fIow at onset of the accident, and shut af ter containment depressurization is acnieved. Relief from f ull or part stroke exercising tLis valve at power is equested because of physical limit ations, (scaff olding needs to be built to reach these valves) that are located inside the containment. These valves will be exercised during cold shutdowns.

59

2. :a Deg: y A/C Vaives 1RS-100 and 1RS-1Ci, inside containment isol 3 tion c hecks f or outside recircuiation spray lines, cannot be exercised during power operation. These valves are normally shut at power ~out are required to open to f ulfill their saf ety f unction. Due to inaccessibility ,

without ladders or scaff olding, being located inside the s ub-atmospheri conta :nment, aW being dry pipe, celief f rom cart or f ull stroke exercising quarterly is requested.

These valves will be manually f ull stroke exercised during cold shutdowns.

D. Component Cooling

1. Category B Valve TV-NS101, neutron shield tank makeup water i sol a t i on , cannot be exercised during power cperation. This valve is shut at power and is required to remain shut to f ulfill its saf ety f unc tion. Relief f rom quarterly f ull or part ial exercising is requested dJe to the possibility of the valve sticking open and overflowing the neutron shield expansion tank. This valve will be exercised during cold chutdowns. *

2. Category A Valve TV-1CC110F1, cooling water discharge f rom containment air recirculation coolers, cannot be exercised during power operation. Rel ief is requesteo from at power testing because if this valve f ailed to close while being tested, this would iricapacitate the containment cooling system that is nonnally cooled oy chilled water. This valve will be tested at cold shutdown. Tnis valve will be f ull stroke exercised during cold si utdowns.

i 60

3. Category A Valves TV-1CC111 A1, TV-1CC111 A2, TV-1CC111D1, and TV-1CC111D2, inside and outside containment isolations f or the CRDM coolers, cannot be exercised during power operation. These valves are enrmally open at power operation and are required to close to fulfill their s afety f unction upon a CIB signal. Relief f rom at power part or i

full stroke testing is requested because shutting any of these valves and isolating cooling water, while the 2 actor control or shutt n rods are energized, or the plant is above 250 degrees Fahrenheit, would resul t in component dam age. These valves will be exercised during cold shutdowns.

E. Main Steam

1. Category C Val ves 1MS-18, IMS-19, and 1MS-20, s team driven auxiliary f eed pump reverse flow checks, cannot be exercim1 during power operation. Relief is requestad from quarterly, full stroke and backseat verification because of the

1. (potentially hazardous) environment encountered in the main steam valve roam. These valves are exercised during the monthly OST because it is one of th: ee steam supplies to a steam header. These valves are nonnally closed, but may be required to either open or shut to fulfill their intended purpose. These valves are full stroke exercised during return to power f rom cold shutdown.

2. Category B/C Valves NRV-1MS-101 A, NRV-1MS-101B, and NRV-1MS-101C, main steam non-return checks, cannot be exercised during power operation. Relief is requested f or stroke testing during power operation because it is not a

61

possible to stroke these valves due to both physical restraints (steam flow) and reactor protection (steam break) restraints. These valves will be verified closed during cold shutdown valve exercising. ,

3. Category B Valves PCV-1MS-101A, PCV-1MS-101B, and PCV-1MS-101C, main steam line abnospheric dump valves, '

cannot be exercised during power operatior,. Relief is requested f rom full or part stroke testing during power operation because these manual isolation valves are located in a potentially hazardous area. The manual v?lve could possibly be damaged when being reopened against a 1,000 psi dp. These valves will be f ull stroked and timed at cold shutdown.

4. Category E/C Valves TV-1MS-101A, TV-1MS-101B, and fV-lMS-101C, main steam line isolations, cannot be exercised during power operation. Relief is requested for full stroke testing during power operation because it would cause a possible safety injection and reactor trip. These valves t will be part stroked quarterly during power operation and f ull stroked and timed during hot standoy.

F. Feedwater

1. Category C Val ves 1FW-33,1FW-34, and 1FW-35, auxili ary f eed pump discharge checks, cannot be exercised during power operation. Relief is requested from stroking at power due to thermal shock of auxiliary f eed and main feed interf ace.

Feeding steam generators with cold water would result in large level transients. These valves will be exercised during r.old shutdowns.

62

2. Category C Valves IFW-42, IFW J3, and 1FW-44, auxiliary f eedwater to main feedwater checks, cannot be exercised during power operation. Relief is requested from stroking at power due to thencal shocking of auxiliary f eed and main f eed interf ace. Feeding steam generators with cold water

' would result in large level transients. These valves are f ull stroke exercised during cold shutdowns.

3. Category C Valves 1FW-387, 1FW-388, 1FW-389, 1FW-390, 1FW-391, and IFW-392, auxiliary feedwater redundant header cnecks, canti t be exercised during power operation. Relief is requested 1 om f ull or part stroke testing a: power because of the thermal r hock of auxiliary feed and main feed interf ace. Feeding steam generators with cold water would result in large ievel transients. These valves will be full stroke exercised during cold shutdowns.

J

4. Category B/C Valves MOV-1FW-15 ', MOV-1FW-156B, and 4 MOV-1FW-156C, loop f eedwater containment isolation checks, Cdnnot be exercised during power operation. Relief is requested f rom f ull and part ctroke testing at power because shutting these valves during power operation could cause 3 loss of t eedwater resul ting in a loss of heat sink and a reactor trip. The motor operator associated with this valve i s f or closure with a very small or no dif ferential pressure across the valve; it is not for use at power. These valves will be exerc ised during cold shutdown.

5. Category B Valves FCV-1FW-478, FCV-1FW-479, FCV-1FW-483, FCV-1FW-489, FCV-1FW-493, and FCV-1FW-499, main feedwater flow control and bypcss valves, cannot bo exercised during

• power operation. Relief is requested f rom f ull or part stroke testing at power because shutting these valves at 1

power could CaJ5e a ioss of feedwater resulting in a 1o55 of heat sink and a reactor trip. Tnese valves are backup con t a i nm en t isn'etion "alves. These valves will be full struke exercised during culd shutdown.

63

G. Compressed Air

1. Category A Valve 11A-90 and Category A/C Valve 11A-91, instrument air containment isolations, need not be exercised ,

during power operation. Relief from quarterly f ull or partial st-oke exercising is requested because these valves are passive valves not required to change position to f ulf ill their saf ety f unc tion. These valves are full stroke exercised during cold shutdown.

2. Category A/C Valve 1SA-15, and Category A/E Valve ISA-14, station air containment isolations need not be exercised 6tring power operation. These valves are shut at power and are requireu to remain shut to fulfill their safety f unc t i on. Theref ore, they are classified as passive val /es and relief from quarterly full or partial stroke exercising is requested. These valves are full stroke exercised during cold shutdowns.

4 H. Control Air Vm tilation ,

1. Ca'.egory A Valves IVS-D5-3A, IVS-DS-3B, IVS-DS-SA, and 1/5-05-5B, cont ainment isol ations f or ref ueling purge line ,,

neeJ not be exercised during power operation. These dampers are shJt at power operation and are required to remain shut t a f ulf ill their saf ety f unction. Relief from quarterly f ull or part stroke exercising is requested f or these passive valves not required to change position to fulfill their saf ety f unction. These valves will be exercised nring cold snutuoans.

2. Category A/E Valve IVS-D-5-6, containment vacuum br eak lina isolation, need nat be exerc ised durin power operat'en.

This damper is shut at power operation and required to 64

remain shut to f ulfill its safety f unction. Relief Trom quarterly full or part stroke exercising is requested because of it being a passive valve not required to change position to fulfill its safety function. This valve will be exercised during cold shutdown.

8

3. Category B Valves TV-1VS101A, TV-1VS101B, TV-1VS101C, TV-1VS101D, and TV-1VS101E, control room emergency air bottle outlet isolations cannot be exercised during power operation. These valves are shut at power operation and are required to open to f ulfill their safety f unction. Relief f rom quarterly full or partial stroke exercising is requested due to tha f act that present testing capabilities would possibly violate technical specification bottle pressure requirements. These valves will be full stroke exercised during cold shutdowa.

)

1. Post H DBA Control 2

1. Category A/E Valves 1HY101,1HY102,1HY103,1HY104,1HY110, and lHY111, H recombiner containment isolations, need not 2

be exercised during power operation. These valves are shut at power and are required to remain shut at the onset of the postulated accident to fulfill their safety function.

Relief f rom quarterly f ull or part stroke exercising is requested to prevent violating containment integrity. These valves will be f ull stroke exercised during cold sl.utdown.

a bb

VI. At tactraent II The dr awings listed taelow were used during the course of this review.

9 System Drawing No.

s Reactor Coolant 155A-6 & 155B-6 Chemical and Volume Control 159A-6 & 1598-7 Vent and Drain 169A-6, 169B-5, & 169C-6 Residual Heat Renoval 156A-6 Safety Injection 167A-4 & 167P-4 Cont ainme it Vac. and Leak age Monit oring 168A-5 c on t a i nmen t Depressurization 165A-6 Sample 179A-6, 179B-6, & 179C-5 canponent Cooling 157A-6, 157B-5, 15) -5 &

157D-6 Fuel Poul Cooling 162b4 s

Main Steam 120A-5 Feedwater 124A-6 4

Steam Generatur Blowdown 180A-4 ftux i1i ary Ston 122A-4 Enilled rht cr 129B-1 Ri ser Water 127A-7 Intake Structure 127B-6 Emergency Diesel 151 A-4 Post DBA Hydrogen 150B-6 m

i 66

V II. At t achment III

, A. The following <alves are never f ull stroke exercised or have a testing f requency greater than each ref ueling outage.

1. Valve Test i ng Program

a. E.1.c

b. E.1.d

c. J.1.a B. The following relief requests have insufficient technical basis, and relief is not r ecom ended.

1. Valve Testing Program J

a. K.2.b 1

<P 67