ML19257C337
| ML19257C337 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/31/1979 |
| From: | Lettieri V, Pedersen E, Restivo T BROOKHAVEN NATIONAL LABORATORY |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| CON-FIN-A-3117 BNL-NUREG-26907, NUDOCS 8001280452 | |
| Download: ML19257C337 (62) | |
Text
If1TERIl1 REPORT e
Accession !!o.
Contract Prog' ram or Project
Title:
Inservice Inspection and Testing Program.
Subject of this Document:
Connecticut Yankee (Haddam Neck)
Type of Document.
Informal Report Au thor ( s ) *.
T. Restivo, V. Lettieri, E. Pedersen and R.E. Hall ctober 1 m Date of Document:
Dr. Cy Cheng Responsible 11RC Individual Division of Operating Reactors and NRC Office or Division:
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 This document was prepared primarily for preliminary or internal It has not received full review and approval.
Since there use.
may be substantive changes, this document should not be considered final.
Brookhaven flational Laboratory Upton, 11Y 11973 Associated Universities, Inc.
for the U.S. Department of Energy Prepared for U.S. iluclear Regulatory Comission Washington, D. C.
20555 1825 142 Under Interagency Agreement EY-76-C-02-0016 11RC FIH flo. A-3117
=I 30 seal'C'13Dd Te6101 I!!TERIi1 REPORT Assistance P.ept 8001280
LIMITED DISTRIBUTION L-NUREG
-26907 10RMAL REPORT RECOMMENDATIONS TO THE NRC FOR THE SAFETY EVALUATION REPORT OF CONNECTICUT YANKEE (HADDAM NECK) NUCLEAR PLANT INSERVICE INSPECTION AND TESTING PROGRAM REVISION 1 T. RESTIV0, V. LETTIERI, E.S. PEDERSEN, AND R.E. HALL Ybbb bh0$00%$0, DATE PUBLISHED - OCTOBER 1979 DEPARTMENT OF NUCLEAR ENERGY BROOKHAVEN NATIONAL LABORATORY UPTON. NEW YORK 11973
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N OTIC E he United States Thn reput was prepaird as an acwunt of work sp>nviied bs t Sudcar Regulatory G.a crament. Neither ihr United States nor the United States 4 shcir (ontrat ton, subcontrac ton t;onimission, nor any of their rrnployres, nor any (c.spress or imptied, or anuines any legal lnew of any infortna-t or thcar cinployces, inakes any warran y, bahality or respinnhitity for the accuracy, ownpletenrw or uwfuto ed, or represents that its u tion, apparatus, prmlutt or prm ee dist infringe pinately owned rights.
BNL-NUREG-26907 INFORMAL REPORT LIMITED DISTRIBUTION Recommendations to the NRC for the Safety Evaluation Report of Connecticut Yankee (Haddam Neck) Nuclear Plant Inservice Inspection and Testing Program Revision 1 T. Restivo, V. Lettieri, E.S. Pedersen and R.E. Hall Engineering and Advanced Reactor Safety Division Department of Nuclear Energy Brookhaven Naticnal Laboratory Upton, New York 11973 October 1979 Prepared for U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under Interagency Agreement EY-76-C-02-0016 NRC FIN No. A-3117 1825 145 NRC Research anf Te M.Mnm M?Cn
Notice:
This document contains preliminary information and was prepared primarily for interim use.
Since it may be subject to revision or correction and does not represent a final report, it should not be cited as reference without the expressed consent of the author (s).
1825 146
TABLE OF CONTENTS E x e c u t i v e S umm a ry............................................................ I 1.0 Inservice Inspection Program............................................
2
~
2.0 Pumps, Inservice Testing Program.......................................
11 3.0 Valves, Inservice Testing Program......................................
17 4.0 rold Shutdown Testing of Valves........................................
34 5.0 Program Breakdown......................................................
46 6.0 M i sc e l l a n e o u s C omme n t s................................................. 5 4 Conclusion..................................................................55 1825 147 t
NRC Research and iecanics i
s Ass..istarice epoit
Brookhaven National Laboratory Recommendations to the NRC for the Safety Evaluation Report of Connecticut Yankee (Haddam Neck) Nuclear Plant Connecticut Yankee Atomic Power Company Inservice Inspection & Testing Program (For the 1978-1981 period)
(Docket No. 50-213)
Executive Summary Under contract to the Nuclear Regulatory Commission (NRC), the Reactor Engineering Analysis Group of Brookhaven National Laboratory (BNL) has con-ducted a review of the following Connecticut Yankee Inservice Inspection and Testing Program submittals:
a.
June 20, 1977 (D.C. Switzer to A. Schwencer), Inservice Inspection -
Class 1 and Class 3 Components.
b.
May 26,1978 (D.C. Switzer to A. Schwencer), Inservice Inspection -
Class 2 ccmponents and Tablke IWV-1, Valve Test Program.
c.
July 14,1978 (W.G. Counsil to D.L. Zieman), Inservice Pump Test Program and Valve Test Program (changes to IWV-1).
d.
April 27,1979 (W.G. Counsel to D.L. Zieman), Haddam Neck Plant, In-Service Inspection and Testing Program.
These submittals represent the Inservice Inspection Program and Inservice Pump / Valve Test Program for the 40 month and 20 month periods respectively be-ginning January 1,1978.
The BNL review process culminated with the Safety Evaluation Review (SER) meeting held at the Connecticut Yankee plant on January 17,18, and 19,1978.
Attendees were personnel from the plant, NUSCO, NRC and BNL. Mr. T.J. Restivo (consultant to BNL) and Mr. V. Lettieri (t ') represented BNL.
The recommendations made in this report are based on evaluations which considered:
Practicality within limitations of equipment design and geometry, requirements of Section XI of the 1974 Edition thru Summer of 1975 of the ASME Boiler and Pressure Vessel Code,10CFR50.55a(g), NRC Staff Guidance Letters (November 1976 and January 1978), and topics of numerous NRC Staff /BNL briefings.
The licensee has requested that Code relief be granted for:
6 of the 9 Inservice Inspection relief requests naining (following the withdrawal of 8 requests), 10 of the pump items and 34 of the 50 valves.
Also recommended is that Cold Shutdown Testing be approved for all of the valves against which this request was made.
1826 143 1
1.0 INSERVICE INSPECTION 1.1 Relief Request:
IWB-2600 (Bl.2), IWB 2500 (B-B) a.
Lower Head Peel Segment Meridional Welds (6) b.
Lower Head Peel Segment to Disc Circumferential Weld
~
The examination of these welds as required by IWB-2600 from inside the vessel is restricted by the locations of the adjacent incore instrumentation penetrations.
Examination of those areas ac-cessible between the penetrations and conduits may be performed
~
from the outside surface to the extent practical due to radiation levels.
Code Requirement:
Volumetric examination is required.
The areas shall include tne longitudinal and circumferential welds in the vessel heads.
This includes weld metal and base metal for one plate thickness beyond the edge of the weld.
The examinations perfomed during each inspection interval shall cover at least 10 percent of the length of each longitudinal shell weld and meridional weld, and 5 percent of the length of each cir-cumferential weld and head weld.
For welds on the reactor vessel, examinations may be performed at or near the end of each inspection interval.
Licensee Basis for Relief Request:
The examination of these welds as required by IWB-2600 from inside the vessel is restricted by the locations of the adjacent incore instrumentation penetrations.
Ex-amination of those areas accessible between the penetrations and conduits will be perfonned fran the outside surface to the extent practical due to radiation levels.
The general area radiation levels at this location are expected to be in the 300 to 500 mr/ hour range at 3 feet fran the vessel with 30,000 to 50,000 dpm surface contamination.
Examinations will not be performed if the examiners must receive a whole body dose in excess of 1250 mr in order to complete any one examination.
Examinations will be performed on 5 percent or 10 percent of the total length of each weld as required by the Code.
Examination of these welds will be performed at or near the end of the ten-year inspection interval, as allowed by the Code.
Radiography cannot be utilized as an alternative examination method as access to both sides of the weld would be required.
Surface ex-aminations would require basically the same access as ultrasonic examination and consequently, radiation levels permitting, ultra-sonic examination would be perf~ med.
1825 149 2
Evaluation: Discussions with the licensee at the SER meeting con-cluded that this item should not be considered a relief request at this time.
This inspection is planned for the April 1980 interval, and the licensees' intent is to satisfy the code at that time.
At present, radiation levels and accessibility problems are not accurately known, and no specific justification can be presented for not satisfying the code. A relief request will be submitted at the time of the inspection if it is then determined that the applicable code requirements cannot be met.
1.2 Relief Request:
IWB-2600 (Bl.2), IWB-2500 (B-B).
Closure Head Peel Segment to Disc Circumferential Weld The licensee has requested relief to visually examine the subject weld for leakage during hydrostatic tests in lieu of volumetric ex-aminations.
Code Requirement:
See Code Requirement, Item 1.1 Licensee Basis for Relief Request: The closure head pee) segment is completely enclosed within the pattern of CRDM penetrations in-side the shroud and is not accessible for examination as required by IWB-2600.
During the February,1979 refueling outage, an investigation was made by CYAPC0 and Westinghouse personnel to determine inspectibil-ity of the RPV head peel segment welds.
As can be seen from the sketch, Reference Bl.2, access for the examination of these welds is prohibited by their location relative to the CRDM penetrations, the permanent insulation and the head ventilation shroud sections.
We have also attached photographs of the actual installation which shows the congestion in this area.
Inspection from the inside (clad) surface is not possible because of surface irregularities, and high radiation.
Integrity of these welds will be verified dur-ing the periodic pressure tests.
Evaluation:
The design of the closure head and control rod drive penetration locations prevent volumetric examination of the Closure Head Peel Segment to Disc Circumferential Weld.
As an alternate and continuing inspection of the weld, the licensee has proposed to verify the integrity of these welds during periodic pressure tests.
This is interpreted to be a visual inspection of these welds during each Code required (IWB-5200) system leakage test prior to startup following each reactor refueling outage.
The test is at not less than the system nominal operating pressure at 100% rated reactor power. Other welds on the closure head are examined to code re-quirements and are subject to additional examinations if unac-ceptable indications are revealed. The visual inspection of tne Closure Head Peel Segment to Disc Circumferential Weld during the system leakage test at each refueling outage, and acceptable 1825 150 3
results fran volumetric examination of other closure head welds is the practical alternative to the Code required examination, and it is therefore reconmended that this relief request be granted.
1.3 Relief Request:
IWB-2600 (B2.2), IWB-2500 (B-D).
Pressurizer -
Nozzle to Vessel Welds (6)
Code Requiremant:
The nozzle-to-vessel welds and nozzle-to-vessel radiused section shall be examined to cover 100% of the volume.
All nozzles shall be examined during each inspection interval.
Licensee Basis for Relief Request:
The geometric configuration of the weld surface prevents ultrasonic examination being performed as required by IWB-2600.
Surface examinations will be performed on this weld in lieu of volumetric examination.
Evaluation: The licensees' May 26, 1978 response letter to the Q-1 has deleted Note 6 from the " Code Relief Request" column, and states that " Item 82.2, Category B-D, pressurizer nozzle-to-vessel welds are in accordance with Code requirements.
1.4 Relief Request:
Table IWB-2600 (B3.3) and Table IWB-2500 (B-F).
Steam Generators (Primary Side) Nozzle to Safe End Welds.
Volumetric examinations will be performed to the extent practical.
Code Requirement:
The volumetric examinations performed during each inspection interval shall cover the circumference of 100 per-cent of the welds.
The areas shall include dissimilar metal welds (e.g., safe-end welds) between combinations of carbon, low allow, or high tensile steels and stainless steels, nickel-chronium-iron alloys, nickel-copper alloys.
This shall include the base material for, at least, one wall thickness beyond the edge of weld.
Licensee Basis for Relief Request:
The geauetric configuration and surface condition of the steam generator safe end to pipe weld prevents ultrasonic examinations being performed to the extent re-quired by IWB-2600.
The configuration of the (8) steam generator nozzle to safe-end welds prevents a canplete volumetric examination from being performed. As can be seen from the sketch, Figure B4.5, the carbon steel nozzle casting on one side and the geometry of the safe-end forging on the other side prevent full ultrasonic coverage from being possible.
To supplement the limited 42 refracted L-wave ex-aminations of the weld, transducers of other characteristics will be utilized to the extent practical, as will surface examination techniques.
It will be possible to perform a Code examination of about 60". of this weld design.
1825 151 4
Evaluation: Approximately sixty percent (60%) of the Steam Genera-tors.(Primary Side) Nozzle to Safe End Welds will be inspected to Code requirements. The configuration of the (8) steam generator nozzle to safe-end welds prevents approximately forty percent (40%)
of the welds from being volumetrically examined. The carbon steel nozzle casting on one side and the geometry of the safe-end forging on the other side prevent full ultrasonic coverage from being per-formed. The Licensee proposes to supplement the limited 42* re-fracted L-wave examinations of the weld with transducers of other characteristics to the extent practical, and with surface examina-tion techniques. The Licensee's proposed examination and supple-mented examinations are the practical alternative to the Code required examinations, and it is therefore recommended that this relief request be granted.
1.5 Relief Request:
Table IWB-2600 (B3.2) and Table IWB-2500 (B-D).
Regenerative Heat Exchanger Nozzle to Vessel Welds.
See Relief Request, Item 1.3 Evaluation: The notes taken by BNL at the draft SER meeting (Janu-ary 17 thru 19,1979) clearly show the licensee deleting the note requesting relief and stating the Code would be met.
In the event that the Licensee cacnot.neet the requirements of the Code, a re-lief request with sufficient technical justification should be sub-mitted.
1.6 P.elief Request:
IWB-2600 (B3.7) IWB-2500 (B-H).
Regenerative Heat Exchanger Integrally Welded S.apports.
Volumetric examinations cannot be accomplished to the extent re-quired by IWB-2600.
Code Requirement:
In the case of vessel support skirt, the volu-metric examination perfomed during each inspection interval shall cover at least 10 percent of the circumference of the weld to the ve ssel.
In the case of support lug attachments,100 percent of the welding to the vessel shall be examined.
The areas shall include the integrally-welded support attachment (e.g., support skirts). This includes the welds to the vessel and the base metal beneath the weld zone and along the support attach-ment member for a distance of two support thicknesses.
~
Integral support pads on nozzles are excluded.
Licensee Basis for Relief Request: The integrally welded supports are attached by fillet welds.
The configurations of such welds is such that examinations cannot be perfomed to the extent required by IWB-2600 and only the base material of the component wall can be examined by ultrasonic techniques.
Surface examination will be performed on integrally welded attachments to supplement the volumetric examination.
1825 152 s
Evaluation: The licensee has satisfactorily demonstrated that the configurition of these welds make it impossible to perfom volu-
~
metric examinations to the extent required by the code.
In that ultrason'c exams are accomplished where practical and 100 percent surface exams (penetrant) are also accomplished, it is recommended that relief be granted.
1.7 Relief Request:
Table IWB-2600 (B4.1), Table IWB-2500 (B-F).
Piping Pressure Boundary - Safe End to Pipe Welds.
Volumetric examinations cannot be accomplished to the extent required by IWB-2600.
Code Requirement:
See Code Requirement, Item 1.4.
Licensee Basis for Relief Request:
The examination is limited by the nozzle, safe end geometry and surface condition, and the sur-face condition of the weld. The surface on the pipe side of the weld, which is a cast elbow, is machined for a distance of approxi-mately 3 inches from the edge of the weld. Ultrasonic examination is limited to this distance from the edge of the weld.
Evaluation:
The resubmitted ISI/IST Program, cover letter dated April 27, 1979, Attachment 1, Haddam Neck Plant, In-Service Inspcc-tion and Testing Program shows no relief requested. Therefore, it is recommended that this relief request be denied.
1.8 Relief Request:
Table IWB-2600 (4.5), Table IWB-2500 (B-J).
Fi~ ping Pressure Boundary - Circumferential and Longitudinal Pipe Weld.
Volumetric examination cannot be accomplished to the extent re-quired by IWB-2600.
Code Requirement:
Twenty-five percent (25%) of the circulferential Joints including the adjoining one (1) foot sections of longitudi-nal joints and 25% of the pipe branch connection joints shall be examined each inspection interval.
Licensee Basis for Relief Request:
In Loop 1 of the safety injec-tion system, weld Number 1, a 4 inch elbow to nozzle weld is not completely inspectable due to geometric configuration.
This weld will be volumetrically examined to the extent yactical.
Surface examinations will be used to supplement the volumetric examina-tions.
Limited coverage of the steam generator safe-end to piping weld, a Category B-J weld, results from the geometry of the safe-end and the irregular surface condition of the weld. A volumetric examina-tion of about 60% of this weld will also be possible.
Surface examinations will be utilized to supplement the limited volumetric examinations.
1825 153 6
Evaluation: The Licensee states that due to geometric configura-tion and the irregular surface condition of the weld, a volumetric examination cannot be accomplished to the extent required by IWB-2600.
However, the Licensee does not provide any technical justification, such as a word description, drawings or photographs, that supports this determination.
He proposes to perfonn a volu-metric examination of approximately sixty percent (60%) of the weld, and to supplement this examination with surface examinations.
The Licensee's proposed examinations could be the practical alter-native to the Code required examinations provided the Licensee demor;strates the impracticality of full compliance. Therefore, until such time as the Licensee provides adequate technical justi-fica *. ion to support less than full compliance with the Code, it is recommended this request be denied.
1.9 Relief Request:
Table IWB-2600 (B4.6), Table IWB-2500 (B-J).
Branch P1pe Connection Welds Exceeding 6" Diameter.
The licensee has requested relief from volumetric examinations to the extent reqtiired by IWB-2600.
Code Requirement:
See Code Requirement, Item 1.8.
Licensee Basis for Relief Request:
The geometric configuration of the weld surface prevents ultrasonic examinations from being per-formed to the extent required by IWB-2600.
Examinations will be performed to the e) tent practical from the pipe and nozzle surfaces adjacent to the we16 Surface examination of the weld will be per-fomed to supplement te volumetric examination.
Evaluation:
See Evaluation, Item 1.7.
1.10 Relief Recuest:
IWB--2600 (B4.9), IWB-2500 (B-K-1).
Piping Pres-sure Bouncary - Integrally Welded Supports.
The licensee has requested relief from volumetric examinations to the extent required by the code.
Code Requirement:
The volumetric examinations perfomed during each inspection interval shall cover 25 percent of the integrally-welded supports.
The areas shall include the integrally-welded external support attachments. This includes the welds to the pressure-retaining boundary and the base metal beneath the weld zone and along the support attachment member for a distance of two support thicknes-ses.
Licensee Basis for Request:
The integrally welded supports are attached by fillet welds. The configurations of such welds are such that examinations cannot be perfonned to the extent required by IWB-2600 and only the base material of the component wall can be examined by ultrasonic techniques.
Surface examination will be 1825 154
perfomed on integrally welded attachments to supplement t".e volumetric examination.
Evaluation:
The licensee has satisfactorily demonstrated that the configuration of these welds make it impossible to perfom volu-metric examinations to the extent required by the code.
In that ultrasonic exams are accomplished where practical and 100 percent surface exams (penetrant) is also accomplished, it is recommended that relief be granted.
1.11 Relief Request:
IWB-2600 (B5.2), IWB-2500 (B-G-1).
Reactor Coolant Pumps - Pressure Retaining Bolting (when removed).
This relief request will be withdrawn.
The licensee tests the subject bolts in-place to IWB-2600 (B5.1).
1.12 Relief Request:
IWB-2600 (B5.6), IWB-2500 (B-L-1).
Reactor Coolant Pumps - Pump Casting Welds.
This relief request will be withdrawn at this time.
The licensee has stated that, " Volumetric examinations as required by IWB-2600 will be attempted utilizing radiographic techniques. The success of these examinations will be dependent upon the availability of high energy gamma sources and the level of background radiation.
Internal fittings in the pump may also restrict the extent of ex-aminations performed." Any request for relief will be made if re-quired at the time the proposed exams are attempted.
1.13 Relief Request:
IWB-2600 (B6.2), IWB-2500 (B-G-1).
Valve Pressure Boundary - Pressure Retaining Bolting.
This relief request will be withdrawn.
The licensee tests the subject bolts in-place to IWB-2600 (B6.3).
1.14 Relief Request:
IWC-2600 (C1.2), IWC-2520 (C-B).
Residual Heat Exchangers - Nozzle to Yessel Welds.
The licensee has requested that surface examinations be conducted on the nozzle to channel weld in lieu of volumetric examination.
Code Requirement:
The volumetric examination shall cover 100 percent of the nozzle-to-vessel attachment welds.
Licensee Basis for Reques+"
The einforcing collar on the nozzle to cha.inel weld precludes volu-
- ic exmnination. A surface ex-amination of these welds wil' De anducted.
Evaluation:
The welded heat exchangers head precludes access and volumetric exam from within. The weld configuration described also precludes volumetric exam from outside, therefore, it is agreed that surface testing is the only practical alternative.
It is re-commended that code relief be granted.
M25 155 8
1.15 Relief Request:
The resubmittal ISI/IST Program, cover letter dated April 27, 1979, Attachment 1, Haddam Neck Plant, In-Service Inspection and Testing Program shows relief requested.
- However, the notes taken by BNL at the draft SER meeting (January 17 thru 19, 1979) clearly show that there are no examinations scheduled for the inspection period covered by this submittal where relief re-quests are required.
Item Category System C2.1 C-F Residual Heat Removal C2.2 C-F Residual Heat Removal C2.3 C-F Residual Heat Recoval C2.1 C-F Chemical and Volume Control C2.2 C-F Chemical and Volume Control C2.3 C-F Chemical and Volume Control C2.1 C-G Main Steam C2.2 C-G Main Steam C2.3 C-G Main Steam C2.1 C-G Feedwater C2.2 C-G Feedwater C2.3 C-G Feedwater 1.16 General 1.16.1 Relief Request:
The licensee requests that calibration blocks be made to the requirements of Article T-434.1 in Winter 1976 Addenda of Section V in lieu of I-3121 of Section XI.
Licensee Basis for Request:
The reason this alternative is requested is that the Code requires that calibration blocks for the examination of welds in Ferritic vessels 2-1/2 inches thick and greater be fabricated from material taken from the component nozzle drop out or material from the component prolongation.
As a third alternative, when it is not possible to fabricate the block from material taken from the component, the block may be fabricated from a material of a specification included in the applicable ex-amination volumes of the component.
It is required that the acoustic velocity and attenuation of such a block be demonstrated to fall within the range of straight beam longitudinal wave veloc-ity and attenuation found in tha unclad components.
For the components in Connecticut Yankee particularly, the pressurizer and steam generators, it will be impossible to meet the requirements of alternatives 1 or 2.
Materials of the specifica-tion are readily available, but because all the components involved are clad on the inner surface, it would be impossible to obtain a comparison of sound beam velocities and attenuations in the unclad component.
Evaluation:
Since there is no material available from a drop out or component prolongation, the licensee has canmitted to fabricate 9
1825 156
the calibration block from a material of the same specification, product form and heat treatment as one of the materials being joined.
This is in accordance with T-434.1.1 of the Winter 1976 Addenda of Section V.
We agree that the requirement of I-3121 that requires the acoustic velocity and attenuation of the block to be demonstrated to fal' within the ranges found in the unclad com-ponents is impractical since these components are clad.
In that this is so, and that the licensee ultrasonically scans the subject nozzles from the unclad side, it is recommended that relief be granted as requested.
1.16.2 Relief Request: The licensee requests to use Appendix III of Section XI in lieu of Article 5 of Section V as a guideline for piping weld inspection.
Licensee Basis for Request:
This alternative is requested because the Code provides no other guideline for the inservice examination of piping welds.
Evaluation:
IWA-2232 of Section X states that where Appendix I is not applicable, the provisions of Article 5 of Section V shall ap-ply regarding ultrasonic examinations.
Appendix III of Section XI, Winter 1975 Addenda, provides rules for ultrasonic examination of ferritic steels and Supplement 7 provides additional guidance for examination of austenitic welds.
Therefore, it is recommended that the use of either Article 5 or Appendix III be accepted.
j82h l57 10
2.0 PUMPS, INSERVICE TESTING PROGRAM 2.1 Charging Pumps 2.1.1 Relief Request:
Inlet pressure for pumps P-18-1A and P-18-1B will not De measured during tests.
Code Reauirement:
Pump inlet pressure measurement is required per Table IWB-3100-1.
Licensee Basis for Relief Request:
Instrumentation for direct measurement of pump inlet pressures is not available.
It is proposed to use the static pressure of the volume control tank (head and ullage pressure) as the inlet pressure reference when checking the operations of the pumps monthly.
Evaluation:
The plumbing from the volume control tank (VCT) to the charging pump inlets is a fixed resistance system.
Based on this, the licensee's plan to detemine and reference the VCT pressure and head to establish pump inlet differences (used to compare outlet pressure readings) is considered an acceptable alternative.
It is recanmended that relief be granted fran the code requirement to measure inlet pressure.
2.2 Residual Heat Removal Pumps 2.2.1 Relief Request:
Flowrate and pump inlet pressure will not be measured during the monthly tests for pumps P-14-1A and P-14-18.
Code Requirement:
a.
Table IWP-3100-1 requires that flowrate be measured when testing pumps that operate in a variable hydraulic resistance sys-tens.
b.
Table IWP-3100-1 requires that inlet pressure P1 be measured during pump tests.
Licensee Basis for Request:
a.
The RHR pumps are run on recirculation monthly per tech. Spec.
4.3.
In this mode, flow is restricted by a 3/4 inch recirculation line, and is therefore meaningless.
Flowrate measurements will be made during cold shutdowns when the RHR system is in nomal oper-ation.
b.
Instrumentation is not installed which will permit the measuring of inlet pressure for these pumps.
It is proposed to use the static head of the refueling water storage (RWS) tank as the inlet pressure reference.
11 1825 153
Evaluation:
a.
The RHR systems design precludes operating the pumps in any other mode but the recirculation mode while the plant is in normal operation. The recirculation circuit is only sized to flow < 1 percent of the RHR system's design rated flow (5000 GPM per pump).
This low flow is not considered valid for evaluating the hydraulic performance of a centrifugal pump. This monthly recirculation test with either code required parameters recorded or detemined, would serve as an operability test.
The testing proposed at cold shutdowns with design flowrates and code required parameters (less direct measured inlet pressure),
would be a valid hydraulic performance test for the pumps.
In that the RHR system is not designed with the capability to record all code required parameters during monthly tests, and that the licensee has proposed monthly operability tests and design flow hydraulic perfomance tests at cold shutdowns, it is recommended that relief be granted from the code requirement to measure flow-rate monthly, b.
The plumbing from the RWST to the RHR pump inlets is a fixed resistance system.
Based on this, the licensee's plan to determine and reference the RWST to pump inlet static head to establish inlet differences (used to compare outlet pressure readings) is con-sidered an acceptable alternative.
It is recommended that relief be granted from the code requirement to measure inlet pressure.
2.3 High Pressure Safety Injection Pumps 2.3.1 Relief Request:
Flowrate, pump inlet pressure, and bearing temperature will not be measured during the monthly tests for pumps P-15-1A and P-15-1B.
Code Requirement:
a.
Table IWP-3100-1 requires that flowrate be measured when testing pumps that operate in a variable hydraulic resistance sys-tem.
b.
Table IWP-3100-1 requires that pump inlet pressure P1 be measured during pump tests.
c.
The bearing temperature of all centrifugal pump bearings, and main shaft bearings of reciprocating pumps shall be measured at points selected to be responsive to changes in the temperature of the bearing.
12 1825 159
Licensee Basis for Request:
a.
The HPSI system does not have instrumentation for measuring flowrates as required by IUP-3100.
b.
Instrumentation is not installed which will permit the measuring inlet pressure for these pumps.
It is proposed to use the static head of the RWS tank as the inlet pressure reference.
c.
Pump bearing temperature cannot be measured on those pumps since the bearings are located deep inside the pump casing and are surrounded by the oil reservoir.
There are no design provisions for directly measuring pump bearing temperature.
Hand held pyrometers in contact with surface of the pump casing results in questionable data.
Evaluation:
a.
The HPSI pumps are run monthly on recirculation.
This recirculation flow is approximately 60 percent of the design flow.
In that the pump recirculation path is a fixed hydraulic resistance system from/to the RWST, flow measurement is not required by code.
The monthly 60 percent design flow tests, and a planned 100 percent flow test at the 1980 refueling interval (revealed at the SER meet-ing) are believed sufficient to satisfy the code requirement.
Therefore, a request for code relief is not required in this case.
b.
The plumbing from the RWST to the HPSI pump inlets is a fixed resistance system.
Based on this, the licensee's plan to determine and reference the RWST to pump inlet static head, to establish in-let differences (used to compare outlet pressure readings) is con-sidered an acceptable alternative.
c.
It is agreed that measurement of pump bearing temperature on these pumps is considered impractical based on their design. A monthly check on the lubrication level and vibration tests are ac-complished per code.
Based on this, it is recommended that relief from code requirement to measure Tb be granted.
2.4 Service Water Pumps 2.4.1 Relief Request:
Inlet pressure will not be measured during monthly tests for pumps P-37-1A, P-37-1B, P-37-1C, and P-37-1D.
Code Requirement:
Pump inlet pressure measurement is required per Table IWP-3100-1.
Licensee Basis for Request:
Instrumentation for direct measurement of pump inlet pressure is not available.
It is proposed to es-tablish inlet pressure references during the tests by referencing the head fran the level of the river to the pump suction.
1825 100
Evaluation:
The licensee has stated that the path frcm the river to the pumps is a fixed hydraulic resistance system.
Referencing the river water level with respect to the pump inlets is therefore considered an acceptable alternative to direct measuring of pump inlet pressure.
It is therefore recommended that relief be granted from the code requirement to measure pump inlet pressure.
2.5 Auxiliary Steam Generator Feedwater (ASGF) Pumps 2.5.1 Relief Request:
Flowrate will not be measured during monthly tests for pumps P-32-1A and P-32-18.
Code Requirement: Table IWP-3100-1 requires that flowrate be measured when testing pumps that operate in a variable hydraulic resistance system.
Licensee Basis for Request: The auxiliary steam generator feedwater pumps (steam driven) recirculation test circuit does not contain flow instrumentation.
Flowrate is detemined along with the other code required parameters during refueling outages when a special test setup allows level changes in the demineralized water storage tank (DWST) to be measured and timed.
Evaluation:
The ASGF system's design is such that during normal plant operation, the pumps can only be operated on recirct:lation flow from the DWST.
The recirculation circuit flow is ap-proximately 50 GPM (approximately 10 percent of the ASGF pump's de-sign flow).
Such a low flowrate is not considered valid for evaluating the hydraulic perfomance of a centrifugal pump.
The monthly tests with the other parameters recorded would serve as operability tests.
The testing proposed at refuelings with design conditior, flowrates (detenained) and other code parameters measurev., would be a valid hydraulic perfomance test for the pumps.
In that the ASGF system is not designed with the capability to measure flow during the monthly tests, and that the licensee has proposed monthly operability tests, and design flow hydraulic perfomance tests at refuelings, it is recommended that relief be granted from the code requirement to measure flowrate monthly.
2.6 Low Pressure Safety Injection Pumps 2.6.1 Relief Request:
Low Pressure Safety Injection Pumps P-92-A and P-92-B.
The licensee has requested relief from the following code requirements:
1825 161 14
a.
Directly measuring pump inlet pressure.
b.
Measuring flourate during monthly tests.
c.
Measuring bearing temperatures.
Code Requirement:
a.
Table IWP-3100-1 requires that inlet pressure be measured during pump tests, b.
Table IWP-3100-1 requires that flowrate be measured when testing pumps that operate in a variable hydraulic resistance sys-tem.
c.
The bearing temperature of all centrifugal pump bearings, and main shaft bearings of reciprocating pumps shall be measured at points selected to be responsive to changes in the temperature of the bearing.
Licensee Basis for Request:
a.
The LPSI system is not designed with provisions for measuring flowrate during monthly pump tests.
b.
The LPSI system is not designed with provisions for measuring pump inlet pressure.
It is planned to use the static head pressure of the RWST as the inlet pressure reference for the LPSI pumps.
c.
Pump bearing temperature cannot be measured on this pump since the bearings are located deep inside the pump casing and are sur-rounded by the oil reservoir.
There are no designed provisions installed for directly measuring pump bearing temperatures.
Hand held pyrometers in contact with surface of the pump casing results in questionable data.
Running the pumps for prolonged periods to obtain stabilized temperature data is believed detrimental because the pumps are run at 1cw flow (< 10 percent of design) in the recirculation mode.
Evaluation:
a.
The LPSI systems design precludes operating the pumps in any other mode but the recirculation mode while the plant is in normal operation. The recirculation circuit is a fixed resistance cir-cuit, and as such would not require flow measurement for pump perfonnance evaluation.
However, the recirculation circuit is only sized to pass < 10 percent of the LPSI system's design rated flow (5000 GPM per pump).
This low flow is not considered valid for evaluating the hydraulic performance of a centrifugal pump.
This monthly circulation test with other code required parameters re-corded or determined would serve as an operability test.
1826 Ic2 15
The licensee is presently proposing to run design flow hydraulic performance test on the pumps at the 1980 refueling interval, and approximately every 5 years following.
The proposed frequency of the performance tests is questionable, and should be further re-viewed by the staff.
Until this is accomplished, it is recanmended that the request for relief be denied at this time.
b.
The plumbing from the RWST to the LPSI pump inlets is a fixed resistance system.
Based on this, the licensee's plan to detennine and reference the RWST to pump inlet static head to establish inlet differences (used to compare outlet pressure readings) is con-sidered an acceptable alternative.
It is recommended that relief be granted from the code requirement to measure inlet pressure.
c.
It is agreed that measurement of pump bearing temperature on these pumps is considered impractical based on their design.
A monthly check on the lubrication level and vibration tests are ac-complished per code.
Based on this, it is recommended that relief fran code requirement to measure Tb be granted.
i826 163 6
3.0 VALVES, IflSERVICE TESTIftG PROGRAM
3.1.1 General
The scope of this review is limited to those valves which perfem a safety related function.
Safety related valves, for the purpose of IST, have been defined as those valves that are neces-sary to function to safely shutdown the plant and/or mitigate the consequences of an accident. As a minimum, all valves that receive a containment isolation signal or a safety injection signal shall be included in the IST program.
The following guidelines were developed after review of some initial IST programs.
3.1.2 Leak Testing of Valves Which Perform a Pressure Isolation Function There are several safety systems connected to the reactor coolant pressure boundary that have design pressures that are below the re-actor coolant system operating pressure.
It is required that there are redundant isolation valves faming the interface between these high and low pressure systems to prevent the low pressure systems from being subjected to pressures which exceed their design limits.
In this role the valves are perfonning a pressure isolation func-tion.
The redundant isolation provided by theee valves regarding their pressure isolation function is important.
It is considered neces-sary to provide assurance that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity.
For this reason it is believed that some methods, such as leak testing, should be used to assure their condition is suf-ficient to maintain this pressure isolation function.
In the event that leak testing is selected as the appropriate procedure for reaching this objective the staff believes that the following valves should be categorized as A or AC and leak tested in accordance with IWV-3420 of Section XI of the applicable edition of the ASME Code.
These valves are:
SI-MOV-861A, 861B, 861C, 8610 (Safety Injection)
SI-CV-862A, 8628, 862C, 862D (Safety Injection)
SI-V-863A, 863B, 863C, 863D (Safety Injection)
CD-MOV-871A, 871B (Safety Injection)
FH-M0V-578, 535, 522, 508 (Leop Fill)
FH-M0V-562, 507 521, 534, 544, 310 (Loop Drain)
RH-MOV-m,?, S04, 780, 781 (RHR)
FH-CV-296 (Loop Fill)
FH-
-502, 516, 521, 534, 525 (Loop Drain)
We have discussed this matter and identified the valves listed above to the licensee.
The licensee has agreed to consider leak testing these valves in accordance with IWV-3420 of the applicable edition of the ASME Code and to categorize these valves with the i825 h4 1,
appropriate designation.
If the licensee determines that leak testing is not necessary because there are other methods that the licensee has and will use to detemine each valve's condition, the licensee will provide to the NRC for evaluation on a valve-by-valve basis the details of the method used that clearly demonstrates the condition of each valve.
3.1.3 Containment Isolation Valves The Appendix J review for this plant is a completely separate review from this IST program review.
However, the deteminations made by that review are directly applicable to the IST program.
The present IST submittal should be acceptable until the Appendix J review is completed. At that time, the licensee will be required to amend his IST program to reflect the conclusions of the Appendix J review.
3.1.4 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 superceded by Appendix J requirements for CIVs.
The staff has con-cluded that the applicable leak test procedures and requirements for CIVs are determined by 10 CFR 50 Appendix J.
Relief from para-graph IWV-3420 (a-e) for CIVs presents no safety problem since the intent of IWV-3420 (a-e) is met by the Appendix J requirements.
Sections f and g of IWV-3420 must be met by the licensee otherwise relief must be requested from these paragraphs.
It should be noted that these paragraphs are only applicable where a type C Appendix J leak test is performed.
The safety function of CIVs and thus passive CIVs is to perfom leak limiting barriers.
These are valves, which are nomally closed, thus in their safety position, and are not required to open to mitigate the consequences of an accident or to safely shutdown the plant.
Therefore, the operability of these valves is inconsequential with regard to the safety function for which they perfo rm.
It is thus concluded that the quarterly stroke and stroke time measurement are meaningless for passive CIVs.
3.1.5 Stroke Requirements for Passive Valves These valves are normally closed and thus in their safety-related position, and are not required to change position, that is to open or close to mitigate the consequences of an accident or to safely shutdown the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function for which they perform.
It is thus concluded that the quarterly stroke and stroke time measurement are meaningless for passive valves.
1 s
105 18
3.1.6 Valves to be Tested at Cold Shutdowns Valve testing should commence not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or plant is ready to return to power. Completion of all valve testing is not a prerequisite to return to power.
Any testing not completed at one cold shutdown should be perfomed during subsequent cold shutdowns to meet the Code specified testing frequency.
In the case of valves exercised less frequently than cold shutdown (i.e., refueling), relief fran the Code requirement must be re-quested. These cases ara treated as such in this review.
3.1.7 Valve Exercising Requirements ASME Code,Section XI, Subsection IWV-3410(a) requires that Code Category A and B valves be exercised once every 3 months, with the exceptions as defined in IWV-3410(b-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-3420(b).
IWV-3/00 requires no regular testing for Code Category E valves.
Ope r-ational checks, with appropriate record entries, shall record the position of these valves before operations are perfomed and after operations are completed and shall verify that each valve is locked, or sealed.
The limiting value of full stroke time for each power operated valve shall be identified by the owner and tested in accordance with IWV-3410(c).
In the above exceptions, the code pennits the valves to be tested at cold shutdown where:
a.
It is not practical to exercise the valves to the position required to fulfill their function or to the partial position dur-ing plant operation.
b.
It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.
3.1.8 Changes to the Technical Specifications In a November 1976 letter to the Connecticut Yankee Atomic Power Company, the NRC provided an attachment entitled "NRC Staff Guidelines for Excluding Exercising (Cycling) Tests of Certain Valves During Plant Operation." The attachment stated that when one train of a redundant system such as in the ECCS is inoperable, nonredundant valves in the remaining train should not be cycled since their failure would cause a loss of total system function.
For example, during power operation in same plants, there are stated minimum requirements for systems which make up the ECCS which allow certain limiting conditions for operation to exist at any one time and if the system is not restored to meet the re-quirements within the time period specified in a plant's Technical Specification the reactor is required to be put in some other mode.
Furthermore, prior to initiating repairs all valves and interlocks 19 1825
!c6
in the system that provide a duplicate function are required to be tested to demonstrate operability immediately and periodically thereafter during power operation.
For such plants this situation would be contrary to the NRC guideline as stated in the document mentioned above.
The Connecticut Yankee Nuclear Plant's Technical Specifications may have requirements that are contrary to the above mentioned guidelines. We have discussed this situation with the licensee and the licensee has agreed to review the Technical Specifications and to consider the need to propose Technical Specification changes which would have the effect of precluding such testing.
If, after making this consideration, the licensee determines that the TS should not be changed because the guidelines are not ap-plicable or if that the guidelines cannot be followed, the licensee shall submit to the NRC the reasons that led to their detennination for each potentially affected valve.
In the licensee submittal, the potentially affected sections of the TS, in addition to the valves, should be identified.
3.2 General Relief Request 3.2.1 Relief Request:
The following Category A CIV valves will meet Ap-pendix J leak testing requirenents in lieu of Section XI re-quirements.
(This relief request was not discussed exactly as written during the draft SER meeting.
The intent, however, was discussed. To be consistent with later reviews of IST Programs and Connecticut Yankee's resubmittal program this relief request has been included in the revised BNL report.)
Valve Valve Valve Valve DH-TV-1847 CC-CV-885 SS-V-999 CH-CV-305B BD-V-506 CC-TV-1831 SS-V-999A CH-CV-305C BD-V-515 CC-V-884 PW-CV-139 CH-CV-305D BD-V-522 VS-TV-1848 PW-CV-140 DH-TV-1841 BD-V-529 S0V-12-1 HC-V-212 DH-TV-1844 BD-TV-1312-1 VS-CV-1104 PU-V-242 FM-MOV-31 BD-TV-1312-2 CC-CV-731 PU-V-24 2A FW-CV-192 BD-TV-1312-3 FCV-611 HS-CV-295 FW-CV-194 BD-TV-1312-4 VH-V-507 HS-CV-295A FW-CV-19 6 VH-V-597B CC-FCV-608 BV-1-1B FW-CF-198 DH-TV-554 CC-CF-721 HCV-1101 FH-CF-29 6 WD-H IC V-1840 WG-A0V-558 BV-1-1A WD-TV-1846 WG-TV-1845 P50 DH-TV-1843 SS-V-984A SA-V-411A DH-TV-1844 SS-TV-950 SA-V-413 LM-TV-1811A SS-TV-955 LD-A0V-202 LM-TV-1811B SS-TV-960 LD-A0V-203 1826 167
~
Valve Valve Valve Valve U1-TV-1812 SS-TV-965 LD-A0V-204 CC-CV-853 DH-TV-1842A CH-TV-334 CC-TV-1411 DH-TV-1842B CH-CV-305A Code Requirement:
IWV-3420 Valve Leak Rate Test.
Category A valves shall be leak-tested.
Tests shall be conducted at the same (or greater) frequency as scheduled refueling outages, but not less than once every two years.
Valve seat leakage tests shall be made with the pressure differential in the same direction as will be ap-plied when the valve is performing its function with the following exceptins:
1.
Any globe type valve may be tested with pressure under seat.
2.
Butterfly valves may be tested in either direction, provided their seat construction is designed for sealing against pressure on either side.
3.
Gate valves with two-piece disks may be tested by pressurizing them between the seats.
4.
All valves (except check valves) may be tested in either direction if the function differential pressure is 15 psi or less.
5.
The use of leakage tests involving pressure differentials lower than function pressure differentials are permitted in those types of valves in which service pressure will tend to diminish the over-all leakage channel opening, as by pressing the disk into or onto the seat with greater force.
Gate valves, check valves, and globe type valvas having function pressure differential applied over the seat, are examples of valve applications satisfying this re-quirement.
When leakage tests are made in such cases using pres-sure lower than function maximum pressure differential, the ob-served leakage shall be adjusted to function maximum pressure dif-ferential value by clculation appropriate to the test media and the ratio between test and function pressure differential assuming leakage to be directly proportional to the pressure differential to the one-half power.
6.
Any valves not qualifying for reduced pressure testing as defined in 3420(c)(5) shall be leak-tested at full maximum function pressure differential, with adjustment by calculation if needed to canpensate for a difference between service and test media.
Valve seat leakage may be determined by:
1.
Draining the line, closing the valve, bringing one siue to test pressure, and measuring leakage through a downstream telltale con-nection, or, 18b5168
2.
By measuring feed rate required to maintain pressure between two valves, or between two seats of a gate valve, provided the total apparent leak rate is charged to the valve or gate valve seat being tested, and that the conditions required by IWV-3420(c) are satisfied.
The test medium shall be specified by the Owner.
Basis for Relief Request: Appendix J leak testing meets the intent of Section XI Requirements.
Operability testing of these valves during normal plant operation could cause a loss of containment integrity and/or system function if a valve failed in a non-conservative position.
Because the safety function of these valves is to provide containment integrity by their leak tightness, these valves are and have been leak tested under Tech. Spec. requirements based on " App.
J, Type C" tests.
See Tech. Spec. 4.4.
In that leakage tests are conducted to satisfy containment integrity requirements, waivers from IWV-3420(b) " Analysis of Leak-age Rates" and (g) " Corrective Action" are requested.
CYAPC0 proposes to demonstrate leak tightness by following containment integrity rules, which observe an integrated acceptance criterion for these test parameters, in lieu of individual valve performance measurement.
CYAPC0 proposes to use existing procedures fc,r exercising and leak testing of valves used as containment isolation.
Modifications to procedures as agreed upon by CYAPCO and NRC Staff concerning " App.
J" tests and exemptions will be reflected in this program.
All " active" containment isolation valves are exercised at cold shutdowns by a procedure to demonstrate the Reactor Containment Atmospheric Control System Functions properly should an czarpres-sure situation exist in the reactor containment, by verifying that all automatic actions required of the system under this condition do occur.
Evaluation:
The Category A valve leak rate test requirements of IWV-3420(a-e) have been superceded by Appendix J requirements for CIVs.
The staff has concluded that the applicable leak test procedures and requirements for CIVs are detennined by 10 CFR 50 Appendix J.
Relief from paragraph IWV-3420(a-e) is met by the Ap-pendix J requirements.
Sections f and g of IWV-3420 m m 5 mG by the licensee otherwise relief must be requested fri U t paragraphs.
It should be noted that this relief request a ? 6
> y where a type C Appendix J r
leak test is performed.
Thwef'sre, it is recommended that relief be granted from the leak test requiremeni.; of Section XI for the CIVs listed above.
22
}h2b lb9
3.2.2 Relief Request:
The licensee requests a waiver frm the requirements of IWV-3410(c)(3).
p de 2equiremer+:
IWV-3410(c)(3).
If an increase in stroke time of 25% or more from the previous test for valves with stroke times greater than ten seconds or 50% or more for valves with stroke times less than or equal to ten seconds is obseru, test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed.
In any case, any abnormality or erratic action shall be reported.
Basis for Relief Request:
The licensee requests a waiver from the requirements of IWV-3410(c)(3) to enable engineering dispositions to be made on stroke time variations without necessarily committing to monthly tests.
The stroke times have been derived basically from plant design information and reviewed by plant operations personnel to verify consistency with time restraints dictated by normal and emergency conditions.
Evaluation:
The licensee has not submitted sufficient justification for supporting his request for relief from the re-quirements of IWV-3410(c)(3).
In addition, this does not meet the intent of Section XI.
It is therefore recommended that the request for relief be denied and that the licensee be requested to meet the requirements of IWV-3410(c)(3).
3.2.3 Relief Request: The licensee requests a waiver from the requirements of IWV-3410(g).
Code Requirement:
IWV-3410(g) Corrective Action.
If a valve fails to exhibit the required change of valve stem or disk position by this testing, corrective action shall be initiated immediately.
If the conditions is not, or cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the valve shall be declared inoperative.
When corrective action is re-quired as a result of tests made during cold shutdown, the con-dition snall be corrected before startup.
A retest showing ac-ceptable operation shall be run following any required corrective action before the valve is returned to service.
Basis for Relief Request:
The licensee requests a waiver from the requirements of IWV-3410(g) in that the operating status of a valve would best be determined by the plant management after an en-gineering and operations review of the test data.
Evalu;. ion: The licensee has not submitted sufficient justification for supporting his request for relief from the re-quirements of IWV-3410(g).
In addition, this does not meet the ;n-tent of Section XI.
However, it is possible that there exists a technical justification to support a relief request from this Code requirement for particular valves. The plant's Limiting Conditions of Operation may provide the technical basis for granting relief for specific valves.
It 9 therefore recommended that the request lg25 l70 23
for relief be denied and that the licensee be requested to meet the requirements of IWV-3410(g), at this time.
3.3 Safety Injection System (16103-26045 Sh. 6) 3.3.1 Code Relief:
Category A Valves 3.3.1.1 Relief Recuest: Valves SI-CV-862A, SI-CV-862B, SI-CV-862C, and SI-CV-8620 will not be exercised in accordance with Code Re-quirements.
Code Requirement:
Category A valves shall be exercised at least once every 3 months with the exceptions as shown in the following paragraph.
They shall be leak-tested at the same (or greater) frequency as scheduled refueling outages but not less than once ev-ery two years.
Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant oper-ation.
If only limited operation is practical during plant oper-ation the valve shall be part stroke exercised during plant oper-ation and full stroked during each cold shutdown; in case of frequ-ent cold shutdowns these valves need not be exercised more often than once every 3 months.
Valves that cannot be operated during normal plant operation shall be specifically identified by the Owner and shall be full stroke exercised during each cold shutdown; in case of frequent cold shutdowns these valves need not be ex-ercised more often than once every 3 months.
Licensee Basis for Relief Requested:
A full-flow test of these valves would require that a HPSI flow be established into the RCS.
A test of this nature would require that the reactor pressure ves-sel (RPV) head be removed, and would result in water chemistry problems and high radiation exposure to plant personnel caused by dislodging crud in the safety injection system piping.
The licensee proposes to part-stroke test these valves at reactor refueling outages and full-stroke test them every interval in con-junction with full flow tests of the safety injection system.
Evaluation:
The safety injection valves SI-CV-862A, 862B, 862C, and 8620 are in the HPSI system. The valves are closed during nonnal plant operation and are part of redundancy that isolates the operating RCS prr ssure from the lower design pressure HPSI system.
The check valves onac when the HPSI pumps are activated and RWST water is supplied to the RCS during the emergency condition.
These check valves are located in the HPSI pump discharge connectior.s to the reactor coolant system and their function is to prevent backflow from the reactor coolant system to the HPSI sys-tem.
The valves require a flow to demonstrate movement to fulfill their function.
During normal plant operation flow cannot be j h.)7
initiated because the combined LPSI and HPSI pumps can only develop a pressure of about 1700 psi and this pressure is not sufficient to overcome the reactor coolant system pressure of about 2250 psi.
During cold shutdown these pumps are disabled for low temperature overpressurization protection.
Therefore, the only time that these valves can be exercised is at refueling outages when a full flow testing of the HPSI system may be conducted with the reactor vessel head removed.
Such a test could, however, result in water chemis-try problems and high radiation exposure to plant personnel.
The licensee proposes to part stroke the valves at reactor refueling outages and full stroke them every interval in con-junction with full flow tests of the safety injection system.
Full flow tests as proposed have not been conducted to date during the operational life of the plant.
The experience gained from the tests planned for the 1980 outage should be used as the licensee's justification of proposing full flow exercising tests once each interval.
Based on the above evaluation, it is recommended that the licensee be granted relief frm full stroking the valves at quarterly inter-vals, and instead part stroke exercise the valves at refueling out-ages and full stroke exercise in conjunction with full flow testing of the safety injection system.
The granting of relief does not constitute a recommendation to grant relief for full stroke ex-ercising once per interval for the remainder of the plant life.
Instead, it is recommended that the licensee be requested to re-evaluate his request basd on the results of the 1980 tests, and re-submit the once per interval relief request (if required) in a fu-ture submittal.
Any justification presented, should then be based on the experience gained from the 1980 tests.
3.3.2 Code Relief: Category C Check Valves 3.3.2.1 Relief Request:
Val ves SI-CV-103, SI-CV-10/A, Si-CV-107B,
SI-CV-872A and SI-CV-872B will be stroked at refueling outages in lieu of Code Requirements.
Code Requirement:
Check valves shall be exercised at least once every 3 months, with the exceptions as shown in the following para-graph.
Check valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant operation.
If only limited operation is practical during plant operation the check valve shall be part stroke exercised during plant operation and full stroked during each cold shutdown.
In case of frequent cold shutdowns these check valves need not be ex-ercised more often than once every 3 months.
Check valves that cannot be operated during normal plant operation shall be specific-ally identified by the Owner and shall be full stroke exercised 25 1825 172
during each cold shutdown.
In case of frequent cold shutdowns these check valves need not be exercised more often than once every 3 months.
Licensee Basis for Relief Request:
For valves SI-CV-103, SI-CV-107A, and SI-CV-107B full or partial valve exercising requires that flow be established into the reactor vessel.
System pressure downstream of these valves does not allow flow during normal operations. During cold shutdowns, available volume in the reactor vessel is insufficient to accommodate flow required for exercising these valves.
In addition, the high flow generated by the LPSI pumps would stir up crud in the Safety injec-tion piping and deteriorate the chemistry of the RCS water.
The licensee will use gravity flow from the RWST through these lines to partially stroke the valves at reactor refueling when the RHR system can be taken out of service.
This was done at the 1979 outage. A full flow test is proposed during the 1980 outage while the reactor core is removed.
If this test is satisfactory, it will be done once per interval.
For valves CD-CV-872A and CD-CV-872B exercising requires that the RCS be depressurized and vented, to allow flow from the lower pres-sure RHR/LPSI systems to be established. The tests cannot be con-ducted at cold shutdowns because of the water chemistry and venting requirements discussed above.
These valves will be part-stroke tested at reactor refuelings and full-stroke tested during the safety injection system tests scheduled once each interval.
Evaluation: The LPSI pump discharge check valves SI-SV-107A and 107B, the check valves SI-SV-103 located in the LPSI pump discharge to the RHR system and core deluge check valves CD-CV-872A and B, are closed during nomal plant operation, and are required to open when the LPSI flow is initiated to the reactor during an emergency.
The function of these valves is to prevent a backflow from the RCS and RHR systems to the LPSI pumps.
Quarterly Testing:
The subject check valve designs are such, that they can only be exercised by disassembling or by flow.
The LPSI system configuration is such, that flow can only be initiated through the check valves by activating the LPSI pumps. During normal plant operation, the RCS pressure is approximately 2000 psig, and acts to close CD-CV-872A and 872B (assuming CD-MOV-871A and 871B are open).
The discharge pressure of the LPSI pumps is far lower than the RCS operating pressure, and cannot open check valves 872A and 872B against the RCS head.
SI-CV-103, 107A, and 107B are in series with 872A and 872B and are also prevented from exercising.
It should be noted, that the mini-flow recirculation 26
} }J -
lines off the LPSI pumps are upstream of the 107A and 107B which eliminates any part stroke exercise of these check valves when the LPSI pumps are run monthly.
Based on the above, it is agreed that full or part stroke exercising the subject valves by disassembly (where possible) or flowing is impractical on a 3 month basis.
Cold Shutdown Tests:
Perfont.ng a design flow test using the LPSI pumps is the only method available (without disassembly) to full stroke exercise the subject check valves. This requires venting the RCS, and removal of the pressurizer manway or several safety valves before a LPSI pump can be used for initiating design flow to the reactor (Low Temperature Overpressure Protection for Reactor Vessel requirements, established by the NRC).
Perfonning this flow test at each cold shutdown would, according to the licensee, re-quire several days extra work, and extension of what would usually be a " quickie" maintenance outage.
To partially stroke the check valves would require that the RCS be vented, and that the pressurizer level be established at a low level and visually monitored as flow is established from the LPSI pumps and introduced into the RCS (pressurizer).
In both the full stroke and part stroke cases cited, water pumped by the LPSI pumps would originate from the RWST (borated water).
Introduction of this water to the RCS would require additional waste liquid processing which is time consuming and delays startup.
Disassembly (where possible) of the check valves is impractical from a time standpoint, and would also increase the length of out-ages.
The licensee's basis for relief has adequately established that full or part stroke exercising the subject check valves by flow or disassembly at cold shutdown is highly impractical from a time and operations standpoint.
Testing at refueling:
The licensee proposes to part stroke the valves at refueling outages when the RHR system can be taken out of service.
Part stroking of the valves will be accanplished by using a gravity flow from the refueling water storage tank (RWST) through the LPSI system.
This was done at the 1979 outage.
Based on the 1979 outage gravity flow test it may be possible for the licensee to provide data on the degree of stroking (". of design flow as an example) obtained by the gravity flow test.
Such data would assume that the seat leakage across a stuck closed valve is not misinterpreted as stroking of the valve.
The licensee should also provide additional infonnation about the gravity flow test procedure including a description of where the parallel flow paths exist and how each path is checked individually to assure the proper exercising at each valve.
27 J
f826 174'
Summary:
It is agreed that full or part stroke exercising the sub-ject check valves quarterly is impractical, and that exercising at cold shutdowns is also impractical. However, based on the evalua-tion of the licensee's proposals for tests at refueling intervals, it is recommended that this item remains open until the licensee has provided the NRC with additional information about the proposed gravity flow test and the data has been evaluated.
The licensee also stated at the SER meeting that an attempt would be made to manually exercise the valves SI-CV-872A and 872B when the reactor vessel head is removed during refueling, as these valves are attached to the vessel head.
Was this attempted and what were the results?
3.3.2.2 Relief Request:
Valves SI-CV-856A and 95c8 will not be full stroke exercised in accordance with Section XI requirements.
Code Requirements:
See Code Requirement, item 3.3.2.1 Licensee Basis for Relief Request:
In order to full stroke these valves, ficw must be established into the RCS, because the pump re-circulation and test line is 3/4", insufficient to simulate design flow conditions.
Full flow testing of the HPSI system may only be conducted with the reactor vessel head removed.
Because of the water chemistry and radiation problems associated with pumping large amounts of water in through this system, the 1icensee proposes to test these valves as follows:
Alternate Testing:
These valves will be part stroke tested quarterly, and full stroke tested once each interval in conjunction with full flow tests of the HPSI system.
Evaluation:
The HPSI Pump Discharge check valves SI-CV-856A and 856B are closed during normal plant operation, and their function is to open when the HPSI pumps are activated and supply RWST water to tre RCS during the emergency condition.
The l' PSI pump system's configuration is such that full stroke exercising quarterly is considered to be impractical.
The 862A, B, C, D check valves that are downstream and in series with the sub-ject check valves, are prevented from opening by the RCS pressure (approximately 2250 psig) during power operations. The pressure developed by the HPSI pumps (approximately 1500 psig) is insuf-ficient to overcome this RCS pressure, thereby preventing flow through the HPSI system and the subject check valves.
Part stroke exercising is accmplished monthly during HPSI pump miniflow recirculation tests.
The basis given for the licensee's proposed full stroke exercise tests once per interval as part of the HPSI pump full flow tests is 28 1.825 175"
questionable at this time.
Full ficw tests as proposed have not been conducted to date during the operational life of the plant.
The experie.'2 to be gained by the tests planned for the 1980 out-age should be used as the basis for the licensee's justification of proposing full flow exercising tests once each interval.
The licensee's IST resubmittal of April 1979 for the 20 months starting July 1,1979, includes the period for the 1980 outage.
Therefore, at this time, it is recommended that the licensee be granted relief from full strcke exercising the subject check valves quarterly based on the evaluation written above.
However, the granting of this relief does not constitute a recommendation to grant relief as requested for full stroke exercising once per interval for the remainder of the plant's life.
Instead, it is re-conmended that the licensee be required to re-evaluate his request based on the results of the 1980 tests, and resubmit the "once per interval" relief request (if required) in a future submittal. Any justification presented, should then be based on the experience gained from the 1980 tests.
3.4 Residual Heat Removal System (16103-26045 Sh. 5, 6) 3.4.1 Code Relief: Category C Check Valves 3.4.1.1 Relief Request: Check Valves RH-CV-783 and RH-CV-808A will not be exercised in accordance with Code Requirements.
Code Requirement:
See Code Requirement, item 3.3.2.1 Licensee Basis for Relief Request:
These valves are located in piping which is normally drained and do not function unless water is present in the containment pump, as would be the case during a LOCA.
It is not practicable to flood the containment floor and pump to hydraulically exercise these valves.
Alternate Testing:
Each of these valves will be disassembled and inspected to detennine interior condition and operability once each interval. RH-CV-783 was disassembled and inspected in February, 1979 and found to be in satisfactory condition.
Evaluation:
The Containment Sump Suction check valves RH-CV-783 and RH-CV-808A are in the recirculation lines to the RHR pumps.
The valves are required to open when the sump recirculation mode is required following the LCCA.
The valves are not designed to be exercised by external actuators, and can only be exercised by flow or by disassembling.
Flowing the valves is impractical at any time as the systems configuration is such that the containment sump would have to be filled with water, and the contaminated water flowed back through the RHR pumps to the reactor.
Therefore, disassembly and exercise appear to be the practical alternative.
18 8 i76 29
~
Based on the licensee's statement that these valves were disassembled, inspected and found in satisfactory condition during the February 1979 refueling outage, indicates an inspection frequ-ency greater than once per quarter may be justified.
However, the licensee provides no technical justification that supports a frequ-ency of testing of once per interval.
Until such ^;:hnical justification is received and reviewed, it is recanmended that this relief request be denied.
3.5 Chemical and Volume Control (16103-26045 Sh.10) 3.5.1 Code Relief:
Category B Valves
- 3.5.1.1 Relief Request:
Valves CH-FCV-110, and CH-FCV-110A will be full stroke exercised at reactor refuelings during scheduled safety inspection system testing.
Code Requirement: Category B valves shall be exercised at least once every 3 months with the exceptions as shown in the following paragraph.
Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant oper-ation.
If only limited operation is practical during plant oper-ation the valve -hall be part stroke exercised during plant oper-ation and fuli.troked during each cold shut; in case of frequent cold shutdowns these valves need not be exercised more often than once every 3 months.
Valves that cannot be operated during normal plant operation shall be specifically identified by the Owner and shall be full stroke exercised during each cold shutdown; in case of frequent cold shutdowns these vaives need not be exercised more often than once every 3 months.
Licensee Basis for Relief Request: These valves are arranged in parallel flow paths such that either valve can be utilized to con-trol charging flow to the RCS.
The valves are normally open and modulate to control flow.
They remain open in the accident mode but assume a pre-set SIS position.
Exercising these valves full stroke during nonnal operations would cause flow and pressure transients in the charging system. Cold shutdown T.esting is not possible as stroking these valves to the accident position requires an integrated SIS test, performed only at refueling outages when the plant is lined up to conduct such testing.
Evaluation: These control valves are located in the charging pump discharge connection to the reactor coolant system and their func-tion is to control the charging flow to the RCS.
The valves are normally open and remain open in the accident mode but assume a pre-set SIS position.
The valves cannot be part-or full stroked exercised during operation as this would cause flow and pressure transients in the charging system and a possible reactor shutdown.
- Requires NRC Review 30 v
1825 177
The licensee states that testing the valves during cold shutdown would require an integrated SIS test that is only performed at re-fueling outages.
It is understood that the frequency of the integrated SIS tests performed at refueling outages are once per interval.
The licensee has not provided sufficient technical justification that supports a relief request to an exercise frequency of once per interval.
Un-til such time as this justification has been received and reviewed it is recommended that this request be denied.
3.6 Service Water System (16103-2604S Sh. 9) 3.6.1 Code Relief: Category B Valves
- 3.6.1.1 Relief Request:
Valves SW-MOV-5 and SW-MOV-6 will not be exercised in accordance with Section XI requirements.
Code Requirements:
See Code Requirements, item 3.5.1.1 Licensee Basis:
These valves open to supply service water to the residual heat exchangers in the event of a failure in the component cooling system.
There is no automatic operation.
Stroking these valves requires that the service water system be cross-connected with the component cooling water system to provide emergency flow to the Residual Heat Removal Heat Exchangers.
The service water system utilizes water from the Conne:ticut River, and the component cooling water system is a closed system containing potentially contaminated water. Cross-connecting could result in releasing non-confonning water to the river, and require a major cleanup of system components, which would require that they be taken out of service during the restoration process.
These valves were satisfactorily cycled during the February,1979 refueling out-age when special arrangements could be made to minimize the cleanup.
They had not been stroked in the past ten years, so the tests concluded that the valves were still able to fulfill their function.
The licensee proposes to exercise these valves each five years.
Evaluation:
The RHX inlet valves SW-MOV-5 and -6 are closed during normal plant operation when the component cooling system provides cooling water to the RHX's.
In the emergency mode, the component cooling system drops out, SW-MOV-5 and -6 open, and RHX cooling is provided by the service water system.
It is agreed that the requirement to clean the RHX's and associated plumbing after introduction of service water, makes it impractical to exercise the valves every 3 months as required by the code, and
- Requires NRC Review 31 1826 178
relief from this requirement is justified.
However, a test frequ-ency of five years is too infrequent to meet the intent of the Code.
The Licensee failed to clarify the condition of the valves, other than to say that they were in " satisfactory condition".
The degree of operability was not mentioned.
Therefore, until such time that the licensee submits an alternate test frequency with supporting rationale, it is recommended that the request for code relief be denied at this tire.
3.7 Miscellaneous Systems 3.7.1 Code Relief:
Category A Valves
- 3. 7.1.1 Relief Request:
The licensee has requested relief from exercising the follcwing valves per code requirements for Category A valves.
The valves are CIV's.
Valve Category Valve Service PW-CV-139 AC Primary Water to PRT PW-CV-140 AC Primary Water to PRT HC-V-211 AE Space Heater Containment Return PU-V-24?
AE Cavity Purification Line PU-V-242A AE Cavity Purification Line HS-Ct-295 AC Containment Space Heating Supply HS-CV-295A AC Containment Space Heating Supply
%BV-1-1B AE Containnent Purge Air Exhaust
%HCV-1101 AE Containment Purge Air Exhaust Bypass
%8V-1-1A AE Containment Purge Air Supply
%P50 AE Fuel Transfer Tube SA-V-411A AE Air Monitor Purge SA-V-413 AE Service Air to Containment
- BD-V-506 AE Steam Generator No.1 Blowdown
- BD-V-515 AE Steam Generator No. 2 3 lowdown
- BD-V-522 AE Steam Generator No. 3 Blowdown
- BD-V-529 AE Steam Generator No. 4 Blowdown
- CC-V-884 AE Neutron Shield Tank Fill Line
- VS-CV-1104 AC Air Monitor Sample to Containment
- VH-V-507 AE Primary Vent Header
- VH-V-507B AE Primary Vent Header
- SS-V-999 AE Neutron Shield Tank Sample
- These valves vere added in the resubmittal
%BV-1-10, HCV-1101, BV-1-1A, P50:
These valves were categorized as "A" in the submittal, and were revised to Category AE as a result of the SER meeting.
- Requires.NRC Review 3
1825 l79
- SS-V-999 AE Neutron Shield Tank Sample
- SS-V-999A AE Neutron Shield Tank Sample
- FW-CV-192 AC Aux. Feed Water Supply to S.G. No. 4
- SS-V-999A AE Neutron Shield Tank Sample
- FW-CV-192 AC Aux. Feed Water Supply to S.G. No. 4
- FW-CV-194 AC Aux. Feed Water Supply to S.G. No. 3
- FW-CV-196 AC Aux. Feed Water Supply to S.G. No. ?
- FW-CV-198 AC Aux. Feed Water Supply to S.G. No.1
PRT Sample Code Requirement:
See Code Requirement, item 3.3.1.1 Licensee's Basis for Relief Request:
The valves are closed during normal plant operation, and their safety related position is to re-main closed.
Evaluation:
The NRC staff considers these valves listed above as passive, i.e., a closed valve. whose function is to remain closed during the emergency condition. The staff has determined that the exercising requirement of Code Section XI provides no meaningful information for these passive valves, and relieves the licensee from the 3 month stroke and stroke timing requirements.
- These valves were added in the resubmittal 82S l80 33
4.0 COLD SHUTDOWN T; STING 0F VALVES 4.1 General 4.1.1 Valves shall be exercised to the position required to fulfill their function unless such operation is not practical during plant oper-ation.
If only limited operation is practical during plant oper-ation, the valve shall be part stroke exercised during plant oper-ation and full stroke exercised during cold shutdowns.
Valves that cannot be exercised during plant operation shall be full stroke ex-ercised during cold shutdowns.
Full stroke exercising during cold shutdowns for valves not full stroke exercised during plant oper-ation shall be on a frequency detennined by the intervals between shutdowns as follows: for intervals of 3 months or longer, exercise during each shutdown; for intervals of less than 3 months, full stroke exercise is not required unless 3 months has passed since last shutdown exercise.
The intent of this section is to satisfy the requirements of the NRC letter dated January 13, 1978, i.e., "NRC Staff Guidance For Preparing Pump and Valve Testing Program Descriptions and As-sociated Relief Requests Pursuant to 10 CFR 50.55 a(g)," specific-ally section 5, page 7.
4.2 Safety Injection System (16103-26045 Sh. 6) 4.2.1 Category B Valves 4.2.1.1 Valves: CD-MOV-871A, CD-MOV-8/1B Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee's Basis:
Exercising the subject MOV's open quarterly during normal plant operation would violate an NRC Guideline (November 1976).
Evaluation:
The Core Deluge valves CD-MOV-8/1A and 8718 are in the LPSI system. The valves are closed during nonnal plant operation and form part of a redundancy with check valves CD-CV-872A and 872B that isolates the lower design pressure LPSI from the RCS operating pressure (2000 psig).
The valves are opened during an emergency condition when LPSI is required.
The licensee submittal had proposed to exercise the valves every 3 months to code.
The staff poised out the November 1976 Guidelines concerning the exercising power operated valves in series with check valves that would interface with the RCS a operating pres-sure.
The licensee stated that there were no provisions in this system that would enable him to check the closed integrity of the 872A and 872B check valves prior to exercising M0V's 871A and 871B respectively.
Based on the staff guideline, the licensee is 9 {8\\
34
proposing to full stroke the valves at cold shutdowns and re-fuelings.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising every 3 months and that full stroke exercising at cold shutdowns is the practical alternative that satisfies the intent of the code.
4.3 Residual Heat Removal System (16103-26045 Sh. 5, 6) 4.3.1 Category A Valves 4.3.1.1 Valves:
RH-MOV-780, RH-MOV-781, RH-MOV-803 and RH-MOV-804 Code Requirement:
See Code Requirement, item 3.3.1.1 Licensee Basis:
These valves are interlocked with the Reactor Coolant System such that operation is not possible unless the RCS pressure is less than 375 psig.
Evaluation: The Residual Heat Removal Valves RH-MOV-780 (Inboard Stop-Loop #1), RH-MOV-/81 (Outboard Stop-Loop #1), RH-MOV-804 (In-board Stop-Loop #2), and RH-MOV-803 (Outboard Stop-Loop #2) isolate the lower design pressure RHR system from the operatior al pressure of the RCS (approximately 2000 psig).
The valves are opened when the RHR system is used to remove decay heat from the reactor during normal shutdown conditions.
The valves are pressure interlocked with the RCS, and cannot be opened when the RCS is above 375 psig.
The valves are full stroke ex-ercised at cold shutdown conditions when the RHR system is used.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part stroke or full stroke ex-ercising the valves every 3 months and that cold shutdowns below 375 psig is the only time the valves can be exercised.
It is therefore reccmmended that the licensee be allowed to full stroke exercise the valves at cold shutdown.
4.3.2 Category B Valves 4.3.2.1 Valves:
RH-MOV-23 and RH-MOV-34 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
The containment spray system is set up such that opening either RH-MOV-23 or 34 will initiate flow. By entering the containment and closing manual valve RHR-V-23A, the valves could be "no-flow" stroked but Technical Specifications 3.11 prevent this, as it would be disabling the containment spray system.
35 1825 182
Evaluation:
The containment spray system is set up such that open-ing Containment Spray valves RH-MOV-23 and RH-MOV-34 will initiate containment spray.
In order to isolate these valves, RHR-V-23A would have to be closed.
Closing 23A (manual valve inside con-tainment) would put the valve in a non-conservative position, i.e.,
disabling the Containment Spray system during normal plant oper-ation. This condition would violate Tech. Spec. requirements and the NRC's November 1976 guidelines.
The licensee has agreed to full stroke exercise the subject MOV's at cold shutdowns.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part stroke or full stroke ex-ercising the valves every 3 months and that exercising the valves at cold shutdown is the practical alternative that satisfies the intent of the code.
4.3.2.2 Valves: RH-MOV-33A and RH-MOV-33B Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis: RH-M0V-33A and RH-MOV-33B provide a flow path from the RHR system to the charging pump suction header.
Stroking these valves varies the suction header pressure in the charging system and could cause charging pump flow oscillations.
Evaluation:
Valves RH-MOV-33A and 33B are normally closed valves leading frcm the RHR pumps to the suction side of the charging pumps.
The valves are required to open to feed from the RHR to the charging pumps when this mode of recirculation is required during the emergency conditions.
The licensee has indicated that the flow transients caused in the charging system by cycling the valves could cause Reactor Coolant Pump seal damage.
Also, opening these valves opens a flow path from RWST to the charging pump suction which would affect baron concentration in the RCS and reactivity.
Cased on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative that satisfies the intent of the code.
It is recommended that the licensee be allowed to full stroke ex-ercise the valves at cold shutdowns.
4.4 Chemical and Volume Control System (16103-26045 Sh. 10) 4.4.1 Category A Valves 36 182'5 i83
4.4.1.1 Valves:
LD-A0V-202, LD-A0V-203, and LD-A0V-204 Code Requirement:
See Code Requirement, item 3.3.1.1 Licensee Basis:
Closing these valves would shut down the letdown line.
Evaluation:
The Letdown Orife Flow Control valves LD-A0V-202, LD-A0V-203, and LD-A0V-204 are partially stroked at frequencies higher than the code required 3 months, during normal plant oper-ation.
Full stroking the valves closed would shut off the letdown flow and could result in a reactor trip.
The valves will be full stroke exercised at cold shutdowns.
The valves are CIV's.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of full stroke exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
4.4.1.2 Valve:
Ch-TV-334 Code Requirement:
See Code Requirement, item 3.3.1.1 Licensee's Basis:
Closing this valve isolates seal water supply to the Reactor Coolant Pumps.
Evaluation:
The Seal Water Return Line Trip Valve CV-TV-334 is in the seal water supply line from the RC pumps to the charging pumps and is a CIV. The valve is open during nomal plant operation and its safety related function is to close to form part of con-tainment.
The valve can only be full stroke exercised.
Closing this valve during nomal plant operation stops seal water to the RC pumps and could result in pump damage.
The licensee has agreed to test the valve at certain cold shutdown conditions where the RC pumps are inactive, and operation of the seal water system is not required.
Based on the above, it is con:luded that the licensee has demonstrated the impracticality of exercising the valves every 3 months and that full stroke exercising at cold shutdown conditions is the practical alternative that satisifies the intent of the code.
4.4.2 Category B Valves 4.4.2.1 Valve:
LD-MOV-200 Code Requirement:
See Code Requirement, item 3.5.1.1 37 1825 184'
Licensee Basis: Closing this normally open valve to check operability would disrupt letdown flow.
This would cause flow / pressure transients in the charging and letdown systems.
Evaluat'on:
The Letdown Isolation valve LD-MOV-200 is in the letdown line and is open during normal plant operation.
The valve cannot be part stroked, and goes full closed when it's required to operate.
Shutting off the letdown line can have an affect on pres-surizer level which can result in a reactor trip.
The valve will be exercised at cold shutdown.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative that satisfies the intent of the code.
4.4.2.2 Valve:
CH-MOV-257 Code Requirement:
See Code Requirement, item 3.b.1.1 Licensee's Basis:
Closing this normally open valve would cause the charging pumps to cavitate.
Part stroke testing is not possible (no jog control on valve operator).
Evaluation:
The Volume Control Tank Outlet valve is in the line from the VCT to the suction side of the charging pumps.
The valve is open during nonnal plant operation and is in the path of the makeup and RC pump seal water flow via the charging pumps.
The valve's safety related function is to close during the emergency condition. Closing the valve during plant operation causes cavita-tion of the charging pumps, and shuts off makeup and seal water flow, the results of which could be a reactor trip and RC pump seal damage.
The valve will be full stroke exercised a c,.c s. utdown.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative that satisifies the intent of the code.
4.4.2.3 Valves:
BA-MOV-32 and BA-MOV-373 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
Cycling these valves could potentially cause a highly borated solution to reach the RCS, via the charging system, which is in continuous service.
8 0826 185'
~
Evaluation: BA-MOV-32 and BA-MOV-373 are in the flow path from the RSWT to the suction side of the charging pumps.
The valves are closed during nomal plant operations. Opening them would allow RWST water to flow to the RCS via the charging pumps and result in a boron concentration increase in the reactor coolant water with resultant reactivity changes.
Both valves will be full stroke ex-ercised at cold shutdowns.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising the valves every 3 months and that full stroke exercising at cold shutdowns is the practical alternative.
4.4.2.4 Valve: B A-MOV-366 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
Operation of this valve while the plant is at power could potentially cause a concentrated boric acid solution to reach the reactor, via the charging system.
Evaluation:
The Boric Acid to Charging Pump Valve BA-MOV-366 is closed during nomal plant operation and it's safety related func-tion is to open to provide Boric Acid from the Boric Acid Tank (BAT) to the reactor via the charging pumps.
Opening the valve during normal plant operations would supply the boric acid to the RCS resulting in a boron concentration increase and reactivity de-crease.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
4.4.3 Category C Valves 4.4.3.1 Valves: BA-CV-320 Code Requirement:
See Code Requirement, item 3.3.2.1 Licensee Basis:
Exercising this valve to the open position must be done by passing flow through it, and this couid potentially cause a concentrated boric acid solution to reach the reactor, via the charging system.
Evaluation:
The Boric Acid Strainer Discharge check valve SA-CV-320 is in the line from the Boric Acid Tank (BAT) to the suc-tion side of the charging pumps. The valve is required to open when the Boric Acid is required to be supplied to the reactor via the charging pumps during the emergency condition..
1826"f8'6' 39
The valve is not designed to be exercised by an external actuator, and can only be exercised by flowing the boric acid from the BAT.
During nonnal plant operation, this high concentration boron solu-tion would be supplied directly to the charging pump and increase the boron concentration of the reactor coolant thereby affecting reactivity.
The check valve will be exercised at cold shutdown.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
4.4.3.2 Valve:
BA-CV-387 Code Requirement: See Code Requirement, item 3.3.2.1 Licensee Basis:
Exercising this valve to the open position must be done by passing flow through it, and this could potentially cause a concentrated boric acid solution to reach the reactor, via the charging systen.
Evaluation:
The Boric Acid to Charging Pump check valve BA-CV-387 1s closed during normal plant operation and its safety related function is to open when BA-MOV-366 is opened and the concentrated boric acid solution is supplied from the BAT to the charging pumps.
Opening BA-CV-387 during normal plant operation would require open-ing BA-MOV-366 and flowing the concentrated Boric Acid solution to the reactor coolant via the charging pumps. This would increase the reactor coolant's boron concentration, ano result in a re-activity change.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising the valve every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
4.4.3.3 Val ve:
BA-CV-372A Code Requirement:
See Code Requirement, item 3.3.2.1 Licensee Basis: Operation of this valve while the plant is at power could cause boric acid solution to reach the reactor via the charging system.
Evaluation:
The RWST to Charging Pump check valve BH-CV-372A is closed during normal plant operation, and its safety related func-tion is to open when BA-MOV-373 is opened and water is supplied from the RWST to the charging pumps. Opening the check valve 40 1825 187
during nomal plant operation would require opening BA-MOV-373 and flowing the relatively higher borated water from the RWSi to the reactor coolant via the charging pumps.
This would increase the reactor coolants baron concentraticn, and result in a reactivity change.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of part or full stroke exercising the valves every 3 months, and that full stroke exercising at cold shutdown is the practical alternative.
4.5 Main Steam System (16103-26045 Sh.1) 4.5.1 Category A Valves 4.b.1.1 Valves: BD-TV-1312-1, BD-TV-1312-2, BD-TV-1312-3, and BD-TV-1312-3 Code Requirements:
See Code Requirements, item 3.3.1.1 Licensee Basis:
The valves are tested as containment isolation valves only.
Evaluation:
The Steam Generator Blowdown valves BD-TV-1312-1, -2,
-3, and -4 are open during normal plant operation, and their safety related function is to close and fom part of containment in an em-ergency condition.
The valves cannot be part stroke exercised, and can only be full stroke exercised together (i.e., all and simultaneously).
Full stroke exercising during nomi plant oper-ation stops the steam generator blowdown.
The licensee has indicated that the code frequency could cause chemistry problems with the steam generator water which could re< alt in tubing de-gradations.
It is believed that the licensee has demonstrated the impracticality of exercising every 3 months and that full stroke exercising at cold shutdowns is the practical alternative that satisfies the intent of the code.
4.5.2 Category B Valves 4.5.2.1 Valves: MS-TV-1211-1, MS-TV-1211-2, MS-TV-1211-3, and MS-TV-1211-4.
Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
Full stroke exercising each of the subject valves closed during nomal plant operation shuts off its respective steam line to the turbine.
Evaluation:
The Main Steam Outlet val ves MS-TV-1211-1, -2,
-3, and
-4 are open during nomal plant operation, and their safety 41 18'2N188
related function is to close.
The valves are part stroked at a frequency that satisfies the code, and are full stroked at cold shutdowns.
Full stroking any valve quarterly, shuts off the steam in that line, and could result in a reactor trip.
Based on this, it is concluded that the licensee has demonstrated the impracticality of full stroke exercising every 3 months, and that full stroking at cold shutdowns is the practical alternative.
4.5.2.2 Valves: MS-NRV-11, MS-NRV-21, MS-NRV-31, and MS-NRV-41 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
Full stroke exercising the subject valves during normal plant operation would shut off a steam supply line.
Evaluation:
The Steam Generator Non-return valves MS-NRV-11, -21,
-31, and -41 are open during normal plant oparation and their safety related function is to close.
The valves are part stroke exercised quarterly and full stroked at cold shutdowns.
Full stroking any of these valves quarterly shuts off the steam in that supply line, and could result in a reactor trip.
Based on this, it is concluded that the licensee has demonstrated the impracticality of full stroke exercising every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
4.6 Feedwater System (16103-26045 Sh. 2) 4.6.1 Category B Valves 4.6.1.1 Valves:
FW-MOV-11, FW-MOV-12, FW-MOV-13, a nd FW-MOV-14 Code Requirement:
See Code Requi rement, i tem 3.5.1.1 Licensee Basis:
These valves are normally open passive valves whose positions are the same during plant operations and emergency conditions.
Failure of any valve in a non-conservative position would cause loss of system function.
Evaluation:
The Steam Generator Feedwater Isolation valves FW-MOV-11,-12, -13, and -14 are nonnally open, full stroke only type valves.
The valves are required to stay open during emergency conditions when emergency feedwater is supplied to the steam generators by the auxiliary steam generated feed pump.
Failure of these valves in a non-conservative position has more serious consequences than not stroking these valves quarterly.
4 i825 I89
Based on this, it is concluded that the licensee has demonstrated the impracticality of full strcke exercising every 3 months, and that full stroke exercising at cold shutdcwns is the practical alternative.
4.6.1.2 Valves:
FW-FCV-1301-1, FW-FCV-1301-2, FW-FCV-1301-3, and FW-FCV-1301-4 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
Failure of a valve in non-conservative position would cause loss of system function.
Evaluation: The Feedwater Regulator Valves FW-FCV-1301-1, -2, -3, and -4 are control valves that are open and in constant operation (part stroking) when the plant is in normal operation.
Exercising a valve closed, shuts off the feedwater to its respective steam generator and could cause a reactor trip.
The licensee has demonstrated the impracticality of full stroke exercising every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
4.6.1.3 Valves:
FW-H ICV-1301-1, FW-H ICV-1301-2, FW-H ICV-1301-3, a nd FW-H IC V-1301-4 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
Cycling these normally closed valves during operation causes severe water hammer problems.
This has been verified by operating experience.
Evaluation: The Feedwater Bypass Valves FW-HICV-1301-1,1301-2, 1301-3, and 1301-4 are valves in the emergency feedwater circuit and provide flow control of emergency feedwater to the steam generators. The valves are normally open and flow feedwater sup-plied by the feedwater pumps.
The licensee has stated that, from experience, closing the valves causes water hammer.
In that water hammer is undesirable in a fluid system and can have deleterious effects, it is agreed that full stroke exercising quarterly is impractical, and that full stroke exercising at cold shutdowns is the practical alternative.
4.6.2 Category C Check Valves 4.6.2.1 Valves:
FW-CV-153B, FW-CV-156-1, FW-CV-156-2, FW-CV-156-3, FW-CV-156-4, and FW-CV--184 Code Requirement: ' See Code Requirement, i tem 3.3.2.1 43 1-8 5
190
Licensee Basis: Full or partial stroke testing of these valves requires that an auxiliary feedpump be started and flow be es-tablished to the Steam Generators.
This test is undesirable while the reactor is at power because of the stem generator thermal shock potential.
The pumps take suction from the Demineralized Water Storage Tank (cold water).
Evaluation:
Check val ves FW-CV-1538, -156-1,156-2,156-3,156-4,
~
and -184 are in the emergency feedwater system from the auxiliary steam generated feed pumps.
Part or full stroke exercising the valves would require flowing water from the demineralized water storage tank to the steam generators via the emergency feedwater pump.
The demineralized water is at ambient temperature, and would result in thermal shock to the steam generators.
The licensee has demonstrated the impracticality of part or full stroke exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
4.7 Service Water System (16103-26045 Sh. 9) 4.7.1 Category B Valves 4.7.1.1 Valves:
SW-MOV-1, SW-MOV-2 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
These valves control service water cooling to several essential plant loads.
Failure of valves in non-open posi-tion could cause overheating of these loads resulting in loss of operation.
Evaluation:
The east and west header isolation valves SW-MOV-1 and SW-MOV-2 respectively are open during nonnal plant operation and are required to close during the emergency condition to assure that sufficient service water pressure is available to supply required cooling water to essential service equipment.
The valves cannot be part stroked, and full stroking them during normal plant operation shuts down cooling water to the turbine oil cooler, GNg Cooler, seal oil system coolers and other cooling systems which are required for plant operation.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative that satisfies the intent of the code.
b 44
4.7.1.2 Valves: SW-MOV-3, SW-MOV-4 Code Requirement:
See Code Requirement, item 3.5.1.1 Licensee Basis:
These valves control service water cooling to the component cooling heat exchangers.
Failure of valve in non-open position could cause overheating resulting in loss of generation.
Evaluation:
The Component Cooling (CC) System Heat Exchanger Discharge valves SW-MOV-3 and -4 are open during normal plant oper-ation. The valves cannot be part stroked, and closing the valves would stop service water cooling flow through the CC heat ex-changers and cause an increase in temperature of letdown water (non-regenerative heat exchanger).
These heat exchanges are re-quired to be operative during plant operations.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative that satisfies the intent of the code.
4.8 Miscellaneous Systems 4.8.1 Category A Valves (CIV's) 4.8.1.1 Valves: CC-TV-1831, VX-TV-1848, 50V-12-1, FCV-611, DH-TV-554, WD-HICV-1840, WD-TV-1846, DH-TV-1843, DH-TV-1844, LM-TV-1811A, LM-TV-1811B, LM-TV-1812, CC-TV-1411, CC-FCV-608, WG-A0V-558, WG-TV-1845, SS-TV-950, SS-TV-955, SS-TV-960, SS-TV-965, DH-TV-1842A, DH-TV-1842B, CH-CV-305A, CH-CV-305B, CH-CV-305C, CH-CV-3050, DH-TV-1844 Code Requirements:
See Code Requirements, item 3.3.1.1 Licensee Basis:
Operability testing of these CIV valves during normal operation could cause a loss of containment integrity and/or systen function if a valve failed in a non-conservative position.
The valves will be exercised at cold shutdowns.
Evaluation:
These valves are all " active" containment isolation valves that cannot be tested during plant operation without causing a loss of containment integrity and/or system function if a valve failed in a non-conservation position. The valves will be full stroke exercised at cold shutdowns.
Based on the above, it is concluded that the licensee has demonstrated the impracticality of exercising the valves every 3 months, and that full stroke exercising at cold shutdowns is the practical alternative.
i 826 I912 45 s
5.0 PROGRAM BREAKDOWN 5.1 Reactor Coolant System (16103-26045 Sheet 4)
S.1.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement.
Valve Category Valve Category PR-MOV-567 B
PR-SV-586 C
PR-MOV-569 B
PR-SV-587 C
PR-SV-584 C
PR-SV-588 C
PR-SV-585 C
5.1.2 The following are valves that were listed in the IST submittal and were agreed upon to be non-safety related (safety related as de-fined by "NRC Staff Guidance For Preparing Pump / Valve Testing..."
dated January 13,1978), and were deleted from the IST program.
Valve Valve RC-MOV-501 PR-A0V-568 RC-M0V-512 PR-A0V-570 RC-MOV-513 PR-A0V-573 RC-MOV-524 PR-A0V-574 RC-MOV-526 PR-M0V-596 RC-MOV-537 PR-MOV-597 RC-MOV-538 PR-MOV-598 RC-MOV-546 PR-MOV-599 5.2 Safety Injection System 5.2.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement.
Valve Category Valve Category
%SI-MOV-861A B
- SI-MOV-863A A
%Si-MOV-861B B
- SI-MOV-863B A
%SI-MOV-861C B
- SI-MOV-863C A
- SI-MOV-861D B
- SI-MOV-863D A
- Valves recategorized
%SI-M0V-861A, 861B, 861C, 8610:
these are motor operated valves in the HPSI system. The valves are closed during nonnal plant operation and form part of a redundancy with check valves SI-CV-862A, 862B, 862C, 862D that isolates the HPSI system from the RCS operating pressure.
The valves are opened during an emergency condition when HPSI is required.
The licensee is presently exercising these valves monthly per Tech. Spec.,
without first determining the closed integrity of the 862 series check valves. Discussions led to the licensee agreeing to stroke the 861 MOV's quarterly per code preceeded by an integrity check of the 867 check valves.
In this case, the' licensee would be in compliance with the NRC Staff Guidance of November 1976.
Valve Category Valve Category SI-MOV-24 E
SI-V-855B E
RH-HCV-746 E
SI-V-104A E
RH-FCV-602 E
SI-RV-870 C
CD-V-873 E
SI-V-104B E
SI-V-854A E
SI-V-10bA E
SI-V-854B E
SI-V-1058 E
SI-V-855A E
SI-V-102 E
5.2.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related and therefore will be added to the resubmittal as shown.
Valve Category SI-MOV-24 E
RH-HCV-796 E (not listed in resubmittal)
RH-FCV-602 E (not listed in resubmittal) 5.2.3 The following are valves that were listed in the IST submittal, and were agreed upon to be non-safety related (safety related as de-fined by "NRC Staff Guidance For Preparing Pump / Valve Testing...,"
dated January 13,1978), and were deleted from the IST Program.
Valve FP-MOV-31 5.2.4 The following are valves in the IST submittal that were recategorized in the resubmittal as a result of the SER meeting Val ve From Category To Category SI-CV-962A C
AC SI-CV-862B C
AC SI-CV-862C C
AC SI-CV-862D C
AC SI-MOV-863A A
AE SI-MOV-863B A
AE SI-M0V-863C A
AE SI-MOV-863D A
AE CD-MOV-871A B
A CD-MOV-871B B
A 5.2.5 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested.
1825 194.-
47
Valve Category Valve Category SI-CV-103 C
- S I-C V-862C C
SI-CV-107A C
- SI-CV-862D C
SI-CV-107B C
%CD-CV-872A C
SI-CV-856A C
%CD-CV-872B C
- S I-C V-862A C
SI-CV-856B C
- SI-CV-862B C
5.2.6 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirenents of Section XI. Additional information is required by the NRC to verify the impracticality of full stroke exercising every 3 months.
Valve C ategory Valve Category SI-C V-862A C
SI-C V-1078 C
SI-CV-862B C
SI-CV-872A C
SI-C V-862C C
SI-C V-872B C
SI-CV-862D C
S I-CV-85 6A C
SI-CV-103 C
SI-C V-856B C
S I-CV-107A C
5.2.7.
The following valves requested relief frcm full stroke exercising every 3 months to full stroke exercise at cold shutdown at the SER neeting. The IST resubmittal, however, shows that the valves will te full stroke exercised quarterly.
Valve Category
- CD-MOV-871A B
- CD-MOV-871B B
5.3 Residual Heat Removal System 5.3.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirement.
Valve Category Valve Category RH-V-785A E
RH-V-791A E
RH-V-785B E
RH-V-791B E
RH-V-789A E
RH-V-794A E
RH-V-789B E
RH-V-794B E
- Valve recategorized
% Note:
These valves were identified SI-CV-872A and SI-CV-8728 in BN1-NUREG-26171 dated February 1979.
1825 i95'-
48
Val ve Category Valve Category RH-MOV-21 B
RH-RV-715 C
RH-MOV-22 B
RH-CV-788A C
RH-MOV-25 B
RH-CV-7888 C
RH-MOV-26 B
RH-CV-808A B
RH-MOV-27 8
i<H-M0R-874 E
RH-M0V-28 C
RH-V-23A E
RH-MOV-29 B
FH-A0V-796 E
RH-A0V-602 E
5.3.2 The following are valves that were not listed in the IST submit: 11 and were agreed upon to be considered safety related and therefore will be added to the resubmittal as shown.
Valve Category RH-V-23A E
FH-A0V-796 E
RH-A0V-602 E
5.3.3 The following are valves in the IST submittal that will be recategorized in the resubmittal as a result of the SER meeting.
Valve From Category To Category RH-MOV-780 B
A RH-MOV-781 B
A RH-M0V-803 8
A RH-MOV-804 B
A 5.3.4 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested.
Val ve Category Valve Categor"t RH-MOV-23 B
- RH-MOV-781 B
RH-MOV-34 B
- RH-MOV-803 8
RH-CV-783 C
- R H-M0V-804 8
RH-CV-808A C
RH-MOV-33A B
- R H-MOV-780 B
RH-MOV-33B B
5.4 Chemical and Volume Control System 5.4.1 The following are valves in the IST program which the licensee intends to test to the applicable code requirements.
- Valves recategorized hh,
49
Valve Category Valve Category LD-RV-205 C
CH-V-270 E
CH-V-264 E
CH-V-273 E
BA-M0V-349 8
BA-CV-361 C
BA-CV-370 C
BA-V-399 E
BA-MOV-386 B
BA-V-352 E
BA-V-359 E
BA-V-362 E
CH-V-286 E
BA-V-364 E
BA-V-360 E
BA-V-371 E
CH-V-261 E
DH-TV-1841 E
5.4.2 The following are valves that were not listed in the IST submittal and were agreed upon to be considered safety related, and there-fore, will be added to the resubmittal as shown.
Valve Category
- CH CV-305A AC
+CH-CV-305B AC
+CH-CV-305D AC
+CH-CV-305C AC DH-TV-1841 A
DH-TV-1847 A (not listed in resubmittal)
FH-A0V-110 B (not listed in resubmittal) 5.4.3 The following are valves that were listed in the IST submittal, and were agreed upon to be non-safety related (safety related as de-fined by NRC Staff Guidance for Preparing Pump / Valve Testing...,"
dated Januray 13,1978) and were deleted from the IST Program.
pl ve Valve Val ve CH-CV-260 CH-CV-268 CH-MOV-298 CH-CV-262 CH-CV-27/
+ General Relief Requested 1825 197 50
5.4.4 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested.
Valve Category Valve Category LO-A0V-202 A
BA-MOV-32 B
LO-A0V-203 A
BA-MOV-373 B
LO-A0V-204 A
LO-M0V-200 8
FH-CV-296 AC CH-FCV-110 B
BA-MOV-366 B
+CH-CV-305A AC BA-CV-320 C
+CH-CV-305B AC 7.BA-CV-387 C
+CH-CV-305C AC BA-CV-372A C
+CH-CV-305D AC 5.5 Main Steam System 5.5.1 The following are valves in the IST program which the licensee intends to test to the applicable ccde requirement.
Valve Category Valve Category MS-SV-11 C
MS-NRV-38 BC MS-SV-12 C
MS-SV-41 C
MS-SV-13 C
MS-SV-42 C
MS-SV-14 C
MS-SV-43 C
MS-NRV-18 BC MS-SV-44 C
MS-SV-21 C
MS-NRV-48 BC MS-SV-22 C
MS-PICV-1206A B
MS-SV-23 C
MS-PICV-1206B B
MS-SV-24 C
BD-V-506 AE MS-NRV-28 BC BD-V-515 AE MS-SV-31 C
BD-V-522 AE MS-SV-32 C
BD-V-529 AE MS-SV-33 C
MS-SV-1216A C
MS-SV-34 C
MS-SV-1216B C
5.5.2 The following are valves in the IST submittal that were recategorized in the resubmittal as a result of the SER meeting.
Valve From Category To Category MS-NRV-11 B
BC MS-NRV-21 B
BC MS-NRV-31 B
BC MS-NRV-41 B
BC "BA-CV-387:
This valve was identified as BA-CV-381 in the IST Program submittal.
+ General Relief Request
- \\-
1825 198 51
Valve From Category To Category MS-TV-1211-1 B
BC MS-TV-1211-2 B
BC MS-TV-1211-3 B
BC MS-TV-1211-4 8
BC BD-TV-1312-1 B
A BD-TV-1312-2 B
A BD-TV-1312-3 8
A BD-TV-1312-4 B
A 5.6 Feedwater System 5.6.1 The following are valves in the IST program, which the licensee intends to test to the applicable code requirement.
Val ve Category Valve Category FW-MOV-35 B
%FW-CV-143-3 C
%FW-CV-143-1 C
%FW-CV-143-4 C
%FW-CV-143-2 C
5.6.2 The following are valves that were listed in the IST submittal, and were agreed upon to be non-safety related (Safety related as de-fined by "NRC Staff Guidance for Preparing Pump / Valve Testing....,"
dated January 13, 1978) and were deleted from the IST Program.
Valve Category Valve Category FW-CV-135-1 C
FW-CV-135-4 C
FW-CV-135-2 C
FW-CV-182 C
FW-CV-135-3 C
5.6.3 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested.
Valve Category Valve Category FW-MOV-11 B
FW-MOV-12 B
FW-FCV-1301-1 B
FW-H ICV-1301-1 B
FW-FCV-1301-2 B
FW-H IC V-1301-2 B
FW-FCV-1301-3 B
FW-HICV-1301-3 B
FW-FCV-1301-4 B
FW-H IC V-1301-4 B
FW-CV-153B C
FW-CV-156-3 C
FW-CV-156-1 C
FW-CV-156-4 C
FW-CV-156-2 C
FW-CV-184 C
FW-MOV-13 8
FW-MOV-14 B
% Note:
The resubmittal states that licensee will " verify open only" 52
Valve Category Valve Category
+*FW-CV-192 C
+*FW-CV-196 C
+*FW-CV-194 C
+*FW-CV-198 C
5.6.4 The following are valves in the IST submittal that were recategorized in the resubmittal as a result of the SER meeting.
Val ve From Category To Category FW-CV-192 C
AC FW-CV-194 C
AC FW-CV-196 C
AC FW-CV-198 C
AC 5.7 Service Water 5.7.1 The following are valves in the IST program 5Aich the licensee intends to test to the applicable code requirement.
Valve Category Valve Category SW-A0V-8 B
SW-CV-276A C
SW-A0V-9 B
SW-CV-270B C
%SW-A0V-1?.9 B
SW-CV-276C C
%SW-A0V-130 B
SW-CV-2760 C
5.7.2 The following are valves in the IST submittal that cannot meet the requirements of Section XI and relief has been requested.
V al v_e_
Category Valve Category SW-MOV-1 B
SW-MOV-3 B
SW-MOV-2 B
SW-MOV-4 B
5.7.3 The following are valves in the IST submittal that cannot be full stroke exercised every 3 months but will meet the requirements of Section XI.
Additional information is required by the NRC to verify the impracticality of full stroke exercising every 3 months.
Valve Category Valve Category SW-MOV-5 B
SW-MOV-6 B
+ General Relief Request
- Valve Recategorized "These valves are shown as SW-V-129 and 130 in the resubmittal.
They are, however, air operated valves and should therefore be shown as SV-A0V-129 and 130.
1825 200 53
6.0 MISCELLANE0US COMNENTS 6.1 Augmented Inspections of Valves:
It is recanmended that the Nuclear Regulatory Canmission (NRC) take a position of requiring augmented inspections for valves that are currently designated as Category E in this IST program, and are proven to be of safety significance.
The Code, to date, has not addressed the generic function of these valves during an accident situation.
It is most essential that these safety related valves be in the correct position during an accident situation. Safety related is defined by "NRC Staff Guid-ance For Preparing Pump and Valve Testing..." dated January 13, 1978.
This definition states " safety related are those pumps and valves necessary to safely shutdown the plant or mitigate the con-sequences fo an accident." Should these valves be in the incorrect position a safe shutdown may not be possible.
The Code chooses to ignore this type of valve with statements of the form:
"IWV-1300 Exclusions.
Valves that are not covered by this Subsection include valves used for operating convenience only such as manual vent, drain, instrument and test valves and valves used for maintenance only."
It is inconsistent to be concerned solely with the operability of some valves (Category A, B, C, and D) when others (Category E valver incorrectly positioned) will nullify the operation of the pumps and Category A, B, C, and D valves.
In light of recent events this inconsistency should be addressed and resolved.
The concept of " augmented inspection" is to have periodic visual inspections, with written records, of the position of the valve.
This concept might be a method of standardizing the procedures re-lating to passive valves (Category E, and non-Category E type),
position verification.
Valves that the NRC should be concerned with are Category E, and non-Category E type valves, such as on the accumulator discharge outlets, valves on either side of safety re-lated pumps, and valves in the ECCS injection path or recirculation path (RWST to RCS, pump to RCS, Emergency Feedwater flow path).
The concept of augmented inspections is not original, the NRC stated it could be used in its November 17, 1976 letter to the Power Authority of the State of New York.
This was a generic let-ter that went to all operating plants.
The topic of the letter was NRC Staff Guidance for Complying with 10 CFR 50.55a(g) - Inservice Inspection Requirements.
54
Conclusion The Inservice Testing Program submitted by the Connecticut Yankee Atomic Povar Company for the Haddam Neck Nuclear Power Station, and modified by this evaluation report is in general compliance with the requirements of Section XI of the 1974 Edition and Addenda through the Summer of 1975 of the ASME Boiler and Pressure Vessel Code as required by 10 CFR 50.55 a(g), and NRC Staff guidance letters and briefings.
Those items not found to be in compliance with the above, require further infomation and evaluation.
P e
1825 202 55
DISTRIBUTION E. Adensam 1
R. Cerbone 1
P. Check 1
C. Cheng 5
A. Coppola 1
G. Edison 1
D. Eisenhut 1
B. Grimes 1
R. Hall 2
W. Kato 1
G. Lainas 1
V. Lettieri 3
V. Noonan 1
W. Osborne 1
E. Pedersen 1
T. Restivo 1
V. Stello 1
T. Telford 1
H. Todosow 2
A. Wang 1
NRC - Division of Technical Information and Control 2
f82'6 203