ML19240C002

Inservice Testing Program for Pumps & Valves at Davis-Besse Nuclear Power Station - Unit 1 (Docket 50-346) for Period Nov 1977 Through Nov 1987, Safety Evaluation

ML19240C002
Person / Time
Site:	Davis Besse
Issue date:	03/31/1981
From:	Cook T, Hanek J, Weber D EG&G IDAHO, INC., EG&G, INC.
To:	Shemanski P Office of Nuclear Reactor Regulation
References
CON-FIN-A-6265 EGG-EA-5400, TAC-10985, TAC-111316, TAC-11316, NUDOCS 8104170713
Download: ML19240C002 (35)

Text

EGG-EA-6400 Mrch 1981 SA.tETY EVAiUATION REFORT, INSERVICE TESTING PROGRAM,

, DAVIS-BESSE NUCLEAR POWER STATION - UNIT 1 (DOCKET NO. 50-345) tn. I

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This is an informal report intended for use as a preliminary or working document 2

11C Research and "ecmica Assistance Report g,,,,, ,, ,

U.S. Nuclear Regulatory Commiss mn e OE r tract No. DE- AC07-76ID01570 { E$gG%

B104270 ] b

G p E G r G w..... ,~

e mw t oa a m (319 . 11 79 It4TERIM RF. PORT Accession No _ .. - _ . _ _ .

Report No. E UC-ESddC3 .

Contract .$rogram or Project Tit:e:

Systems Engineering Support Subject of this Docr' ment:

Saf ety Evaluation of the Inserv ce lesting Proc, ram for Pumps nd Valves at thc Da >is-Beste Nuckar Poucr Sta'aa" - Uni t 1 i DncLet No. 50- 3%) for the ."eriod

nemi>er 1977 througP. Novinher 1987.

Type o Decu . ent:

Sofot) f/, a l e.h ti>< Reaar t A rther,5):

T. L Cr ol J. F. Hanet Date of Oc*:ument: J f 6333[Cf] @pd fg{]Ql{gj nara 1 81 N ASSIStahCe Report Responsible NRC Individual and NRC O!! ice or Division:

n. J . Capnuc;i , 'GC- DE

. his cocorront ./as prJpared pnmarily for prelim AMy t,r int;.f al use. ** b as not received p rovai Since triere may be subs'.an'ive changes this dc ment should f ull review and ari' i not be cons:dered fir el EG&G idaho, Ir:C idi.ho f alls. Idaho 834i5 Prepared for .he U.S Nuclear Reg ;'ntory Commission

. Washingtor;, D.C.

Under DOE Contract N7. JE-ACO?-761D31570 NRC FIN No. _f 626b INTERIM REPORi

CONIENP, 1

I. INTPODUCTION ........ ......... ......................... .... ..

11. P UPP T ES i l N G P R O GR AM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  ?

1. A l l S af e t y - R e l a t e d P ump s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

. S a' iy-Related :r st6 l led Spare Pumps

...................... 5 V/1 V E T ES T ! i.G PR O GP AM E . AL U AT I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 ill.

1. r-ev eal Considerations ...................... .............. 7 Tv >t ing of Valves which ?erfon a ,

rb. stare isniation Funct on ......... ................ ,

1.2 I.S ,t Ccdc Secticn XI Pewirements . ................ S

.1 Steci.e Tes*inr, of Cmr*, galus ... .......... . . ... 9 C 5+rne Ta ting of tt or Operated Valves .... ... 9 1.: L C E f.1,06 ReQXit for Relicf to Iest Valves 4

a t C ol d S h u t d own . . . . . . . . . . . . . . . . ........ .. ...... 9 1.6 Changes to the Technical Specifict: vons ............. C 1.1 Safet3-Related Valves ............ .................. 10 i,8 Va.ve Testing at Cold Shutoowns ...................... 10 1.4 C3tegury A Valve Leak Check Requirements for Containment Isoi3 tion Valvet (CIVs) .................. 11

'.10 Application of Appendix J Testing to the IST Program .......................................... 11 1.il Pressurizer Powcr Operat.:d Relief Valves ............. il 1.12 Manual Stop/ Check Val ei, ......... ................. 12

< AllSystems............................................... 12

' 1 M 1 S af et yQiated Pener Operated Valves . . . . . . . . . . . . 12 J. Stea~ Gener ator Secondary System . . . . . . ... . .............. 14 mategory L ,,alves i ,,

.5 . 1 r

4. Statarn and instrument Sir .................. .............. 14 4.1 Category N C valves ..... .. ......................... ic 0 N j i r( gM L '.;ppl y . . . . ..........., ........... . ....,, ...,

. . CataE ry A/C Valves ................ ................. 15

6. Contalnment and Penetratson Rooms .......................... '6 6.I fategory A/C Valves .................................. 16

7. Reactn. Coalant .. . ............................... ...... 17 4i 3 RC Research anc Technica' Assistance Report -

l ~/

.1 Category B Valves ...................................

3. Makeup and Purification .. ................................ 18 8.1 Category A Valves ............ ....................... 18 a.2 Category A/C Valves .................................. lb

9. vecay He6L and Emergency Core Cooling ...................... 19 9.1 CategorySValves................................... 19 9.? Cctegory C Valves .................................... 40

10. Emergency Core Looling, Containment Spray, and

[ Ore flood ............. ........ ......................... (l 10.1 7tegory A/C Valves .................................. 21

1. Comw ,er. . Cooling Water ..... .......... .... ............ 21 11.1 Category ^. Valves .............. ................ .... 2' lI.i L ati.gcry B Vaivec ..................., . .... .... 22

12. Rtc or Coolant System Details ............................. 22 lc.1 Cctegary A/C Valves ............................ ..... 22

13. Service Water . ......................... .............. ... 23 13.1 C5tego v C Valves ........ .......... ............ 23 IV. APPENDIA A .. ............. . .................................. 2-

1. Lode Requiree nts--Volves ... ... .........................

2. Lode r tuu lr emen t s--P umps . . . . ... ........................ 24 V. AliA E thi . ........... ..... .............................. ... 25

1. Dec;y Heat and Emergency Core Cooling . .............. ... c>

l.i Volse's DHll and DHl2 ................................. 25

& . i m l e v.' f a n d m g ., . ........ .... .. ................ . . . . . . . c)

VI. hiTALWLhi 11 .. .. ................. ........................... 26

1. Oln 5tearn .... ...... .. .................................. 20 le l Lateoury C Volves .................................... .'O

. b t tam Generator Seccndary bystem . . . . . . .................... 2 f-2.1 totegury t; Velves .............................. ..... 26

3. Conte 17. rent anc Penetration Rooms .......................... 20 111

_G. C .Researc,1 and .. . ,ecamca, o"

Assistance Report

3.I Categoiy C Valves ...................... ............. 26 4 Reactcr Coolant ................. ..........................

7 4.1 category B Valves .................................... 27

5. takeup and Puri.! cation .................................... 27 5.1 Category A Valves ............................... .... 27

6. Decay Heat and Emergency Core Cooling ...................... 27 6.1 Category B Valves .................................. . 27 6.2  ; a t e g o ry C V a l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 7 (o:ponent Cool;ng Water ....... ................. ...... . 23 7.1 Category A Velves .................................... 28 7.2 Category B Valves .................................... 28 VI1. Al T AfilME NT III ..... ................... .....................

V. a 4IIiAe ns P. Ti N T ALIF LLPf c f 6f fl T4 I V* ..................................................

8 m

iv HC Research and _ec,an.ica Assistance Report

1. INlRUDUCTION Contained herein is a saf etj evaluation of the pump and valve inser vice t est ing (IST) progri,m s@mitted by the loiedo Edisca compar.y en June 27, 19/i, t er its Davis-Besse iciit ' nuclear plant. The progr am app lies to Dar s-Besse Unit I f or the pr. iod Noemer, 19/7, threuyn Novemotr, 1987.

- The working session with Toledo ' tison and Ddvit-Besse Unit I repre-sentatiws was ccadt ted on Novemb(r 19 and 20, 1980. The licensee resub-mittal was issued on Decemoer lb,1960 ana > is reviewed by EbW idano, Inc.,

to verify (umpliante o preposeo tests of safet -related Class 1, i, and 3 c

pumps and 'alves with rt quirements of the /6ME Boiler and Pressure Vessel Luce,Section XI, 1r// Eaition, through the Sumr,er of 1978 Addenaa. Tol( %

E dison has 4150 r!.pested relie f rom the ASME Code f rom testing suecified pumps and valves Lecause of aractical reastis. These requests have been t vu lua t ed individua f ly to ce.termine whether they .Tove signif icant risk implications and whether the tests, as req ired, re indeed impract:ca'..

Ine e valuation of the pump testing pr(oram and associatea reliet reques:s is t ontainea in Sect ion 11; the evaluat;on . t he valve testing program ano associateu relief requests is contained in Section 111. All evaluat ions f or Sections il and 111 are the recorts.m.idet .ons of E6 % loahc, loc.

uategory A enJ A/L valves that are currently t>eit.g leak testeo per ietonical 5pecifications (Appendix J) or are currently exemntco from leek

. rate testing oy Technical 5pecifications are contained in !h.tachment .

Valn s that shoulo be reviewed by the NRC to deterc.ine if they sheulu be cet eorized A are tantained in Attachment 1.

Lategory A, B, nd C valves that meet the requirements of the fui]E

' oce 50ction XI dnd are not exercised etery three months are containea in Attechment 11.

A listing of Phlbs used f or this review is contained in n t. : ha nt i11, Valves that ar e newer f ull strute exercised or that have a testing inten al greater than tech ref ueling outage, and relief requests with t tsuf f icient trenn1cel basis where relief is nat recommendea are summarized

.n Attachment IV.

HC Researci and Technica x Assistance Report I

11. PUMP TL5 iliiG PROGRAi1 Ine 151 progrum submitteu by Toledo Edisno Company was exar.inea to t e r 11 y that Class 1, 2, and 3 saf ety-related ru'nps were included in Lne program ano that those pump are subjected to the period % tests as required by the ASME Code,Section XI. Our review fou.d that all Class 1, 2, and 3 safety-reloted pumps were inclaued in the 15T program and, except for those pumps icentif ied below f oc wnich specific relief f rom testing has been

. rea,ested, the pump tests ano f requency of testing comply wi?h the cuue.

ictn loledo loison Company request f or relief f rom testing pumps, the cole r e q u i remer.t ior testing, the basis for requesting relief, and toe EG&G ee luation or tnat request is su:mnarized below.

1. All S af ety-Related Pumps I.1 ice 1ief R eque s t l he l uccisee nus reque.sted specific relief f rom the monthl., inservice test on ell saf ety-related equipment cooling and emergency core cooling p u:np s t ii att ordante wit h t ue requireinent s of Section Kl, anc proposed t o test all pumps in co:Lpliance with bettion XI once per qudrter and to joy alI pumps and medsure 1 low montoly. The pumps are:

Auxillary feedroter Hign Pressure Injection Loa Pressure injection Lontai m;nt hprdy

< o::,panent f ooling Derviu- v. :: l e r .

l !,I ye ricauir em r jt , Keter i t, Appendix A.

1. l . c L icen',ee 's im. j s f or Reques t ing r<elief . Monthly Sect'on X1 u; .c ? iiit, testang nas been ; lechnical Speciticetion requirement for im se ponps tince Apr i l 2/, 1977. An anclysis of t he results of thes:

. ;Ls <nd cumparuble Jata from other operating plants nas snawn no signiti-ant t i wyt s in perf err ance. Based on this analysis, the continuat ion of t

-mttw y! ;onthlj testing would not sign 11icantly increase planc s6tely, ih A.ai11ary feedwater, High Pressure injection, Low Pressure injectlon, and (: a t a n. ent g rey pumps are stanabj pumps whose continuous operation is Jt required. lhe bervice Water and Component Cooling Wdter pumps c.re t cnt inuous ly runninc, and any s ignif ic ent degradation will be detected s ;r ir,9 norma l operat ion.

~

U.snin ly pump t e:, ting reau1res a t otal ut et least 2/d nours per ycur c pi.s ever s11M, at least 7 h man-hours per year for data acquisition,

,, at leest M "an-huurs per yeer f or data reduc tion end record keeping.

ni (i nt ( rvat 1se tutal cost of 320 per man-hour, this amounts to 315,4b0

per year. Based upon the average exposurt rate; in the areas of the Auxil-i,ry Fee 0wa;er, High Pressure Injection, Low Pressure Injection, and Con-

! ainment Spray pumps, the total man-rems exposure per year for Dump test ing

. approxiirately 2.0 man-rems. At the present conservatively estimated

, ust nf 310,000 per man-rem to plant personnel, this exposure costs an djitional $20,000 per year. lotal cost to our customers is approximately 6,400 per year f or nn significa*1t increase in safety.

Altenate Testing: Pumps wi el be tested in compliance with ASME Sec-t Sn XI reauirements once per quarter and will be jogged monthly and flow neasured. ibis is in agreement with present chant,es that are being imple-mented in Subsection !WP of the Code.

The re' ision to change pump testing to a three month interval in IL'-3'D0 nas been approved and will be included in future Addenda. See Minates of t he Nnvember ?9,1979, meeting of t"e Operating and Maintenance Wort ing Group--Trst ing of Pumps and Valves, in San Jon , California, et ed canuary 9, 1900.

1.1. Evaluat'vo. We agree with the licensee's basis and, therefore, feel thet relief should be granted for Auxiliary Feedwater, High Pressure Injection, Low Pressure Injection, Containment Spray, Component Cooling, and Servico Water pt nps from the testing rec;uirements of Section XI. The 1 ;tensw has ded:onstrated through previously conducted testing that the proposed alt ernate t est ing f reGuency is auf ficient to dE termine any pump aegradat ion (the intent nt Section XI). We conclude that the licensee's prc=poul of running pumps monthly to measure O to ensure no pump degrada-tion, and of measuring all parameters quarterly, meets the intent of the Section XI testing requirements and should be sufficient to adequately mnni t or p.np degradat ion.

1.i Relief Reauest The licensee has requested specific relief f rom measuring bearing t< v ature (T,)

t on al' safety-related equipment cooling and emergency c ort t uo l a ng pum;15 in eccordance with the rquirements of Section XI. The

ur y are Au>illory feeuwater High Pressure Injection i w Pressure Injection

( on t .1 i nmen t Spray Ona;n wot Cooling se re u + Water.

'.<.1 Lou Requirement. Refer to Appendix A.

3

1. c' . 2 Licenee's Basis for Reauesting Relief. The ref erenced edit ion of t he Code requ1rcs bearing temperature to be recorded annually. It has been demonstrated by experience that bearing temperature rise occurs only minutes ;1rior to bearing f ailure. Therefore, the detection of rassible

• t: caring tailure by a yearly temperature measurement is extremely uni 1::ely.

It requires at least an hour of pump operation to achieve stable bearing t empc ra t u res . The small probability of detecting bearing f ailure by tem-

, porature measurement does not justif y the additional pump operating timo requ ired to obtain t he measurements.

Alt ernate Test ing: NONE. This is in agreement with present changes that are being implemented in Subsection IWP of the Code, the revision to delete yearly t earing temperature measurement. Deletion of bearing temper-ature measurement has beer approved and will be included in future Addenda.

See minutes of the November 28, 1979, meeting of the Operating and P.ainten-ante Work ing Group -Testing of' Pumps and Valves, in San Jose, Calif ornia, d at ea January 9,1980.

l.J.3 f.w a l u a t ion . We ogree with the licensee's basis and, there+ jre, feel that relief shuuld be grantcJ for Auxiliary feedwater, High Pressure inject wn, Low Pressure injection, Containment Spray, Component Cooling, and Serv ice IL. er pumps f rom the t es' ing requirements of Section XI. The licensee hes demonstrated t hat yearly t> earing temperature (T b) measure-ment in an unrelieble method of de'ecting t; earing failure and : hat deletion af t' yearly T,t measurement will have no adverse effect on tie Section X]

nump t es t iry program. We conclude that the licensee's proposal to run pumps monthly to measure Q to ensure no pump degradation, and to measure all para cters quarterly, except Tb yearly, neets the intent of the Sec-t ion Al t est ing requirements and should be suf ficient to adequately monitor puup degradation.

1. Relief Reauest The licensee has requested specific relief from observation of proper lubric 41 ion level or pressure on all saf ety-related equipment cooling nJ

.smerge ,y core cooling pumps in accordance with the requirements of Sec-t wr xl. The purps are Aueiliarv feedwater High i retsuro Injection

! n v. Pr essure Injec t ion kn t ; inn < n t Spray f.nnponent Cooling Service Water.

l . c; .1 Code Requiremont. Refer to Appendix A.

1.1. 2 Licensee's Basis for Requestina Relief. The observation of lubrication level or pressure is a maintenance f unction not an operability test function. P"mp lubrication requirements are determined by the pump manuf acturer and plant operation.

Alternate 'esting: Pump lubrication requirements are part of the plant maintenance procedures rather than Section XI operability test requirenents. This is in egreement with present changes that arc being inplement ed in Subsection IWP of the Code. The revision to eliminate oMervat ion of lubrication level or pressure f rom the Code has been appruved aod will bo includea in future Adcenda. See minutes of the ibvemb+ r 78, 1979, meeting of the Operating and Maintenance Working Group--Testing . Pumps and Valves, in San Jose, Calif ornia, dated hnuery 5, 1980.

l.3.3 Evaluation. We acret with the licensee's basis and, therefore, foel that reTief should be granted for Auxiliary Feedwater, High Pressure Injection, Low Pressure Injection, Containment Spray, Component Cooling, and Service Water pumps f rom the te; ting requirements of Section XI. The licensee has demoi..trated that prope* lubrication levels or pressures are verified by plant maintenance procedu,'es, and pump lubrication requirements aro spec if ied by pua,. manufacturer. We feel that duplication of recording test parametcrs will not assure any increase in the reliability of the above mentioned safety-reiated pumps. In addition, duplication of recording t es t pc meters would not cont ribute meaning 'ul information to the Sec-

• ino X I pump test ing program. We conclude that the licensee's proposal to r on pumps monthly to measure Q to ensure no pump degradation, and to measure all paraneters quarterly, except lubrication level or pressure, meets the intent of the Section XI testing requirements and should be sufficient to aceqndely monitor pup degradation.

2. Safet v-Related Inst alled Spare Pumps t 1 R< lief Request The lict.nsee has requesteo 7ecific relief from operability test'ng of installeJ t uare Component Cooling and Service Water pumps in accordance with the r equirements of Section XI and proposed to test these pumps when t h. v are c onnec ted to their respect ive systerr.

2.1.1 Co@ Reauirement. Refer to Appendix A.

.'.l.2 Licensee's Basis for Requesting Relief. Any one of the three

u. cpenent Cooling or three Service Water pumps is an installed Sriare. One omnp is normally running, the second is aligned as an autom6 tic backup to t h+ "perating pump, and the +.hird pump is electrically disconnected and nually valved nut of the systom. In the event of failure of the operating puw. t h; second automatically starts and the ir&alled spare is electri-cally conn"c+ed and manually valved in as the reserve pump.

Alt ernate Testing: The normally operating and reserve pumps will he ttstod. iht inst alled spare r,eed be tested only when it is connected to

, the t,y, tom.

5

2.1.3 Evaluation. We agree with the licensee's basis and, theref ore, teel that relief should be granted for installed spare Component Cooling and Service Water pumps from <.he testing requirements of Sectica XI. Jhe licensee has demanstrated thut the installed spare pumps must be electri-cally connected and valved into the system before pump operation is pos-

~

siblt. We conclude that the licensee's proposal to test the installed spare pumps 'ter they have been placed in service meets the requirements of Lection X1, Subsection 3111.

O 6

2 '. VALVE TESTING PROGRAM EVAL 4AT10N ine 15 1 program submitted by Toledo Cdison Company was examiticJ tu verit y that Class 1, 2, and 3 safety-relate) volves were incluJea in one program and that those valves are subjected to the periodic tests required by the A5ME Code,Section XI, and the NRC positions anu guidelines. Our review tound that all Class 1, 2, and 3 safety-related valves were included

~in tne IST program and, except f or those valves identif ied belcw t or wnich spec i t it relief from testing has been requestea, the valve tests and fre-quency of testing comply with tne code requirements enJ the hdC positions and guidelines listed in Section 1. Also, included in Section 1 is the NRC posit ion and valve 1, stings f or the le3k testing of velves that perf orm a pressure isolation function and a procedure for the licenee's use to incor-porate toese valves into the 15T program. Each Toledo Eoison Compely request t oi- eellet from testing valves, the Cude requirement for testing, lolevo Edisun Company's basis for requesting relief , and the EG&G evalua-tion of that request is summarized below and g ' ped according to each specific system.

1. General Considerations 1.1 Testing of Velves which Perf orm a Pressure Isolation Function lhere are severni safet, cvstems connected to the reactor coolant pressure boundary that have desigo -rossure below the rated Reactor Cuoloot system (RCS) pressure. Also incluced are tou .- (ystems which are rated at fuil reactor pressure on the discharge side of pump; that have pump suction

- aei 'HLS pressure. In order to protect these systems f rom RCS pressure, Iwo or more isolation valves are placed in series to form the interf ace between the nigh or-ssure RCS and the low pressure systems. The leac tignt integrity of these valves must be ensured by periodic leak testing to pre-vent ( xceeding t > cesign pressures of the low pressure systems causing a LULA.

It is NRC's pus 1 tion that these volves be classif ied as Categury A or n/C, es aestribec in Section A1, Subsection JWV, of ASME Boiler anJ Pres-sure Jessel code anJ leak tested in acCorddnce with IWV-3420 ut the ebuve mentioned Code at leest once per refueling outage. The allowable leckege limit for eacn valve snould not exceed 1.0 gallons per minute (gpm).c Inc nu and EG&u Joano, Inc., have discussed this matter with the licensee and h.:i; identifiea tae volves listed below as valves that perform 3 pres-sure naundcry isolation function.

Lf 30 Low Pressure injection Cneck cfJ) Low Pressure injection Cneck CF76 Low Pressure injection Check

3. See NUREb-Uo77, "lne Probability of Intersystem LOCA: Impact Dae to Leet iesting and Operational Chenges," and tne proposed Appendix A ta SRP b ec t l un a . 9.t,, " Leak Testing of Pressure Isolation Valves."

7

CF77 Low Pressure Injection Check CF28 Core Flooo Tank Isolation Check CF29 Core flood Tank Isolation Check HP48 High Pressure Injection Check

. HP49 High Pressure Injection Check HPhD High Pressure in. ction Chack HP51 High Pressure lajection Check HPbb H1gn Pressure Injection Check HP57 High Pressure injection Check HP58 Hign Pressure Injection Check HP59 High Pressure injection Check The NHL inf ormed the licensee t hat constant leak monitoring is .an accept-dble methno of ensuring volve integrity in lieu of Section XI, Subsn-tion IWV- W 3 leek testing. The licensee stated that valves CftS, Lf29, HP48, nP49, HP90, HP51, HP56, HP57, HP58, and HP59 ao have constant leck monitoring instrumentation instelled and tnat tne integrity of volves CF30, LF31, DH76, anu DH/7 is verif lea per ST5050.03 at a cold shutdown frequency.

!n cddition, the licensee has included in tne 151 program tne 21/2 in.

nign po ,sure injection lines f rom the oischarge check valves of tne Hign

~

'ressure Injection Pumps to t7e Class I/2 boundary as an expansion of the sverall intpt ction end test orogram. Un the basis of this information, the Ma stated that cat ( gorizing each of these valves C instead of A/C is accept Die.

l. a_tg CoJe SPClion Xl ReoJirements

usec t ion JWV-3411 ut tne bection X1 Lode requires Lnat Cooe Late-g.ir y n and B valves N eiert ised unte every three months, with the Excep.-

.im a derineJ in IWV .N12(o). IkV-3521 requires that Code Category L valves be exerclied unct every three conths, with the exceptions es cef ined in 1,, v - n n . in -3700 contains test requirements for active and passive talve!. ihe limiting value of f ull stroke time f or each power operated calve ' hall bc identified by the owner and tested in accordance witn iWV-34!3(a), (b), end (r). In the above exctptions, the Code permits the valves to be testeo at cold snuidown where:

. 1. 11 1s not practical to exercise the valves to the position requireo to f ulfill their f unction or to the partial position pur my power operation.

i.

11 is not practitel to observe the operation of thevalvesgwith tall soic actuators) upon loss of actuator power. 7

1. 3 atrul.e lestinn of Check Valves lhe hdC stated its position to the licensee that cneck valves whose saf et y tunttion is to open are expected to be full stroke exercised. It only i n:n ted operation is possible (and it hos been demonstrated by the 11censee and agreed to by the NRC), the check valves shall be partial strokt exerciseJ. $1nce disk position is not always ouservable, the NRC statt stated that verit it at ion of the plant 's safety analysis design flow rate througo tot check valve would i' en adequate demonstration of the tull stroke requirement. Any fl9w rate less than design will be considered p ytial strue exertising unless it can be shown that the check valve's disk positi o at the lower flow rate would be equivalent to or greater than the design ' law rate though the valve. The licensee agreed to Londuct tlow tests to 3 isfy the abov( position.

1,4 Struke k ,in g t Mutor Operated Valves The liter..,ee has requested relief f rom the pertial stroke exercising r equirement of Sect ion X] for all power operated valves. The licensee nas

>teteJ thet none of the Category A or B power operated valves identif ied can be partial strt<ke exercised because of the design logic of the operating circuits. These circuits are such that, wnen an open or close signal is recieved, the valve must com.nlete a full struke before the relay is releaseu to allow the velve to stroke in the other direction. We f ind that the aDovt rellet reque st f rom pertial stroke exercising is warranted and shoulo oc granted t;ecause the required f unction of the valves involves only f ull open nr full closed positions.

I . '; L i c e n .,cc ihquest ter Relief to Test Velves at Culd Shutdown l % CoJe permits valvts to be test 0d al cold shutGuwn, and toese vdlvts

r e specifically ident if ica by the licensee and are f ull stroke exer cised 2 ring cold sh;tuswns, tnerefore, the licenste is meeting the requirements t the 6DML CNe. bince the licensee is meeting the requirements of the O 'l % je, it ,iil not be necessary to grant relief.

Hawever, during our review of the licensee's M program, we heve verified that it is not prat-iltal t o exer t ise tn.;e valves during puwer operation and that we agree

1th the licensee's oasis f or request ing relief .

1L shoulu be noted toal the N d L' ditferthtlales for ydlVe testing pur-p s e <. setween tne c u l o s n1.t dor.n morte and the refueling mode. lhet is, for sttug purp: sc5, the i et uellng moJe is not Considered as a Cold souluown.

lo i nanne t o t he ietonical 5 petit itet ions in a Novt 'oer 19/b letter to the licensee, the NRL provided an attach-

~ ment intitleJ, "NRC uJldeline5 for [ACluding Exercising (Cycling) lests of hitain Valves Daring Plent Operation." The attachment stated that, when ane treln of a redunJof.L system such as the [mergency Core Cooling hystem a

(i t to j i s inoperat.lc, nonrecunuant valvts in the remaining train snoula not 9

Le tyt led if their failure in a non-safe position would cduse a loss oi t otcl system f unct ion. For example, during power operation in some plants, there are statec minimum requirements for systems . hich allow certain lim-1 ting conditions for operation to exist at any one time and, if Ine system as not restored to meet the requirements within the time period specif ied in a pl ?nt 's lethnical Specif ications (T.S. ), the reactor is required to be put in some nther mode. Furthermore, prior to initiating repairs, all valvts end interlotis in the system that provide a duplicate function are required to be tt sted to demonstrate operability itmaediately and periodi-colly thereafter during power operation. For such plants, this situation could be contrdry to t.he fiRC guideline as stdted in the document mentioneu above. It should be noted that reduction in redundanc, is not d basis for a T.S. change nor is it, by itself, a basis f or relief f rom exercising in 8(cot dance with Section XI.

lhe licenset has dgreed to review the plant's T.S. and to consioer tne need to propuse 1.5. changes which would have the ef f ect of precluding such testing.

Atter maing inis review, it the licensee determines that the T.S.

snould be chanced because the cuidelines are applicable, the licensee will s utmii t to the hRC, in conjunction with the proposed 1.S. change, the inoper-able tuna 1 Lien for each system that is effected which demonstrdles that the VdlVe't fallLre would Cduse d loss of system funClion or, it the licensee determines that the T.S. should not be changed because the guicelines are ont dpplicdble or cannot be follo ed, tne licensee will suomit tne reasons that led to their determination for each potentially effected section of

, the 1.5.

1./ batety-Relatec Valves ihis review was limited to safety-related valves. S af ety-rel ated valves are detined as those valves that are needed to mitigate the conse-qJencts of do accident anJ/or to shJt duwn the reactor and to mainidin the r1 attur in a shutdown conuition. Valves in this category would typically include certeln A5ME Code Llass l, t, anJ 3 valves dnd could incinue some non-t uue Closs V3lves.

11 unualJ be noted that the licensee mdy hdve inc luded non-sdf ety-i eloted valva in the.r IST program as d decision on the licensee's part to xpano the scope of their progrdm.

! velvt lesting at Cold Shutdowns Instrvice valvt test ing at. cold shutdowns is acceptable when the f ul-louiw s enuitions Lte met:

1. It is understuad that the licensee is to commente testing as soon as the cold-shutdown (ondition is dchieved but not lat(tr than

. 4d hours ofter snutuown, and continue until complete or plant is r eac y t o ret urn ta power.

10

Completion of all valve testing is not a prerequisito to return to power.

Any testing not completed at one cold shutdown should be perturmed auring any subsequent cold shutdowns that may occur before re1ueling to meet the code specified testing frequency.

3. For planned cold shutcowns, where the licensee will complete all the valves iaentif ied in his IST program 'e- testing in tne culd-shutdonn maae, 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.

1.9 Cet ecor v A Valve Lea A Check Requirements for Containment isolation Valves (CIVs)

All CIVs shall be classified as Category A valves. The Cetegory A valve leak rate test requrements of P -3420 through -3425 have been super-ceded of Appenaix J requirements f r- CIVs. Tne NRC has concluoed that the cpplicable leak test procedure- na requirements for CIVs are aetermined by 10 CFR 50, Appencix J. Relief f rom Paragraphs IWV-3420 through -3426 f or CIVs presents no saf ety problem since the intent of IWV-3420 througn -3425 is met by Appendix J requirements.

The licensee snall comply witn Paragraphs JWV-3420 and -3427 until reli' is requested f rom these paragraphs. It should bo noted that these pararaphs are only .ipplicable where a Type C, Appendix J leak test is po r t u rnt d .

Baseo on the considerations discusseo above, the NdC concludes that the alternate testing proposed above will give the reasonable assurance of valve operability intended oy the Code and that the relief thus granteo

, will not endanger life or property or the commen defense and security of the puulic.

1.10 Application of Appendix a Testing to the IST Program lhe Appe'icir J review f or this plant is a completely separate review f rom the 15i progrom review. However, the determinations made by that ieview are u1rectly applicable to the 151 program. Our review has deter-nineo t hat t he current IST program as submitted by the licensee correctly retlu ts uur interpretation of Secticn XI vis-a-vis Appendix J. lhe licen-see nos agreca that, should the Appendix J program be amended, they will um1 their Ibi program accordingly.

i.ll h e surizer Power Opercted Relief Valves i ne ht nos daupted the position that the pressurizer poner operatea reliet valves should be included in the IST program as Category B velves no tested to t oe r equirements of Section XI. However, since the PORVs have shown a high probability of sticking open and are not needea for over-

. pre %ure protection uuring power operation, the NRC has coacluded that ruutine exercising during power opration is "not practical" ana, therefore, nut requartd b,y InV-3412(a).

11

The PORVs' unction during reactor startup and shutdown is to protec t t he "ex !or vt",sel and coolant system f rom low temperature-overpressuri7ation conditions and should be exercised prior to initiation of system condit ions ior which vessel protection is needed.

Tr e f ollowing test schedult is recommended:

1. Full stroke exercising should be performed at each cold shutdown er, as a minimum, once each refueling cycle.

2. St roke timing should be perf orn.ed at each cold shutdown or, as a minimum, once nach refueling cycle.

3. Fail saf e ectuation te sting is permit ted by the fode to be per-f armed at each cold shutdown if the valves cannot be tested during power operation. This testing should be performed at each Cold shut down.

4 The PORV lock valves should be included in the IST program to provide protection against a small break LOCA should a PORV fail open.

The Davis-Besse Unit 1 design utilizes one PORV and an associated block valve. The licensee has included these valve s in the IST program along with a request f ur relief f rom the Section XI, Category B, testing require-rvnis 1or t ne PORV t hat describes the testing and position monitoring pro-gram (reter to Section 7.1.1).

'.1< Onul Stop/Lheck Valves ihr l ic ensee has def ine:' manual stop/ check valves Category C, passive, in the IS T program. The purpose of this categorization is to ensure proper emini< t rative end procedural control of the valve operator position. I h t' artive portion of the valve, the disk, is being exercised as per the reauirement s at Section X] unless identified otherwise in this report.

2. All Systems All Safety-Relat ed Power Operated Valves J.l.1 Relief Recuest. The licensee has requested specifit relief from the power operated va lvn t imine requirements of all safety-related pwer nperat ed velves in accordance with the requirements of Section XI cnd oregreed to neasure the st roke time of all power operated valves to the w ar-st second.

.l.1.1 Coce Roquirement. Refer to Appendi: A.

5.i.l.c Licensee'c. Basis for Requesting Relief. For valves with

< t r oi e t 1 w. less than 10 seconds, this wouh require measuring stroke nw, tn nithin < fraction of a second. Valve timing is performed uting a stop watch >ither by directly observing valve movement or by observing IP

remote position indicators. Neither method can be relied upon to yield result s wi+!. accurncy of less than a second.

Alternate Testing: The st roke time of all power operated valves shall he menured to the neerest second.

2.1.1.' Evaluation. We agree wit h the licensee's basis and,

. therefore, feel relief should be granted f or all power operated safety-releted valvos (wit h stroke times less than 10 seconds) f rom t he timing requirements of Section XI. The licensee had demonstrated that, using the presently available methods of measuring stroke times, accuracy is limited .

and meaningt ul data on valve stroke time degradation cannot be cbt ained.

We conclude that measuring stroke time to the nearest second meets the inttnt of Section XI and should provide meaningful data to use in deter-mining any valve degradation.

P.l.? Relief Recuest. The licensee has requested specific reliet f rum t he power operateti~vilvo timing requirements of all safety-related power operated valves in accordance with Section XI.

? ,1. ' .1 Code keguirement. Refer to Appendix A.

. . l . / .1 !.icensee's Basis f or Requesting Relief. Operat ing xperient. nas irniiTAtod t hat indivianal valve t iming is inf luenced by many 1 ac t ors w.h a' changes in t emperature, humidity, fluxuation in power source, limit switch adjustment, etc. Because of these outside factors,

~

timing "ata can exhibit icetter which exceeds the Code criteria, but which ie d ill less than the maximum full strate time. Lacking in the Codt r-quirements is any provisien f or verifying test results prior to placing tm valve en an accelerated test frequency.

The preu nt CoJ- does not require any action for valves whose strnir ta suddenly decroases a s ignif icant amount. Any marked decrease outside t he norm.fl band of -troke timos could indicate a ":ajor mochanical problem m n as the povmr operator being disconnected f rom the valve. Any signif -

i< nt decren e in stroke timo should be inv-stigated to determine if the v ilu and power actuater are capable of perform 4.g t he ir f ont 1 ion.

A l t ei nat i I e t. t i n g : Masimum full stroke iines shall t;e established f or wh valve based npon requ ired valve response t ime t o assure adequ3tv tystem empanse i t.r s oi e t y-re l a t ed f unc t. inns . Valve test times will be acceptanle 1r les- t nan t h. n uic um allowed. If test time exceeds the maximum allowed, th" v a l w w i l l b. i w dlately retested and corrcctive action taken as

<ppropriate Ane tignif icent decrease in valve test time will inmediately bo invest igated and appropriat e action teken.

?.l.2.3 Lvaluatinn. We agree with the licensee's basis and, t v refore, feel relTef sholiTil be granted f or all scf ety-related power oper-

't>c alvos f rnm t he strok e t iming requirements of ' ection XI. The licensec be< 'st rat ed t hat the initiation of immediete retesting and corrective c c t son up ri cet ect ion of abnormal valve st roke tivs meets t he requirement !

J Sect 10% XI. O canclude that the proposed alternate st _'a timing and c c er is t t w gtion requiremontc. for these valves wi11 provide !he required 13

mecningful deta to determine anc correct any valve degradation (tne luttnt of Section XI).

3. Steam Cenerator becondary System a.1 iateuory L Valves 3.1.i Relief Request. the licensee has requested specific rellet

. f rom exercising Category L valves AF39, 43, 72, 73, 74, and 75, auxiliary iteJ o ter chetAs, in accordance with the requirements of Section XI and proposed to partial stroke exercise these valves during refueling outages.

3.1.1.1 Code Requirement. Refer to Appendix A.

3.1.1.( Licensee's Basis for Requesting Relief. Cycling these valves would require injection of auxiliary feeJwater into the steam gener-ator which would tnermal shock the auxiliary feedwater nozzles. These

, alves cannot be pert ial s t rok e exercised during normal operation or f ull strM e exercised at any time without injecting auxiliary teedwater into tne sic.' ycnetstur cnJ t r.ermal shock ing the aux iliary f eedwater nozzles.

.ee valves will be partial stroke f orward f low cycled during ref ueling cat agt s when the steam generator is told. These valves cannot be full st. oke e>erc ised during ref ueling outages because the auxiliary boiler is used to puwer the auoliary feed pump turbine. The am iliary boiler does not generett enough steam to operate ti.e turaine at o hign flow.

J.l.l.3 Lvoluation. wt egree with the licensee's basis end,

• thert lore, f eel temporary relief shou d be granted f or Category C valves l

AF B, 4J, 72, /3, 74, and 75 from the full stroke exercising requirements of Section X]. The licensee has demonstrated that the valves cannot be exertised during power operation without ceasing thermal shock to the auxiliary tetawater nozzles and inat the steam generators may not be cool enaugti to prevent tnermal shock during cold shutdown. The volves connat be t ull strue e>erciseo during ref ueling outages because the auxiliary coiler nast U t: used tu t upply steam to t ne auxiliary f eed pumps and dues not gt n-er a tt enougn .tt >.to achieve design feedwater flow. We conclude that,

s. i t h ne pr( < tot piping cont igarat ions, only partiel strcke exercising et tnese valves is poss1Dle. However, we recommend that. the licensee further i nves t i gt e e met hud t o f ull stroke exercise these volves.

4 5tation and Instrument Air 4.i iatecory s/L icises

. I ,. i Helief Utquest. ine 11tenste nas requesteJ specific relict from e crcising Lategory A/C valve SAbu?, station air containment isolotion that , in ac ccr aance with the requirements of Section XI.

4.1.1.1 Code Hequirement. Refer to Appendix A.

' ^

.I.l.< Licenst e's Basis f er Request ing Helief. Verification or rt vt r t, ilow clusing can only practicably be accomplished by leak testing.

Ih.s testing ts u only be pcrformed at retoeling outages. This valve wili

se reverse fluw closure teste<J dt refueling outages during the perturmonte of an r;ppendix J, Ty pe C, test .

4.1.l.3 Lealuation. We agree with the licensee's basis and, t heref ore, f eel rellet should be granted for Category A/C valve d/1502 f rom the extrc ising r equirements of Section XI. Itie licensee nas oemonstrdtea that, uue to plant design, the only method available to verify volve closure (its setet3-releted position) is leak testing. We conclude thct the pro-

- postc alternate testing trequency of verifying valve closure during the periormante at leax rate testing at refueling outages should demonstrett>

proper valse optiobility. -

9. l / Relice Keque<,t. The licensee has requested specific relie1 1 rom exercising category A/C valve IA501, instrument air containment isola-tton check, in atturdance with the requirements of Section XI.

4.1.2.) Code Reauiremert, Refer to Appendix A.

4.1.2.c ticensee's Basis for Reauesting Relief. Verif icall if t of reverse flow closing can only practicaDly be accomplished by leek testing.

i bis t est ing con only be perf ormed at rt.f ueling outages. Triis velve will r reverse flow closure tested at refueling outages during the performance et an Appendi, J, 1 3 pe L, test.

9.l.J.a Evaluello", ne agree with the licensee's basis ch0, theret m e, teel relief snould be granted f or Category A/C valve 1/N1 f rom t he ( u t tis ing requirements of Section XI. ihe licensee nas demonstrateo

. that, due 1o plant design, the only methoa available to verify valve closure l i ta .aTety-related position) is leak rate testing. We conclu0e inct the propm.ed ellernate testing f requency of verifying valve closure during the pe r f ort.anc e of leak rcle testing at rttuelir.g outages should demonstrete proper valst 0;>et obi l i ty .

. Nitrogen Supply

. .1 ot t c trv is / t: Va la 1

.l.1 Hellet Request. ine licensee has requested specif ic relicf f rom +. iercising category A/C valve NN53, nitrogen supply containment isola-t ion check , in acc ordente w it h the requirtment s of 5-ction xl.

s.l.l.1 Qde Requirement. Refer to Appendix A.

t.l.i.2 citensee's uasis f or RLquesting Relief. Verification of reverse f lm clos mg can only pract icably be accomplished by leak testing.

lhis 1. Sting can only be perf ormed at rcf ueling outages. This volve will be tr.rse 1lew closure tested at refueling outeges during the performance 01 cn /,p p e n J i >. J, Type C, test.

, b.l.l.a L valuat ion. We agree with the licensee's basis end, theretore, ieel reliet should be granted for Cetegory A/C valve NNbb from tot e>crt i s ing requ i r ement , of Section X]. Inc licensee hos de;iritistrates that, tum 10 plant Gesi 7i, the only method dvailable to verity valve closure 4

)

(its sofety-related position) is leak testing. We conclude tnat the pro-posed alteritate testing frequency of verifying valve closure during ine performance of leak rate testing at refueling outages should demonstrate preper valve operdbility.

6. Lontainment and Penetration Rooms o.1 cateaorv A/C Valves

.l.1 deliet Htquest. The licensee nes requested specific rellet from exercising Category A/C valves CV209 and 210, hydrogen dilution air tuntainment c L ss, in accorcance with the requirements of Section XI ano proposed to exercise them open curing cold shutdown and verify closure Juring refueling.

6.1.1.1 Code Requirement. Refer to Appendix A.

6.1.1.2 L icenste's Basis f or Requesting Relief . Lycling can on o be perf ormeJ tiy in.]ecting air f rom the hycrogen dilution blowers into the ccntainment. This air must be purged from the containment to the environment. Purge time is limited to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year curing normal operation. lesting could cause excessive purging with result.iry increase in releost s to the env ironment. These valves will by cycled ac cola shut-down. No partial stroke exercising is possible during normal Operation sithcat injecting air into the containment. Verification of reverse flow closing can only prccticcbly be accomplished by leak testing. This testing ian only be performed et retueling outeges. These valves will De reverse ilow t.lcsure tested at refueling outages during the performance of an Appen-Jtx J, Type L, test.

o.l.l.a Etaluetien. We agree with the licensee's basis end,

~

treretore, teel rel1et st ould be granted 1or Category A/C valves CVJu9 and

'10 t rum t he exercising requirements of Section AI. The licensee hos

, monstrat s that these selves have two safety-related positions cepending apon plant ct c it ions . Inese valves are required to open to aumit post-attiJent hydrgen dilution cir to the containment and to close to pruvide

( unt a inment isolution. Iney cannut be exercised open during power opc N-tion nithout injecting air into the conteinment wnich must be purgeu to the en61ron.unt. Purge time during power operation is limitea to 3 0 noars

, er year b, W 01ra t i u . Due tu plant design, the only 2Vailable metnsJ

_a vt rif y valve c losure is A cing leak testing, We conclude that tne pro-

, m a altern i t- testing f requency of exercising valves CV209 ano 210 cpen a r.ny talt shutdown and verif ying valve closure during the perf ormance of ien .te t(iting et refueling outages should demonstrate proper valve

.c ;r h ility.

. . l.. Olit Htquest. lhe licensee has requested specif ic reliet trum ( *ercising Lategory n/L calves CVld4, and 12b, conteinment at mphire

.. u.np i t coetts, in acc ordcoce with the requirements of Section XI.

t' . l . c .1 Code Requirement. Refer to Appendix A.

6.1.2.2 Licensee's Basis for Requesting Relief. Verification of reeerse flow closing can only practicably be accomplished by leak testing.

This testing can only be performed at refueling outages. These valves wili De reverst flow closure tested at ref ueling outages during the perf ormance of an Appendix J, Type C, test.

o.l.2.3 Evaluation. We agree with the licensee's basis ano, tuertt ure, f eel relief shoulo be granted for Category A/C valves CV124 and

- 125 t rm the exercising requirements of Section XI. Tne licensee nas demonst rated thet, due to plant design, tr,e only method available to verif y volve closure (tneir safety-related position) is leak testing. We concluce that the proposed alternate testing frequency of verifying valve closure during the perf ormance of leak rate testing at refueling outages should cemonst ate proper valve operability.

7. Reactor Coolant 7.1 Letegory a vahes

/.l.1 Reliet Request. Tne licensee has requested specific relief irum stroke timing Category B valve RC2A, pressurizer pressure control

( Pod ) , in accordunce with the requirements of Section XI.

7.1.1.1 Lode Rewoir nent. Refer to Append 1x A and bection 1.11.

i.l.l.2 Licensee's Basis f or Requesting Reliet. Full stroke me rcising ca"oct be visually verified on inis valve since the valve mech-

' n i s:o is all internal. A test can be perf ormed b3 closing t'e Dlock valse and seeeing if RC2A solenoid energizes and de-energizes properly. Stroke timing is impractical as the valve mechenism is all int e nal una tne valve is pilot attuotec. You can measure the position of the pilot but not of t he valve 115 elf. This is not a motor operated valve. There is no fail-sate position of this valve. RC2A is tested in PT 5164.02, Pressurizer Foner Relief Valve Periodic Test, in conjunction with ST $030.04, RL5 Pres-sure to the uh Refueling Period Calibration Procedure, at least once per

!d s mns niin the unit in c;1d shutuown (or refueling) mode. Inis test verit RS that RCPA Will epen when its associated solenoid is energizta and ill miose when tot soient 4d is de-energizea. This test is normally run aith the RLa pressure at dlM f.sig but can also be performed at <215d psig

'ut A0 psig in tne Rb . TL s test also verifies that the soleioid essociatec with RC2A will be energized et a signal equivalent to an RC5

,1resi;re of au) : lo psig and de-energizeo Dy a signal eqaivalent to an uS pres w e ui abu ? 10 psig. This phase is run by simulating output

.ignais trm tne RPS to P5ht-RL2-b in the NN1 cabinets end verif ying proper operoL im of the solenoid at RLEA. Si 0030.04 will verif y that tne instru-ent strings for the RPS pressure trcnsmitters selectable for use in the

'hl ere celibrcteu frum tne pressure transmitters to the output of the RP5 ccDinets. An ccoustic monitor is used to verify valve opening and closing.

Inis valve ,,.j De ettettively partial strate exercised during normal apera-tion u response to pressurizer conditions. This valve will be full stroke exerc is ed at ret ueling curing perf orn ence of plant procecure Pi bla.02, nn an elsu verifies pressure setpoint. No valve timing is possible.

17

7.1.1.3 Evaluation. We agree with the licensee's basis and, 1 heref ore, feel relief shoulo be granted for Category B valve RC2A f rom the st roke timing requirement s nf Section XI. The licensee has demonstrated

+ hat, due to design, this valve cannot be accurately timed and that stroko

- t ! ming will not provide meaningf ul data f or valve degrada+. ion. The licen-we's test and position monitoring program detailed above (Item 7.1.1.2) was discussed with NRC representatives at the working meeting and found to

, l'e acteutable in that it meets the NRC recommendatiors outlined in Value Testing Section 1.11. We conclude that the proposed alternate test and monitoring progrwn is consistent with NRC recommendations and should demon-strate proper vale operability.

8. Makeuo and Purification 8.1 Categorv A Valves 8.1.1 Relief Requ est. The licensee has requested specific relief 1 rc:. exercisEj Eateaory A valves MU38, 59A, 59B, 59r, 59D, 66A, 66B, 6bC, and 56D, reactor coolant pump seal water containment isolations, in accord-ance with the requirements of Section XI and proposed to exercise these valvcs during refueling outeges.

8.1.1.1 Code Recuirement. Ref er to Appendix A.

B.1.1.2 L icensee's Basis f or Request ing Relief. Cycling t hese valves during norn.al ope ration would stop reactor coolant pump seal cooling h !ter f low. This would 'Jemace reactor coolant pump seals and is not per-mit ted hv plant operating procedure. The reactor coolant pumps are requirea t o be running under all normal conditions except refueling. Valve design precludes partial stroke exercising during normal operation. These valves

. will by cycled et refueling outages.

a.1.1.7 Evaluation. We agree with the licensee's basis and, th reier., f eel relTef should be cranted f or Catogory A valves MU38, 59A, noi , MD, 66A, Cf6, f1ff, ?nd 06D f rom the exerc ising requirements of wctinu XJ. Th" licensen has demonstrated that these valves cannot be r> t rt ised while roactor coolant pumps are in operation without possible

n ap w al O nag . The reactor coolant pumps are required to be running at all tint durino nnrmal plant conditions by plant procedures, and are sm m ed during ref ueling outag+ . Seal water can then be secured. We

( < nt Nde that the proposed altt- ,,cte test frecjuency of exercising these v o l t ei d u r i n t; refuelinq outages when the reactor coolant pumps arf secured shou'd demonstrate prop.<r valve operability.

, .? L'ategsrv A/C Val ms

.I Relief Request. The licensee has requested specific relief t r om ewn ising Category A/C valm MUP4?, 243, 244, and 245, reactor conlant pu: 1p seal water checks, in accordance with the requirements of M e t i..n X1,

..i.l. .nde Reauirement. Refer to Appendix A.

18

U.P.l.2 Licensee's Basis f or Requesting Relief. Reverse flow cycling during normal cperation or cold shutuown would reouire stopping reet tor coolant pump seal cooling water f low. This would damage reacter coolant ;) ump seals and is not permitted by plant procedure. The reactor rooiant pumps are required to be running under all normal conditions except refueling. System operdtlon precludes partial stroke testing curing narmal operation. Reverse flow stroking will be done at refueling outages during the performance of an Appendix J, lype 0, test.

f .l.3 Evaluation. We ogree witn the licensee's basis ano.

1 hert i ore, t ce i r eIIe1 snouTd be granted f or Cotegory A/C valves vibi42, N,JN, ono 2e f rom the exercising requirements of Section A1. The litensee hos demonstrateo that these valves cannot De exercisea wnile reat-t ur coulant pumps are in operation witnout possible pump seal camage. In aud i t ion, the only method available to verify valve closure (their saftty-relateu pos: tion) 1s leet testing. We conclude thot the proposed alternate testing f requency of verif ying valve closure during the perf ormance of leak r ate testing at ref ueling outages should cemo.1 strate proper volve operability.

9. Decay Heat and Emergency Core Cooling y.1 Lateaorv B Valves 9.1.1 Reliet Hequest. The licensee has requested specific relief from exercising Lategory 6 valves DH9A and 90, containment emergency sump i so lat ions, iri accordarite with the requirement s of Section XI and proposed

- to e>crcise these valves during refueling outages.

9.1.1.1 Loue Heauirenent. Ref er to Appena1x A.

9.1.1.2 Licensee's Basis f or Requesting Helief. Cycling these v alvt s woulJ introduce bordted water trom ine burated woler storage tunk Jirectly into the containment emergency sump. These valves are interlocked w i th unm u.J 7b cod can c nly be tested when the bouted woter storagt tank (an be 1tol*trd. lhese valves c annot be partial strok e t esteci uuring nor-Ki d } operallon WlthoJI injecting DDrated Woter into thL Containt; lent elat r-9ency surp. These valves will be cycled at refueling outages wnen the arated water storage tank can be isolated.

9.1.1. Evaluation. ne ogree with the licensee's basis and, toer,ture, tecl rel vt snuald be granted f or Cotegory 6 valves DH9s and 9ts t i um t he ext rc is ing r equ irement s of Section XI. The 11ctiisee has os ren-

,tra t t d that i nt :.e narna l ly c losed volves connot be exercised without tlunuing the c ont ainment tmergency sump f rom t he burated water stors.ge ook. Volves DHA ana n are interlocked with normally open valves bH7A

..d /U, borated water storage tank outlet valves. The oorated water stor-age tenk is required to be available as a water supply during all normal plant tonoitions except. refueling; therefore, DH7A and 7B cannot be closco

. to natisfy the interlock < to allow exercising DH9A and 98. We concluue that the proposed alternate testing f requency of exercising valves DH9A and

<L dur ing ret t 11n9 :Jutages When the buroted water ss.orage tank can be 1Lolated should denonstrate proper velve operability.

') . . ' Coteq0ry C Valves u.2.1 Relief Request. Inc licensee has requested specific r eliet from c^ercising Lotegory C va hes Lf28 and 29, core flood tank outlet t hi c i s , in accordance with the requirements of Section XI.

9.2.1.1 Cooe Requirement. Refer to Appendix A.

9.2.1.6 Licensee's Basis for Requesting Relief. Forward flow cycling cannot be performeo curing normal operation or cold shutdown when the HL5 is f illed and pressurized to pressure greater than that of the core fiuuu tank. Full stroke is precluded by system design. These valves will

!t partial stroke exercised at refueling outages when the contents of the core floca tank can be partially dumped into the RCS while monitoring core f lood t ank level.

9 . 2 .1. .i ivoluation. We agree witn the licensee's bcsis and, theret ore, f.el temporary relief should be granted for Category C valves cF2B aun 29 f rom the exercising requirements of Section XI. The licensee nas demonstrated that the only available tull flow path is into the reacter coulon system and is out poss oie during power operation because the Core fiuod tank pressure cannot overcome RC5 pressure.

inese valV#.s Cdonot be f ull stroke exercised during Cold shutdown without tne possibility of creatirig a low temperature-ovt pressurizetion tonJat un in toe RL5. We cunc luue t hut, with the present piping con 11gur-ation, only pdrtial stroke exercising of these valves is possible. Honever,

, ..e recommend inat tne licensee f urther investigste a method to f ull stroke exercise these valves.

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9.2.c e lici Pequest. The licensee has requested specific relief trom exercising Cateoory C valves HP48, 49, 50, 51, 56, 57, 58, ana 59, high pressure injection checks, in accordance with tne requirements of aection XI.

9. 2. c .1 Loce Requirement. Refer to Appendix A.

e.t.t.2 ticensee's Basis f or Request ing Relie f . These valves c an un i r ue c.,cled t>y nign pressure injection flow. High pressure injec-tion during normal operation or cold shutdown could introduce cold hater into tne signif:cently hotter reactor coolent system. This woula tnermal snock the hign pressure injection nozzles. Aoditionally, high pressure injectluu during cold shutdown could subject the reactor coolant system tu pressure = nigner than allowed in the cold shutdown mode. System operation p rec l oat ', partial stroke exercising these vdives daring normal operation.

l n.: t valte: . sill be forwaro flow cycleJ et refueling outages when the re<ctor vessel heau is removeo to prov1Je an acequate expension volume.

9.?.c.3 tvaluation. We agree with the licensee's basis aw ,

, t oere f ore, f eel r ellet should be granted for Category C velves HP48, 49, 50, bl, 50, 6/, bb, and 59 from the exercising requirements of Section XI.

1% 1itensee nas oenonstrated that toest valves connot be exercised during p . >. e r cperat ien or cold shutcown without causing thermal shock to the nigh 20

pressure injecton nozzles. These valves cannot be full stroke exerciseo curing colo shutcown without the possibility of creating a low tempereture-overpressurization condition in the RCS. We conclude that full stroke exercising these valves curing refueling outages when an expansion volume is available should demonstrate proper valve operability.

10. Emergency Core Cooiing, Containment Spray, ana Core F loca

- 10.1 Lategor;{ A/C Valves 1U.1.1 Reliet Request. The licensee has requested specific reliet f rom exercising Category A/C valves CF15 and 16, core flood tank s;trogen suppl) tuntainment isolation checks, in accordance with the requirements of bection XI.

10.1.1.1 Code Requirement. Refer to Appendix A.

10.1.1.2 Licensee's Basis for Requesting Relief. Verification at reverse f low closing can only practicably De accomplishea by leak testing. This testing can only be performed at refueling outages. These valves will be reverse flow closure tested at ref ueling outages curing tne performance of an Appendix J, fype C, test.

10.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel relief should be granted for Category A/C valves CFlb anc lb trom the exer _ising requirements of Section Xl. The licensee nas Jemon-trated thct, due to plcnt utsign, the only method available to serity

. Vulve closure (their safety-reiot;a position) is leak testing. ne conclude Bat the proposed alternate testing frequency of verifying valve closure our ing t he perf ormance of leek rate testing at refueling outages shoula demanstrate proper valve operability.

11. Component Cooling Water 11.1 Categary A Velves Il.1.1 Relief Hecuest. Tra l aensee has requesteo specif ic relief from exercisn U ategory A valves CLl411B and 14078, component cooling n ater cont ainment isolet ions, in accordance with the requirements of bec-tion Ai ena proposed to exercise these velves during refueling outages.

11.1.1.1 Lude Rtquirement. Refer to Appendix A.

11.1.1.2 Licensee's Basis for Requesting Relief. Cycling these t;1tes auriny nurmel operation or cold shutuawn requires shutting off

( iolin Later to the reactor coolant pumps which would cause extensive d un ge to toe pumps. Luoling water to tne reactor coolent pumps is required extent at refueling. Valve design precludes pertial stroke exer-c is ing these va lves during normal plant operation. These valves will De

, tull stroke exercised at refueling outages.

Il.l.l.a Lvcluation. We agree with the licensee's basis ans, t heret ore, f eel relief shoula be granted #or Category A valves CCl411L ano

1407B f rom t he exercising requirements of Sect ion XI. The licensee has Chmostrated t hat these valces cannot be exercised while t he reactor cool-ant pumps are running without causing pump damage. The pumps are secured during ref ueling out ages and cooling water is not required. We conclude

. that the proposed alternate testing frequency of exercising these valves during refueling outages when the reactor coolant pumps are secured should demonstrate proper valve operability.

11.2 Category B Valves 11.2.1 Relief Request. The licensee has requested speci#ic relief from exercising Category B valves CC1411A and 1407A, component cooling water supply and return, in accordance with the requirements of Section XI and proposed to exercise these valves during refueling outages, 11.2.1.1 Code Requirement. Reier to Appendix A.

11.2.1.2 Licensee's Basis f or Recuesting Relief. Cycling these valves during normal operation or cold shutdown requires shutting of f cooling water to the reactor coolant pumps which would cause extensive

!amane to t he pumps. Cooling water to the reactor coolant pumps is required except at refueling. Valve design precludes partial stroke roer-c 1 sing during normal operation. These valves will be full stroke exzecised at refueling outages.

11.2.1.3 Evaluation. We agree with the licensee's basis and, theref ere, feel relief should be granted for Category B valves CCl411 A and l A07A f rom the exercising requirements of Section XI. The licensee has acmonstrated that these va?ves cennot be exercised while the reactor cool-ant pumps are running without causing pump damage. The pumps are secured during refueling and cooling water is not required. We conclude that the preposed alternate testing f recuency of exercising these valves during refueling outages when the reactor csolant pumps are secured should demon-r trato preper v alve 0;>erability.

12. Reactor Coole't System Details 12.1 Catecary A/C Va ives li.l.1 Eelief Rec / st. The licensee has requested specific relief from r>ercising Categorv A/C valve RCll3, pressu-izer quench tank retircu-let on l ire contalnnent isolation, in accordance with the requirements of Set? inn XI.

12.1.1.1 Code Pecuirement. Refer to Appendix A.

l?.l.1.2 L icensee's Basis f or Reauesting Relief. Verification af r* ver f low closing can only practicably be accomplished by leak testina- ihis test ing can only be perf ormed at ref ueling. This valve will

• N retersr f low closure tested at ref ueling cutages during the perform 5nce nf an Appendix J, Type C, test.

72

16.1.l.3 Lv We agree with the licensee's basis and, t her ef ore, f eel rel1FT_o luct10ti.shoulo oe granted f or L:otegory Aic valve Ell; t rem t rie exercising requirement s of Section XI. The licensee nas demonsteotro that, due to plant design, the only method availaole to verif y valve c losure (its sottty-related position) is leak testing. We concluae that *.he pro-posed alternate testing f r equency of verifying valve closure during tne peri ori ante of leck rate testing at refueling outages should cemanstrate proper va lve operatu li ty.

13. Service Water 15.1 Lott oory C Valves 1.,l.1 Rellef Request. The licensee has requested specific relief from c>ertising Letegury C valve SW57, service water isolation cb % , in et;ordance with the requirements of Section Al.

13.1.1.1 Cooe Requirement. Ref er to Appendix A.

13.1.1.2 Licensee's Basis f or Requesting Helief. Reverse flow cyc ling requires stopping cooling water f low through the turbine plant cc.uiliig woter heat exchanger: which could result in extensive equipment damage, System operation precluors partiel stroke exercising this volve during nurmal plant operation. This valve will be reverse flow cycled at refueling outages when cooling water is not required.

13.1.1.3 Evaluation. We agree with the licensee's besis and, torret ore, f eel relief sn6JTToe granted f or Category C valve 5657 f rom the c > rrc t'.ing r equ irement s ut bettion XI. Itie litetisce has demonst rated t hat, dae to piant design, the only method available to verif y valve closure (its

• at ely -r e l,1cJ pus il lon) is by secur ing service wdter f low through t ne

~

"(noling wattr heat r u h a n t,e r . " These coulers serve the turbine !>uilding e w1pment. Servitt water corinot be secured during power operation withaut p; 31ble equipment d am 3 gt . Turbine building equipatent cooling requireuents coy be su.h that service noter f low connot be secured during cold shat-J An. Le cent luJe that the proposed alternate testing t rcquency at veri- ,

l ying volve c losure our ing ref ueling outages wnen service woter f low can be sec ur n shoulu demonst rate pr oper valve operability.

W 2J

IV. APPEN111 X A

1. Csce Requirements--Valves

, subsection !WV-3411 of the Section XI ASME Code requires that Code Cat ogory A and 5 valves be exercised once every three months, with excep-t ions as dct ined in IWV-3412(a). IWV-3521 requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3522. JWV-3/00 contains test requirements f or active and passive valves. The limiting value of f ull stroke t' 3 for each power operated valve shall be identified by tht- owner and teated in accordance with IWV-3413(a), (b), and (c). In the above cases of exceptions, the Code permit s the v3Ives to be tested at cold shutdown where:

1. It is not practical to exercise the valves to the posi-t ion requircd to f ulf ill their f unction or to the par-tial position during power operation.

2- Jt is not practical to observe the operation of the valves (with f ail safe act::ators) upon loss of actuator power.

2. Code Requirements--Pumps An inservice test snall be conducted on all safety-related pumps, nominally once ach month during normal plant operation. Each inservice test shall r ade the measurement, observation, and recording of all quan-titiet in Tau.e IWP-3100-1, except bearing temperature, which sh.ll be m asured during at least one inservice test each year.

J e

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V. ATTACHMENT I

1. Decay Hc61 .nd Emergency Core Cooling

,  !.1 V::lvgs;j!Hll and DH12 The r utegorization of vahes SH'.1 and 1 was discussed with the licen-tro at the workino meeti.aq a d leC as an unresolved item for further NRC resiew. Ihc -icensee had includc thete two valves in O.e IST p.ogram as Catrqary I:, passive al"es , and expressed a desire tht they rertain in the program as such. The valves are in series and in the Decay Heat Removal System sut tion f rom the RCS inside con' ;inment. c6ch valve is interlocked c.losed when RCS pr essure is rreater than 350 lb and cannot be opened until reartor pressure is reducod to less than 350 lb. Then, the Decay Heat Removal 5, stem is placed in operation and muit remain operr;ing until the plant is ready to return to pownr. lhe lice.mee stated that the valves r innot be leak tested during cold shutdown because t'ey raust remain open for Uecay Heat Removal Systcm operation and that persunnel hazards exist during power ope ation (i.e., acc.:ssibility, high radiatian, and possible bich pressure in the pipe).

2. R view Finriings During thc course of our review of the Davis-Sesse Unit 1 M T program, we t00nd no other valves that need further review by the NRC for complianco

,*ith tte requirements of 10 CFR 50, ApDendix J.

h O

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VI. ATTACHMLN1 11 lhe tollowing are Category A, B, ano C valves that meet the require-treats et the rohE C0ce,Section XI, and are not f u ll stroke exercised eve ry ~

three months during plant operation. These valves dre specifically identi-fled by the owner and are tull stroke exercised during cold shutoow.is and refueling uutages. LG&G has reviewed all valves in inis attachment and agrees with the licensee thdt testing these valves during power eperution

, is not possible due to the valve type and location, system design, or be c eust: this action would place the plant in an unsafe conoition. We f eel that thue valves should not be exercised during powc wration. These valves are listed Lmluw anc grouped according to tr. in which tney are located,

l. Main Steam 1.1 Category L Valves Category C valves F6100 and 101, main steam isolations, cannut se exercised during power operation. Cycling these valves during normal oper-otion results in loss of main steam to the turDine which couses a reacto.

trip. Partial stroke exercising these valves during normal operation is not passible because partial stroke exercising can only be performed locally at the valvo. ]f these valves were to indvertently fail cit 5ed during test'ng, tne main steam reliefs would lift. The local test station is located in the area which fills with steam from the main steam reliefs.

tutry into this area is strictly controlled during operation. No remote

, partial strcke exercising capability is available. These valves will be f ull streke exercised during cola shutdown.

~

2. f team Generator Secondary System J.1 Cateaorv 6 kalves L:ategory B valves fWoul ana 612, main feedwater isolations, connut be v rciseu during power operation. Cycling these valves during normal c 3r-ation waald cause loss of m in feedweter to the steam generator which would cause reactor trip. Valve design prec'ades partial stroke exercising during normal cperaticn. These valves will be full stroke exercised during cold statdawn.

3. Containment and Penetration Rooms 3.' totegory C Valves tategory C volves CVll/, 191, 18b, 187, hydrogen ailution blowers suction and discharge checks, cannot be exercised during power opcration.

C. ling tn se e volves cati only t;e perf ormed by injc ; .ing air f rom the hyoro-9:n d ilut ion blowers into the containment. This air must tie purged from the tantainment to the environmeit. Purge timt is limiteu to 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year coing nurmal operation. Testing could cause excessive purging with lr

resulting increase in releases to the environmont. No partial stroke exer-cising 15 possible durir.g norn.al operation without injecting air into toc containment. These valves will be full stroke exercised at cold shutdown.

Category C volves CV5080 through 5090, containment vacuum breakers,

, connut i>a eurcisea curing power operation. forward flow cycling can only h4 pertormeu by entering the annular aret between the containment and shiela ouilding and verifying freedom of valve by hand. Entry to this area curing nower optration is strictly controlled and limited to entry only wNo aoso-lutely necessary. ( As per Special Order No. 84-4, Revision 4, daten January 3, 1979). Valve design precludes partial stroke exercising during ntrmal operation. These valves will be verified for freedom of valve move-nient ut colo snutdown.

4. keactor Coolant 4.1 Category b Valves Lattgury U valve RC10, pressurizer spray control, cannot be eaercised during power operation. failure of titis valve in the closeo pc: Mion would r e'.u l t in loss of RC$ pressure control which is required during normG operation. Va lve design precludes partial st roke exercising curin g norma i aperation. Inis volve will ue f ull stroke exercised during cold sautoewn.

5. Makeup and Purification, b.1 (etcgory A Valves category 4 valve MUJ3, normal makeup water to tt e reactor moolant sjstem, cannot ce exercisea during power operation, fcilure of this valve in t" closed position during testing would result in total loss of normal mak eup t o t he RCS. Makeup is required auring normal operation. Valve design precludes partiel stroke exercisir.g during normal operation. Inis alve will be cycled at cold shutdown when makeup water is not requirec.

Lutegory n solve MUPA, letdown isolation, cannot be exercised curing pawer operation. If this volve were to f ail in the closed position during testing, loss of nurmol letdown would resu.t. Letdown is requireo to con-trol re,. tor coolant inventory as the requireo reactor coolant pump seal inyt t ion continuously adds water to the RC5. Loss of pressurizer level CLntrol mula result in a reactor trip. This valve will De exercised and stroke time measured during cold shutdown.

o. Decay Heat and Emergetecy Core Cooling 6.1 Lategory o Velves Lategory B v:;lves HP2A, 26, dL, and 2D, high pressure injection isola-tions, cent t t be exerc ised wnile the RCS is pressurized. No pressure moni-t or ing aevices are installed on the upstream side of inese valves. The upstream piping i., isolated from RC5 pressure by two check valves. Lycling L n: te clves uuring normal operaton may allow high pressure water to be releaseu into the high pressure injection System. These valves wili be e >treked and timea at cole shutdown when the RC5 is depressurizeo.

27

6.2 ktegur,y L Valves Category C valves CF30 and 31, Dhlo eno 7/, low pre:sure injection checks, cannot be exercised during power operation. Forward flow cycl:ng

( an only be per formed by injecting water from the decay heat system into the RCS. This can only be done at cold shutdown when RCS pressure is low enough to permit injet t ion. System operation precludes partial stroke exercising these valves during normal operation when RCS pressure is greater

, tha'i t he decay heat system design pressure. These valves will be forw..ro ilow (ycled at cold shutdown.

7. Component Cooling Water

/.1 Lategory A Valv,es Lategory A valve CCib67B, control rod drive cooling ~ater containment isolution, conntt De exercised during power operation. Cycling this valve wuuld require shutting off cooling water to the control rod drives which con caly be done at cold shutdown. Valve design precludes partial stroke exercising during norma', operation. This valve will be full stroke exer-cased al cold shutoown.

7.c Category B Valves Category b vcive CCl460, makeup pump cooling water supply, canrut De t erciseo cering power operation. Cycling this valve during normal opera-tion or celd shutdown requires snutting off cooling water to the makeup pump coolers which could cause damage to the pumps. Cooling water to tne pumps can only be shut oft during cold shutoown. Valve design precludes partial stroke exercising during norrcal operation. This valve will be full stroke exercised at cold shutdown.

Category B valve CC15b7A, control rod drive cooling water supply, cannot be exercised ". ring power operatior. Cycling tnis valve would require shutting oft cooling water tc the control rod drives whicn can only at cone at cold shu t d on'n . Volve design precludes partial stroke exercising curing normal operatson. This valve will be full stroke exercised at colo shutdown.

9 28

VII. ATTACHMENT III T he P&lDs listed below were used during the Course of this review.

System P&ID Revision Main Steam M-003 29

' f eedwater System M-006B 32 Steam Generator Secondary System M-007 29 Makeup Water Treatment System M-010B 22 Station and lostrument Air M-015 20 Fuel Oil and Diesei Generators M-017 26 Nitrogen Supply M-019 23 Containment and Penetration Rooms M-029A 24 M-029B 24 Reactor Coolant M-030 27 Makeup and Purification M-031 31 Decay Heat and Eme,gency Core Cooling M-033 34 Emerg<fncy Core Cooling, Containment Spray, and Core Flood M-034 20 Spent Fuel Cooling M-335 22 Compr,nent Ccoling Water M-036 2a Peactor Cnolant System Details M-040A 26 Service Water M-041 26 O

29

VIII. ATTACHMENT IV The following valves are never full stroke exercised or have a testing frequency 9reater than each refueling outage.

4

1. CF28 and 29, core flood tank discharge checks

, 2. AF39, 43, 72, 73, 74, and 75, auxiliary feedwater checks to the steam generators.

O s

Y 30