ML19305D404

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Safety Evaluation Rept,Inservice Testing Program.
ML19305D404
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 02/29/1980
From: Fehringer J, Rockhold H
EG&G, INC.
To: Nerses V
Office of Nuclear Reactor Regulation
References
CON-FIN-A-6258 EGG-EA-5100, NUDOCS 8004150038
Download: ML19305D404 (40)
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lNTERIM REPORT Accession No.

Report No. EGG-EA-5100 Contract Program or Project

Title:

Systems Engineering Support Subject of this Document: Safety Evaluation Report, Inservice Testing Program, Vermont Yankee Plant - Docket No. 50-271 Type of Document: Safety Evaluation Report Author (s):

J. M. Fehringer, H. C. Rockhold Date of Document: February 1980 Responsible NRC Individual and NRC Office or Division: Vic Nerses, NRC-DOR This document was prepared primarily for preliminary orinternat use. it has not received full review and approval. Since there may be substantive changes, this document should not be considered final.

EG&G Idaho, Inc.

Idaho Falls, Idaho 83401 H. P. Pearsion, Supervisor Infonnation Processing Prepared for the U.S. Nuclear Regulatory Commission and the U.S. Department of Energy Idaho Operations Office Under contract No. EY-76-C-07-1570 NRC FIN No.

A6258 INTERIM REPORT

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NRC Researc1 anc echnical Assistance Retmt soon socyg

EGG-EA-5100 February 1980 ,

l SAFETY EVALUATION REPORT, INSERVICE TESTING PROGRAM, l

VERMONT YANKEE PLANT - DOCKET N0. 50-271 l

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. I J. M. Fehringer H. C. Rockhold I

U.S. Department of Energy .

Idaho Operations Office

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FORM E040 396 (Rev. I179)

INTERIM REPORT Accession No.

Report No. EGG-EA-5100

. Contract Program or Project

Title:

Systems Engineering. Support Subject of this Document Safety Evaluation of the Inservice Testing Program for Pumps and Valves at Vermont Yankee Plant, (Dccket No. 50-271) for the Period 7-30-79 to 3-29-81 Type of Document:

Safety Evaluation Report Author (s):

J. M. Fehringer .

H. C. Rockhold Drte of Document:

February 1980 RIsponsible NRC Individual and NRC Office or Division:

Vic Nerses, NRC-DDR 1 '

This document was prepared primarily for preliminary or internal use. it has not received full review and approval. Since there may be substantive changes, this document should not be considered final.

EG&G Idaho, Inc.

Idaho Falls, Idaho 83415

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U.S. Nuclear Regulatory Commission Washington, D.C.

Under DOE Contract No. DE-AC07 76lD0157C i

NRC FIN No. A6258 INTERIM REPORT l

NRC Research and Technical Assistance Ravne Q

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TABLE OF CONTENTS I i

l I. Introduction . . . . . . . . . . . . . . . . . . . . . . . . 1 t

II. Pump Testing Program . . . . . . . . . . . . . . . . . . . . 1 >

I III. Valve Testing Program. . . . . . . . . . . . . . . . . . . . 8 i i

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IV. Attachment I . . . . . . . . . . . . . . . . . . . . . . . . 32 j 4

V. A ttac hment II . . . . . . . . . . . . . . . . . . . . . . . . 34  !

t VI. Attachment III . . . . . . . . . . . . . . . . . . . . . . . 38

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VII. Attachment IV. . . . . . . . . . . . . . . . . . . . . . . . 39 j 4 i i

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I. Introduction Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted on 4-30-79 by the Vermont Yankee Nuclear Power Corporation (VYNPC) for its Vermont Yankee nuclear plant. The program applies to Vermont Yankee for the period 7-30-79 through 3-29-81. The working session with VYNPC and Vermont Yankee representatives was conducted on 7-18-79

'. and 7-19-79. The licensee's re-submittal was issued on 10-23-79 and was reviewed by EG&G Idaho Inc. to verify compliance of proposed tests of safety related class 1, 2, and 3 pumps and valves with requirements of the ASME Boiler and Presssure Vessel Code,Section XI,1974 Edition, through the Summer of 1975 Addenda. VYNPC has also requested relief from the ASME Code from testing specified pumps and valves because of practical reasons.

These requests have been evaluated individually to determine whether they have significant risk' implications and whether the tests, as required, are indeed impractical.

The evaluation of the pump testing program and relief requests for pumps is contained in Section II below; the evaluation of the valve testing program and associated relief requests is contained in Section III. All evaluations for Sections II and III are the '

recommendations of EG&G Idaho Inc.

Appendix J exemption requests for category A valves currently j

being reviewed by the NRC are contained in Attachment I.

Category A, B, and C valves that meet the requirements of the

. ASME Code Section XI and are not exercised every 3 months are contained in Attachment II. '

Valves that are never full stroke exercised or that have a testing interval greater than each refueling outage are contained in Attachment III.

A listing of P&ID's used for this review are contained in Attachment IV.

f II. Pump Testing Program The IST program submitted by VYNPC was examined to verify that

, Class 1, 2, and 3 safety related pumps were included in the program and that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that Class 1, 2, and 3, safety related pumps were included in the IST program and except for those pumps identified below for which specific relief from testing has been requested, the pump tests and frequencey of testing comply with the code. Each VYNPC request for relief from testing pumps, the code requirement for testing, VYNPC's basis for requesting relief, and EG&G's evaluation of that request is summarized below, grouped according to the system in which the pumps reside.

1

9 A. Service Water

1. Relief Request The licensee has requested specific relief from measuring bearing tenperature on service water pumps -

P7-1A-D in accordance with the requirements of '

Section XI. ,

Code Requirement "

An inservice test shall be conducted on all safety ,

related punps, nominally once each month during normal  ;

plant operation. Each inservice test shall include the i measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing

  • ^

tenperature, which shall be measured during at least one inservice test each year. ,

Licensee's Basis for Requesting Relief 3 The service water pump bearings are physically submerged under a minimum of 30 feet of river water.

Contact pyrometer readings would be impractical. '

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

that relief should be granted for service water pumps P7-1A-D. We conclude that attempting to measure bearing tenperature under these specific conditions would provide inaccurate readings and would not provide any meaningful data for analyzing pump hydraulic or mechanical change.

4

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B. Residual Heat Removal Service Water

1. Relief Request The licensee has requested specific relief from measuring bearing temperature on the residual heat removal service water pumps P8-1A-D in accordance with the requirements of Section XI.  ;

Code Requirement '

An inservice test shall be conducted on all safety .

related pumps, nominally once each month during normal plant operation. Each inservice test shall include the 2

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measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least

{ one inservice test each year.

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Licensee's Basis for Requesting Relief  ;

1 The pump bearings are internal to the pump casing and I

. therefore are completely inaccessible for temperature -

measurements.  :

1 Evaluation -

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We agree with the licensee's basis, and therefore feel j i that relief should be granted for residual-heat removal i
service water pumps P8-1A-D. We conclude that  !
measuring bearing temperature under these specific r i conditions would provide inaccurate readings and would  !
not provide any meaningful data for analyzing pump l hydraulic or mechanical change. j

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4 C. Residual Heat Removal  :

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! 1. Relief Request

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The licensee has requested specific relief from -

measuring bearing temperature on the residual heat  !

! removal pumps P10-1A-D in accordance with the '

requirements of Section XI.

1 Code Requirement i

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An inservice test shall be conducted on all safety  :

i related pumps, nominally once each month during normal l l plant operation. Each inservice. test shall include the >

measurement, observation, and recording of all  !

quantities in Table IWP-3100-1, except bearing ,

l'- temperature, which shall be measured during at least _

one inservice test each year. .

Licensee's Basis for Requesting Relief '

The bearings are internal to the pump casing and are I i- . inaccessible for temperature measurements. A contact  !

pyrometer would not-be feasible since the casing is large and would quickly dissipate heat.

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Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for residual heat removal pumps P10-1A-D. We conclude that measuring bearing temperature under these specific conditions would -

provide inaccurate readings and would not provide any meaningful data for analyzing pump hydraulic or .

mechanical change.

D. High Pressure Coolant Injection

1. Relief Request The licensee has requested specific relief from measuring bearing temperature for high pressure coolant injection pump P44-1A in accordance with the requirements of Section XI.

Code Requirement An inservice test shall be conducted on all safety related pumps, nominally once each month during normal

  • plant operation. Each inservice test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least -

one inservice test each year.

Licensee's Basis for Requesting Relief There are no means available to measure the bearing temperature or a surface representative of bearing temperature. These bearings are internal to the puup casing and are inaccessible for temperature measurement. A contact pyrometer would not be feasible since the casing is large and would quickly dissipate the heat.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for high pressure coolant .

injection pump P44-1A. We conclude that measuring bearing temperature under these specific conditions would produce inaccurate readings and would not provide -

any meaningful data for analyzing pump hydraulic or mechanical change.

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E. Standby Liquid Control

1. Relief Request The licensee has requested specific relief from measuring bearing temperature on standby liquid control pumps P45-1A/B in accordance with the requirements of Section XI.

Code Requirement An inservice test shall be conducted on all safety related pumps, nominally once each month during normal plant operation. Each inservice test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.

Licensee's Basis for Requesting Relief The bearings are internal to the pump casing and are inaccessible for temperature measurements. A contact ,

pyrometer would not be feasible since the casing is large and quickly dissipates the heat.

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

that relief should be granted for standby liquid control pumps P45-1A/B. We conclude that measuring bearing temperature under these specific conditions would produce inaccurate readings and would not provide any meaningful data for analyzing pump hydraulic or mechanical change.

F. Core Spray

1. Relief Request The licensee has requested specific relief from measuring bearing tenperature on core spray pumps P46-1A/B in accordance with the requirements of Section XI.

Code Requirement An inservice test shall be conducted on all safety related pumps, nominally once each month during normal 5

plant operation. Each inservice test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year. ~

Licensee's Basis for Requesting Relief

.r The bearings are internal to the pump casing and are inaccessible for temperature measurements. A contact pyrometer would not be feasible since the casing is large and would quickly dissipate the heat.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for core spray pumps P46-1A/B. We conclude that measuring bearing temperature under these specific conditions would provide inaccurate readings and would not provide any meaningful data for analyzing pump hydraulic or mechanical change. .

G. Reactor Core Isolation Cooling

1. Relief Request -

The licensee has requested specific relief from .

measuring bearing temperature on reactor core isolation cooling pump P47-1A in accordance with the requirements of Section XI.

Code Requirement '

An inservice test shall be conducted on all safety related pumps, nominally once each month during normal plant operation. Each inservice test shall include the measurement, observaton, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.

Licensee's Basis for Requesting Relief '

There are no means available to measure the bearing -

temperature or a surface representative of bearing temperature. These bearings are internal to the pump

' casing and are inaccessible for temperature measurement. A contact I

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pyrometer would not be feasible since the casing is large and would quickly dissipate the heat. ,

Evaluation

~ We agree with the licensee's basis, and therefore feel that relief should be granted for reactor core isolation cooling pump P47-1A. We conclude that measuring bearing temperature under these specific conditions would provide inaccurate readings and would '

not provide any meaningful data for analyzing pump l hydraulic or mechanical change. I H. Fuel Oil Transfer

1. Relief Request '

The licensee has requested specific relief from measuring bearing temperature on fuel oil transfer pumps P92-1A/B in accordance with the requirements of ,

Section XI.

Code Requirement An inservice test shall be conducted on all safety i related pumps, nominally once each month during normal plant operation. ,

Each inservice test shall include the t measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing  !

i temperature, which shall be measured during at least '

one inservice test each year.

Licensee's Basis for Requesting Relief Per IWP-3500, bearing temperature measurements require that each pump be run until the bearing temperatures stabilize.... A bearing temperature is considered stable when three successive readings taken at ten minute intervals do not vary by more than 3%. The fuel oil transfer pump operability test can only be '

performed when the diesel is undergoing testing. When low level is sensed in the day tank, the fuel oil transfer pumps provide the make-up. This normally takes less than 15 minutes. This is not sufficient time to record a meaningful bearing temperature. l 7

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for fuel oil transfer pumps P92-1A/B. We conclude that measuring bearing .

temperature under these specific conditions would provide inaccurate readings and would not provide any meaningful data for analyzing pump hydraulic or -

mechanical change.

III. Valve Testing Program The IST program submitted by VYNPC was examined to verify that Class 1, 2, and 3 safety related valves were included in the program and that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. Our review found that Class 1, 2, and 3 safety related valves were included in the IST program and, except for those valves identified below for which specific relief from testing has been requested, the valve tests and frequency of testing comply with the code requirements and the NRC positions and guidelines listed in General Section A. Also included in the ,

General Section A is the NRC position and valve listings for the leak testing of valves that perfonn a pressure isolation function and a procedure for the licensee's use to incorporate these valves into the IST program. Each request for relief from .

testing valves, the code requirement for testing, the licensee's basis for requesting relief, and the EG&G's evaluation of that -

request is summarized (B through 0) below, and grouped according to each specific system.

A. General

1. 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 reactor coolant system operating pressure. There are redundant isolation valves forming the interface between these high and low i

pressure systems to prevent the low pressure systems -

from being subjected to pressures which exceed their i

design limits. In this role, the valves are performing

! a pressure isolation function. ,

It is our view that the isolation redundancy provided by these valves regarding their pressure isolation function is important. We consider it necessasry to 8

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l i provide assurance that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For this reason we believe that some method, such as leak testing, should be used to ensure the condition of each valve is satisfactory to

, maintain this pressure isolation function.

In the event that leak testing is selected as the appropriate method for achieving this objective, we believe 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:

V10-46A and V10-27A RHR inlets to reactor coolant system V10-46B and V10-278 RHR inlets to reactor coolant system V10-17 and V10-18 RHR suctions from the reactor coolant system V14-13A and V14-12A CS inlets to reactor coolant system V14-13B and V14-12B CS inlets to reactor coolant system We have discussed this matter and identified the valves i listed above with the licensee. The licensee has agreed to consider leak testing each of these valves in accordance with IWV-3420 of the applicable edition of the ASME Code and to categorize these valves with the appropriate designation. If the licensee determines that leak testing is not necessary because there are other methods that they have and will use to determine each valve's condition, they will provide to the NRC for evalution, on a valve by valve basis, the details of the method used that clearly demonstrates the ,

condition of each valve. The licensee has agreed to provide the above information by (date will be provided by the NRC).

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2.  ;

Subsection IWV-3410(a) of the Section XI Code (which

- discusses full stroke and partial stroke requirements) requires that Code Category A and B valves be exercised +

once every three months, with exceptions as defined in IWV-3410(b) (1), (e) and (f). IWV-3520(a) (which i discusses full stroke and partial stroke requirements)

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requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3520 (b). In the above cases of exceptions, the Code permits 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 f;r. tion or to the partial position during power operation. ~

(b) It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.

The staff stated its position to the licensee that check valves whose safety function is to open are expected to be full-stroked. If only limited operation is possible (and it has been demonstrated by the s licensee and agreed to by the staff) the check valve shall be partial stroked. Since disk position is not always observable, the NRC staff stated that verificaion of the plant's safety analysis design flow rate through the check valve would be an adequate '

demonstration of the full-stroke requirement. Any flow rate less than design will be considered part-stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would be -

equivalent to or greater than the design flow rate through the valve. The licensee agreed to conduct his flow test to satisfy the above position.

  • The licensee has stated that none of the Category A or B power operated valves can be part-stroked because of the design logic of the operating circuits. These circuits are such that when an open or close signal is L received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other direction. We find that the above relief request from part-stroking is warranted and should be granted because the required function of the valves involves only full open or full closed positions.
3. Inservice valve testing at cold shutdown is defined as: Valve testing should commence not later than 48 ~

hours after shutdown and continue until complete or plant is ready to return to power. Compl'etion of all .

valve testing is not a prerequisite to return to power. -Any testing not completed at one cold shutdown should be performed during the subsequent cold shutdowns to meet the Code required testing frequency.

i 10

We find the licensee's proposed cold shutdown condition testing acceptable.

4.

The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Category A and B valves and once every nine months for Category C valves. It is

. NRC's position that the code is inconsistent and that Category C valves should be tested on the same schedule as Category A and B valves. The licensee has agreed to modify any procedures as necessary on cold shutdown to read, "In the case of frequent cold shutdowns, valve testing need not be performed more often than once every three (3) months for Category A, B and C valves."

5. Changes to the Technical Specification In a November 1976 letter to the VYNPC NRC provided an

. attachment entitiled "NRC Guidelines for Excluding Exercising (Cyclin Plant Operation." g) Tests of Certain Valves During The attachment stated that when one train of a redundant system such as the Emergency Core

  • Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not be cycled since their failure would cause a loss of total system function. For example, during power operation in some 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 requirements within the time period specified in the plant's Technical Specifications, the reactor is required to be put in some other mode. Furthermore, prior to initiating repairs all valves and interlocks 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.

6. Safety Related Valves  ;

This review was limited to those Class 1, 2 and 3 valves of Section XI of the ASME Code that are safety related.

Safety related valves are defined as those that are needed to mitigate the consequences of an accident and/or shutdown the reactor and to maintain the reactor in a shutdown condition.

11 '

i It should be noted that the licensee may have included nonsafety related valves in their Inservice Test Program as a decision on the licensee's part to expand the scope of their Inservice Test Program.

7. For those valves that are impractical to test * '

quarterly, the licensee has proposed to test them at cold shutdowns or refueling outages. In staff .

i discussions with the licensee on (7-18-79 and 7-19-79) i the licensee has agreed to change this position to test at cold shutdowns and refueling. The licensee has also [

agreed to change their definition "C/R" to cold .

shutdown and refueling instead of the proposed cold  ;

shutdown or refueling. Valve testing exceptions to the above stated position are specifically addressed in this S.E.R. '

) B. Recirculation Pumps

1. Category A/C Valves
a. Relief Reguest
  • The licensee has requested specific relief from exercising category A/C valves 2-2-7A/B and 2-2-8A/B, excess flow checks for instrument isolation, in accordance with the requirements of ~

Section XI and proposed to full stroke exercise these valves during refueling outages. .

Code Requirement

  • 1 Refer to valve testing paragraph A.2.

4 Licensee's Basis for Requesting Relief Valves cannot be shut during power operation since shutting these valves would isolate instrumentation required for power operation.

Valves can only be verified shut by leak testing  ;

l which is performed during the refueling outage '

hydrostatic test.

I Evaluation '

s We agree with the licensee's basis, and therefore -

feel that relief should be granted for category A/C valves 2-2-7A/B and 2-2-8A/B from the  :

exercising requirements of Section XI. These valves are normally open during all modes of

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reactor operation; their safety position is shut.

The licensee has demonstrated that verifying valve '

closure (full stroke exercising) can only be accomplished during refueling outages when the hydrostatic test of the system is performed. This testing is beyond the scope of cold shutdown testing. We conclude that the proposed alternate testing frequency should verify proper valve operability.

L' .

Service and Instrument Air

1. Category A/C Valves
a. Relief Request The licensee has requested specific relief from exercising category A/C valves V72-37A/B and V72-103A/B, primary containment isolations, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief These valves are normally closed and passive during power operation. The safety function of these valves is to remain shut during an accident situation.

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A/C valves V72-37A/B and V72-103A/B from the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are

. meaningless for passive valves.

b. Relief Request The licensee has requested specific relief from 13 l

exercising Category A/C valves V-72-89B/C in accordance with the requirements of Section XI and proposed to verify valve opening during power operation and verify valve closure during refueling outages.

. Code Requirement Refer to valve testing paragraph A-2. -

Licensee's Basis for Requesting Relief There are no means available to test these valves in the manner prescribed by IWV-3520. The valves will be verified open during normal system operation. These valves can only be verified shut during leak testing in accordance with appendix J.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valves V72-898/C from the exercising '

requirements of Section XI. These valves are normally open during all modes of reactor operation, their safety position is shut. The licensee has demonstrated that verifying valve .

closure (full stroke exercising) can only be accomplished during refueling outages when appendix J 1eak testing is performed. This -

testing is beyond the scope of cold shutdown testing. We conclude that the proposed alternate testing frequency should verify proper valve operability.

D. Nuclear Boiler

1. Category A and A/C Valves
a. Relief Request The licensee has requested specific relief from exercising Category A valves V2-74 and V2-77, primary containment isolations, in accordance with -

the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A-2.

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Licensee's Basis for Requesting Relief These valves are normally closed, passive valves, not required to change position in the event of an accident.

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A valves V2-74 and V2-77 from.the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves,

b. Relief Request L

The licensee has requested specific relief from exercising category A/C valves 2-3-23, 2-62A-D, 2-64A-D, 2-73A-H, and 2-305A/B, excess flow checks

' for instrument isolation, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief Valves cannot be shut during power operation since shutting these valves would isolate instrumentation required for power operation.

Valves can only verified shut by leak testing which is performed during the refueling outage hydrostatic test.

Evaluation We agree with the licensee's basis, and therefore feel.that relief sh Wld be granted for category A/C valves 2-3-23, 2-d h-D, 2-64A-D, 2-73A-H and 2-305A/B from the exercising requirements of 15 t __

Section XI. These valves are normally open during all modes of reactor operation; their safety position is shut.

that verifying valveThe licensee has demonstrated closure exercising) can only be accomp(full. stroke lished during -

refueling outages when the hydrostatic test of the ,

system is performed. This testing is beyond the scope of cold shutdown testing. We conclude that ,

the proposed alternate testing frequency should verify proper valve operability,

2. Category B/C Valves i
a. Relief Request The licensee has requested specific relief from exercising category 8/C valves RV2-71A-D automatic depressurizations, in accordance with the requirements of Section XI and proposed to partial stroke exercise 50% of these valves each refueling outage.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief Valves cannot be exercised during power operation '

i since failure in the open position would require tripping the reactor. Also, live steam would be discharged to the suppression pool which would i

heat the water and pressurize the containment.

This causes undue structural stresses in the containment. Valves cannot be exercised during cold shutdowns since steam is required to stroke the main piston in the valve. Experience in .

4 safety and relief valve operation shows that testing 50% of the valves per refueling outage is adequate to detect failures or deterioration.

Valve design prohibits full stroke exercising.

Evaluation ~

' We agree with the licensee's basis, and therefore -

feel that relief should be granted for category B/C valves RV2-71A-D from the exercising l

requirements of Section XI. The licensee has demonstrated that exercising these 16 L

1

valves during power operation would cause undue structural stresses on the containment, and during cold shutdowns is not possible since steam is required for testing. Since valve design prevents full stroke exercising, the only possible test is a manual partial stroke exercise test with the reactor at low pressure following a refueling outage.

We conclude that the proposed alternate test is the most practical method to ensure proper valve operability given the present plant design.

3. Category C Valves
a. Relief Request The licensee has requested specific relief from exercising category C valves V2-278 and V2-96B, feedwater checks for HPCI and RCIC operation, in accordance with the requirements of Section XI and proposed to verify valve opening during power '

operation and to verify valve closure during refueling outages.

  • Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief These normally open valves cannot be shut during power operation without causing a reactor trip.

Testing via the HPCI and RCIC will cause thermal shocking of the feedwater nozzles and could result in damage to reactor internals. Testing these valves during cold shutdown would require removing from service the only mechanism of vessel level control, the reactor cleanup system.

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for category C

. valves V2-278 and V2-968 from the exercising requirements of section XI. The licensee has demonstrated that exercising these valves during power operation would result in a reactor trip or thermal shocking the feedwater nozzles; also, that securing vessel water level control during cold shutdown would place the plant in an unsafe condition. We conclude that verifying valve closure, the safety related position, is possible only during refueling outages when the HPCI and 17 l

RCIC full flow tests are conducted with the vessel head removed to provide the required expansion volume and the reactor cleanup system secured.

E. Core Spray

1. Category A/C Valves
a. Relief Request The licensee has requested specific relief from exercising category A/C valves 14-31A/B, excess flow checks for instrument isolation, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief '

Valves cannot be shut during power operation since shutting these valves would isolate instrumentation required for power operation. .

Valves can only be verified shut by leak testing which is performed hydrostatic test. during the refueling outage

  • Evaluation We agree with the licer,see's basis, and therefore feel relief should be granted for category A/C valves 14-31A/B from the exercising requirements of Section XI. These valves are normally open during all modes of reactor operation; their safety position is shut. The licensee has demonstrated that verifying valve closure (full stroke exercising) can only be accomplished during refueling outages when the hydrostatic test of the system is performed. This testing is beyond the scope of cold shutdown testing. We conclude that -

the proposed alternate testing frequency should verify proper valve operability.

l 18 1

F. High Pressure Coolant Injection

1. Category A/C Valves
a. Relief Request '

The licensee has requested specific relief from  !

exercising category A/C valves SL23-37A-D, excess flow checks for instrument isolation, in

- accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

Code Requirement  !

Refer to valve testing paragraph A.2 l

Licensee's Basis for Requesting Relief Valves cannot be shut during power operation since shutting these valves would isolate instrumentation required for power operation. ,

Valves can only be verified shut by leak testing which is performed during the refueling outage 4

hydrostatic test.

, Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for category A/C valves SL23-37A-D from the exercising requirements of Section XI. These valves are normally open during all modes of reactor i operation; their safety position is shut. The licensee has demonstrated that verifying valve closure (full stroke exercising) can only be  :

accomplished during refueling outages when the >

hydrostatic test of the system is performed. This testing is ieyond the scope of cold shutdown testing. We conclude that the proposed alternate -

testing frequency should verify proper valve operabi1ity. ,

, 2. Category B Valves

a. Relief Request The licensee has requested specific relief from stroke timing Category B valve PCV23-50 in accordance with the requirements of Section XI.

19 9 f

Code Requirement Refer to valve testing paragraph A.2 Licensee's Basis for Requesting Relief '

This valve is a modulating valve. Stroke time is -

not an appropriate reference parameter. Proper valve operation is verified through normal system ,

operation during the HPCI pump test.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for category B 1

valve PCV23-50 from the stroke timing requirements of Section XI. The licensee has demonstrated that stroke timing a modulating valve will not provide any meaningful data on valve degradation. We conclude that verifying proper system operation is

' the most practical method of ensuring proper modulating valve operability.

G. Control Rod Drive Hydraulic

1. Category B Valves .
a. Relief Request -

f The licensee has requested specific relief from exercising and timing category B valves V3-13-126 and V3-13-127 in accordance with the requirements of Section XI and proposed to exercise and time 50% of the control rods every 16 to 32 weeks and

[ to exercise refueling and time 100% of the control rods each outage. (There are 89 number 126 and 127 valves, one of each for each control rod).

Code Requirement '

Refer to valve testing paragraph A.2 Licensee's Basis for Requesting Relief Exercising these valves during power operation '

would require scramming the plant or an undesirable reactor transient. Since scram insertion times are representative of valve I operability and stroke times, alternate testing will be performed in accordance with Tech. Spec.

I 20

section 4.3.C.1 and 2. This section requires that all control rods be subjected to scram-tiae measurements on a refueling outage basis. Also, this section requires that 50% of the control rods be measured for scram times every 16 to 32 weeks.

An evaluation is required that provides reasonable assurance that proper control rod drive

- performance is being maintained. These tests adequately verify valve operability and stroke times.

Evaluation We agree with the licensee basis, and therefore feel relief should be granted for Category B Valves V3-13-126 and 127 from the exercising and timing requirements of Section XI. The licensee has demonstrated that the proposed testing program is more conservative than testing during cold shutdowns. A reactor power reduction is required to conduct these tests and a testing frequency more restrictive than the one proposed would .

result in unnecessary power and operating restrictions. We conclude that the proposed alternate testing method and frequency is the most practical method to ensure these valves function properly to perform their safety function and that a more restrictive testing frequency would only restrict plant operations.

2. Category C Valves
a. Relief Request The licensee has requested specific relief from exercising category C valves V3-13-114 in accordance with the requirements of Section XI and proposed to full stroke exercise 50% of the control rods every 16 to 32 weeks and to full stroke exercise 100% of the control rods each refueling outage. (There are 89 number 114 valves, one for each control rod).

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief Exercising these valves during power operation 21 t

would require scramming the plant or an undesirable reactor transient. Since scram insertion times are representative of valve operabiblity, alternate testing will be performed in accordance with Tech. Spec. section 4.3.C.1 and

2. This section requires that all control rods be subjected to scram-time measurements on a ~

refueling outage basis. Also, this section requires that 50% of the control rods be measured .

for scram times every 16 to 32 weeks. An avaluation is required that provides reasonable assurance that proper control rod drive performance is being maintained. These tests adequately verify valve operability and stroke times.

Evaluation We agree with the licensee basis, and therefore feel relief should be granted for Category C valves V3-13-114 from the exercising requirements of Section XI. The licensee has demonstrated that the proposed testing program is more conservative than testing during cold shutdowns. A reactor power reduction is required to conduct these tests and a testing frequency more restrictive than the one proposed would result in unnecessary power and operating restrictions. We conclude that the proposed alternate testing method and frequency -

the most practical method to ensure these valves '

function properly to perform their safety function and that a more restrictive testing frequency would only restrict plant operations.

H. Standby Liquid Control

1. Category A/C Valves
a. Relief Request The licensee has requested specific relief for Category A/C valves V11-16 and V11-17, SLC injections into the reactor, from the exercising requirements of Section XI and proposed to full ,

stroke exercise these valves during refueling outages. -

22

Code Requirement Refer to valve testing paragraph A-2.

bicensee's Basis for Requesting Relief Exercising these valves during power operation would require injecting borated water into the '

reactor coolant system. This would create a reactivity excursion and potential for reactor trip. Injection of demineralized water would require removing the system from service to clean the borated solution from the piping and replacing '

the explosive actuated valves. This system is required for power operation. Perfonning the demineralized water test during cold shutdowns is impractical since extensive flushing of the boron from the system for several days is required to reduce the boron concentration to a level compatible for injection into the reactor coolant system. Valves will be full stroke exercised during refueling outages. .

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valves Vll-16 and V11-17 from the exercising requirements of Section XI. The licensee has ,

demonstrated that exercising these valves during power operation would cause reactivity excursions and possible reactor trips and during cold shutdown would require extensive flushing and possibly delay reactor start-ups. We conclude that the proposed exercising frequency for these valves during refueling outages is the most practical method to ensure they will function properly, in the direction required to mitigate the consequences of an accident with the present piping configuration.

I. Residual Heat Removal

1. Category B Valves
a. Relief Request The licensee has requested specific relief from stroke timing Category B valves V10-89A/B in accordance with the requirements of Section XI.

23 i

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief .

This valve is a modulating valve. Stroke time is not an. appropriate reference parameter. Proper

  • valve operation is verified through normal system operation during the HPCI pump test.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category B valves V10-89A/B from the stroke timing requirements of Section XI. The licensee has demonstrated that stroke timing a modulating valve will not provide any meaningful data on valve ,

degradation. We conclude that verifying proper system operation is the most practical method of ensuring proper modulating valve operability. .

J. Reactor Core Isolation Cooling

1. Category A/C Valves
a. Relief Request The licensee has requested specific relief from exercising Category A/C valves SL13-55A-0, excess flow checks for instrument isolation, in acccedance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief Valves cannot be shut during power operation since -

shutting these valves would isolate instrumentation required for power operation.

Valves can only be verified shut by leak testing which is performed during the refueling outage hydrostatic test.

i l

l 24 i

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valves SL13-55A-D from the exercising

- requirements of Section XI. These valves are ,

normally open during all modes of reactor '

operation and their safety position is shut. The licensee has demonstrated that verifying valve closure (full stroke exercising) can only be accomplished during refueling outages when the hydrostatic test of the system is performed. This testing is beyond the scope of cold shutdown testing. We conclude that the proposed alternate testing frequency should verify proper valve operability.

2. Category B Valves
a. Relief Request The licensee has requested specific relief from ,

stroke timing Category B valves PCV13-23 and the turbine governor in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief The valves are modulating valves. Stroke time is not an appropriate reference parameter. Proper valve operation is verified through normal system operation during the HPCI pump test.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category B valves PCV13-23 and the turbine governor from the stroke timing requirements of Section XI. The i licensee has demonstrated that stroke timing a modulating valve will not provide any meaningful

- data on valve degradation. We conclude that verifying proper system operation is the most practical method of ensuring proper modulating valve operability. I 25 i

K. Primary Containment and Atmosphere Control

1. Category A and A/C Valves '
a. Relief Request '

~

The licensee has requested specific relief from '

exercising Category A valves, SB16-19-6A, SB16-19-7A/B, SB16-19-9, SB16-19-10, and -

V16-10-22, primary containment isolations, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A-2. -

Licensee's Basis for Requesting Relief r These valves are normally closed and remain

  • passive in the event of an accident. A quarterly test frequency is not required for passive valves.

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted.for Category A valves SB16-19-6A, SB16-19-7A/B, SB16-19-9, .;

SB16-19-10, and V16-20-22 from the requirements of Section XI. These valves are in their safety related position and are not required to open or -

close to mitigate the consequences of an accident or safely sut down the plant. Therefore, the i operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke i and stroke time measurements are meaningless for

  • passive valves,
b. Relief Request '

The licensee has requested specific relief from leak testing Category A valves V16-19A-J, torus ,

drywell vacuum breakers, in accordance with the requirements of Scetion XI and proposed to leak -

test all valves concurrently.  !

Cota Requirement "

l Refer to valve testing paragraph A-2.

l l

I 26

Licensee's Basis for Requesting Relief These valves cannot be leak tested individually.

A leak test will be done which will demonstrate

- that with an internal differential pressure of not less than 1.0 psi, the differential pressure decay rate shall not exceed the equivalant of the leakage rate through a 1-in. orifice.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A valves V16-19A-J from the leak testing requirements of Section XI. The licensee has demonstrated that due to plant design and present piping configurations, individual leak testing of these valves cannot be accomplished. We conclude that the proposed alternate total leakage rate test is the best available test with present piping configurations to ensure these valves will function properly to perform their joint safety function.

L. HVAC - Reactor Building

1. Category A Valves
a. The licensee has requested specific relief for Category A valve SB16-19-7, primary containment isolation, from the exercising requirements of Section XI.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief This valve is normally closed and remains passive in the event of an accident. A quarterly test frequency is not required for passive valves.

Evaluation We agree with the licensee's basis, and therefore f feel relief should be granted for Category A valve

^

SB16-19-7 from the requirements of Section XI.

This valve in its safety related position is not required to open or close to mitigate the consequences of an accident or safely 27

shut down the plant. Therefore, the operabi,lity  !

of this valve is inconsequential with regard to the safety function which it performs. We conclude that the quarterly stroke and stroke time l

measurements are meaningless for passive valves.  ;

M. Nuclear Boiler Vessel Ic2trumentation

1. Category A/C Valves '
a. Relief Request The licensee has requested specific relief from exercising Category A/C valves 2-3-11,2-3-13A/B, 2-3-15A/8, 2-3-17A/8, 2-3-19A/B, 2-3-21A-D, 2-3-23A-D 2-3-25, 2-3-29A/B, 2-3-31A-H, 2-3-311-Q, 2-3-33, 2-3-35, excess flow checks for instrument isolation, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A-2.

  • Licensee's Basis for Requesting Relief Valves cannot be shut during power operation since  ;

shutting these valves would isolate instrumentation required for power operation. ,

Valves can only be verified shut by leak testing which is performed during the refueling outage hydrostatic test. ,

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valves 2-3-11, 2-3-13A/B, 2-3-15A/B, 2-3-17A/B, 2-3-19A/B, 2-3-21A-D, 2-3-23A-D, 2-3-25, 2-3-29A/B, 2-3-31A-H, 2-3-31I-Q, 2-3-33,

  • and 2-3-35 from the exercising requirements of Section XI. These valves are normally open during all modes of reactor operation and their safety
  • position is shut. The licensee has demonstrated that verifying valve closure (full stroke -

exercising) can only be accomplished during refueling outages when the hydrostatic test of the system is performed. This testing is oeyond the scope of cold shutdown testing. We conclude l

28

that the proposed alternate testing frequency should verify proper valve operability.

N. Containment Atmosphere Dilution

1. Category A Valves
a. Relief Request The licensee has requested specific relief from ,

exercising Category A valves FS0-109-75Al/2, primary containment isolations, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A-2.

Licensee's Basis for Requesting Relief '

These valves are normally closed and remain passive in the event of an accident. A quarterly test frequency is not required for passive valves. '

Evaluation

  • We agree with the licensee's basis, and therefore feel relief should be granted for Category A valves FS0-109-75A1/2 from the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident '

or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.

O. Traversing In-core Probe

1. Category A Valves

. a. Relief Request

- The licensee has requested specific relief from stroke timing Category A valve,.TIP solenoid, in accordance with the requirements of Section XI and proposed to measure stroke times to the nearest second.

29

Code Requirement

1. The limiting value of full stroke time of each power operated valve shall be specified by the owner. *
2. The stroke time of all power-operated valves .

shall be measured to the nearest second or 10% of the maximum allowable stroke time, whichever is less, whenever such a valve is full-stroke tested.

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 in observed, 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.

Licensee's Basis for Requesting Relief This valve is a fast acting 1/2 inch solenoid .

valve with a stroke time of less than one second.

The valves listed have Technical Specifications .

time requirements of 5 seconds. When applying the timing requirements of the code, these valves must be timed to 0.5 second. Most of these valves have actual times of 0.3 to 0.6 second. Because of these fast times and the timing increments involved, a slight increase in stroke time will exceed the 50% time increase of IWV 3410(C)(3).

The 0.5 second requirement for these particular valves is too restrictive and may cause increased valve testing which is not truly indicative of valve performance. If an increase in stroke time of one second is observed, corrective action will be taken or the test frequency will be increased to monthly. .

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A valve, TIP solenoid, from the stroke timing 30

" equi"ements Of Section tl. The licensee has demonstrated that measuring str0(e times to the nea est .5 second and that a limit cf 50% for an increase in stroke time for valves with stroke times less than one second will not provide any meaningful data on valve degradation. We conclude '

that a 1 second increase in valve stroke time

~ before corrective action is required will provide i a more meaningful limit so valves are not overesercised because of a t00 restrictive limit.

i 1

h I

e e

i L

a 31

r-Attachment I A. Appendix J Exemption' Requests 1.

The NRC is presently reviewing the VYNPC Appendix J exemption request from leak testing the following valves in '

accordance with the requirements of Appendix J.

Service and Instrument Air ,

V72-37A/B V72-103A/B Nuclear Boiler V2-28A/B 'V2-39 V2-40 V2-74 V2-77 V2-86A-D V2-80A-D High Pressure Coolant Injection V23-15 V23-16 Control Rod Drive Hydraulic V3-181 Standby Liquid Control V11-16 V11-17 Residual Heat Removal .

V10-17 V10-18 V10-26A/8 V1031A/B V10-32 V10-33 V10-34A/B V10-38A/B V1039A/B V10-57 V10-66 Reactor Core Isolation Cooling V13-15 V13-16 i Primary Containment Atmosphere Control i

SB16-19-6A/B SB16-19-17A/B SB16-19-8 SB16-19-10 SB16-19-9 SB16-19-11A/B V16-19-12A/8 V16-20-20 V16-20-22A/B V16-19-23 l Radwaste V20-82 V20-83 V20-94 V20-95 i

32

Reactor Water Cleanup V12-15 V12-18 V12-68 HVAC - Reactor Building SB16-19-6 SB16-19-7 Containment Atmosphere Dilution FS0-109-75A1/2 FS0-109-75B1/2 FS0-109-75C1/2 FS0-109-7501/2 FS0-109-76A/B Traversing In-core Probe Ball A - C Solenoid If this exemption is authorized, the above mentioned valves will be exempt from the leak testing requirements of Appendix J and Section XI. If this exemption is not authorized, plant modifications will be required to ensure leak testing will be in accordance with the requirements of Appendix J and Section XI. '

S 9

9 33

Attachment II The following are Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not full stroke exercised every three months during plant operation. These valves are specifically identified by the owner and are full stroke exercised -

during cold shutdowns and refueling outages. EG&G has reviewed all valves in this attachment and agrees with the licensee that testing .

these valves during power operation is not possible due to valve type and location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be '

exercised during power operation. These valves are listed below and grouped according to the system in which they are located.

A. Nuclear Boiler 1.

Category C valves SR2-14A-D, relief valve discharge line vacuum breakers, cannot be exercised during power operation since.the valves are located inside the drywell and are not accessible. These valves will be manually exercised during cold shutdowns and refueling outages.

2.

Category B valves V2-53A/B and V2-54A/B, recirculation pump discharge and by-pass valves, cannot be exercised during operation since this would require a reactor trip. These valves will be full stroke exercised during cold shutdowns of duration greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and refueling outages. -

B. Core Spray System

1. Category C valves V14-13A/B cannot be full or partial stroke exercised during power operation since pump discharge pressure cannot overcome reactor pressure. These valves cannot'be exercised manually during power operation since the drywell is not accessible. These valves will be full stroke exercised during cold shutdowns when the drywell is accessible and during refueling outages.

C. High Pressure Coolant Injection 1.

1=

Category A valves V23-15 and V23-16, and Category B valves V23-17, V23-19, and V23-20 injection mode valves, cannot be exercised during power oper,ation since repositioning these valves would render the HPCI system inoperable if the valve ~

failed in the unconservative position. These valves will be full stroke exercised during cold shutdowns and refueling outages. -

2. Category C valve V23-18, injection check valve, cannot be

{

T exercised during power operation since flow through this I

34 y 4

valve must be injected into the reactor coolant system.

This would thermally shock the reactor nozzles and cause a reactivity excursion. Manual valve operation is not possible during power operation since the valve is located in the steam tunnel which is not accessible. This valve will be manually full stroke exercised during cold shutdowns and refueling outages. ,

3. _ Category C valves V23-65, SSC-23-12, and V-23-32, injection mode valves, cannot be full stroke exercised during power operation since full HPCI flow adds significant heat to the suppressiol chamber and could exceed temperature limits.

The HPCI pcmp cannot be run during cold shutdowns since steam is no*. available. Approximately 150 psi of steam is required to "un a full flow test of the HPCI pump. These valves will be partial stroke exercised quarterly and full '

stroke exercised during planned cold shutdowns and refueling outages.

4. Category C valve V23-61, torus suction check valve, cannot be full stroke exercised during power operation since there is no full flow test loop available to recirculate the water back to the torus. There are no external means to manually ,

full stroke the valve. This valve cannot be stroked via a system injection into the reactor since that would result in a reactivity excursion and potentially thermally shocking  ;

the reactor nozzles. These valves will be verified to open freely each cold shutdown and refueling outage by removing

. the valve bonnent and manually stroking the valve disc.

D. Control Rod Drive

1. Category A/C valve V3-181, CRD return to RWCU system, (one valve for each of the 89 control rods) cannot be exercised ,

during power operation since this would require isolating and venting a portion of the CRD system. This would cause hydraulic instability throughout the system and is potentially unsafe until the system can be rebalanced and rod stroke re-timed. This cannot be done during power operation. These valves will be full stroke exercised during cold shutdowns and refueling outages.

E. Residual Heat Removal

1. Category A valves V10-17 and V10-18 RHR loop suctions, and .

V10-32 and V10-33 head spray isolations cannot be exercised '

during power operation since these valves are interlocked ,

shut when RCS pressure is greater than 100 psig to prevent overpressurizing a low pressure system. These valves are full stroke exercised during cold shutdowns and refueling outages.

l 35

2.

Category B valves V10-46A/B LPCI injection checks cannot be manually exercised during power operation since the valves are located inside the containment. Exercising these valves by system flow is not possible since pump discharge cannot overcome RCS power operating pressure. These valves will be full stroke exercised during cold shutdowns and refueling outages.

F. Reactor Core Isolation Coolir.g .

1. ,

Category A valves V13-15 and V13-16, and Category B valves V13-18, V13-20, V13-21 and V13-27, injection mode valves, cannot be exercised during power operation since repositioning these valves would render the RCIC system inoperable if the valve failed in the unconservative position. These valves will be full stroke exercised during cold shutdowns and refueling outages. ,

2. Category C valve V13-22, injection check valve, cannot be exercised during power operation since flow through this valve must be injected into the reactor coolant system.

This would thermally shock the reactor nozzles and cause a reactivity excursion. Manual valve operation is not .

possible during power operation since the valve is located in the steam tunnel which is not accessible. This valve will be manually full stroke exercised during cold shutdowns and refueling outages. -

3. Category'C valve V13-40, torus suction check valve, cannot be full stroke exercised during power operation since there .

is no full flow test loop available to recirculate the water back to the torus. There are no external means to manually full stroke the valve. This valve cannot be stroked via a .

system injection into the reactor since that would result in a reactivity excursion and potentially thermally shocking the reactor nozzles. These valves will be verified to open freely each cold shutdown and refueling outage by removing the valve bonnent and manually stroked the valve disc.

G. Primary Containment and Atmosphere Control 1.

Category A valves SB16-19-8, V16-20-20, V16-19-23, 1

SB16-19-6B, and SB16-20-22B, primary containment isolations, cannot be exercised during power operation since this would ,

cause a loss of the differential pressure between the drywell and the suppression chanber. This Dp is a required

  • condition for power operation. These valves are full stroke exercised during cold shutdowns and refueling outages.

l 36

H. HVAC - Reactor Building 1.

Category A valve SB16-19-6, primary containment isolation, cannot be exercised during power operation since this would cause a loss of the differential pressure between the drywell and the suppression chamber. This Dp is a required condition for power operation.

9 0

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VI. -Attachmen't III A.

Valves that are never full stroke exercised or that have a testing interval greater than each refueling outage:

1. RV2-71A-D 0

4 i e i

l 4

4 I

i-38 t

A VII. Attachment IV The P&ID's listed below were used during the course of this '

review.

System P&ID Rev.

Main Extraction, Auxiliary Steam G191150 Service Water 7 Cooling Water G191159-1,2 5 G191159-3 3 Recirculating Pump Cooling Water G191159-5 1 '

Service and Instrument Air G191160-1 13 Miscellaneous G191160-2 9 Nuclear Boiler G191162 8 Core Spray G191167 17 G191168 13 High Pressure Coolant Injection G191169-1 8 Control Rod Drive Hydraulic G191169-2 12 Standby Liquid Control G191170 10 G191171 9 Residual Heat Removal G191172 16 Fuel Pool Cooling and Cleanup G191173 Reactor Core Isolation Cooling 9 G191174-1 12 G191174-2 9 Primary Containment & Atmosphere Control G191175 23

  • Condensate and Demineralized Transfer G191176 9 Radwaste Reactor Water Cleanup G191177-1 11 HVAC Reactor Building G191178-1 12 G191238 11 Nuclear Boiler Vessel Instruments G191367 Containment Atmosphere Dilution 5 VY-E-75-002 2 4

i 6

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_ - .

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