ML19331D127

Safety Evaluation of Inservice Testing Program for Pumps & Valves, Interim Rept for Aug 1979 to Apr 1981

ML19331D127
Person / Time
Site:	Farley
Issue date:	07/31/1980
From:	Fehringer J, Rockhold H EG&G, INC.
To:	Nerses V Office of Nuclear Reactor Regulation
References
CON-FIN-A-6258 EGG-EA-5208, NUDOCS 8008270336
Download: ML19331D127 (98)

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INTERIM REPORT 4

Accession No.

Report No.

EGG-EA-5208 Crntract Program or Project

Title:

Systems Engineering Support Subject of this Document:

Safety Evaluation of the Inservice Testing Program for Pumps and Valves at the Joseph M. Farley Nuclear Plant (Docket No. 50-348) for the Period August 1,1979, through April 30, 1981 Type of Document:

Safety Evaluation Report Author (s):

J. M. Fehringer H. C. Rockhold D:te of Document:

July 1980 R:sponsible NRC Individual and NRC Office or Division:

Victor Nerses, NRC-DE This doc: ment was prepared primarily for preliminary orinternal use. it has not received full review and approval. Since there may be substantive changes, this document should not be considered final.

EG&G ldaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the

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

Under DOE Contract No. DE-AC07 761D01570 NRC FIN No.

A6258 INTERIM REPORT ik$

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TABLE OF CONTENTS T s Page I.

Introduction............................................

1 II.

Pump Testing Program....................................

2 III.

Valve Testing Program...................................

30 IV.

Attachment I...........................................

86 V.

Attachment II...........

93 VI.

A t t a c hme n t I I I..........................................

95 e

i i

i I

I

I.

Introduction Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Alabama Power Company on 1 May 1979 for its Joseph M. Farley nuclear plant. The program applies to Joseph M. Farley for the period 1 August 1979 through 30 April 1981. The working ses,sion with Alabama Power and Joseph M.

Farley representatives was conducted on September 26 and 27, 1979.

The licensee re-submittal was issued on 16 November 1979 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 Pressure vessel Code,Section XI, 1974 Edition, through the Summer of 1975 Addenda. Alabama Power Company 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 Section II and III are the recommendations of EG&G Idaho, Inc.

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

^*tachment I.

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

Valves that are never full stroke exercised or that have a testing interval greater than each refueling outage and relief reauests with insufficient technical basis where relief is not recommended are summarized in Attachment III.

1

II. Pump Testing Program The IST program submitted by Alabama Power Company was examined to verify that Class 1, 2, and 3 safety related pungs were included in the program and that those pumps are subjected to tha periodic tests as required by the ASME Code,Section XI. Our review found that all 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 frecuency of testing comply with the code. Each Alabama Power Company reauest for relief from testing pumps, the code reauirement for tesing, the basis for reauesting relief, and the EG&G evaluation of that request.is summarized below and grouped according to the system in which the pumps reside:

A.

Charging (HHSI) System

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l.

Relief Reauest Tne licensee has requested specific relief from measuring vibration amplitude (V), lubricant level or pressure, and differential pressure (dP) for the Charging (HHSI) pumps P002A, B, and C in accordance with the requirements of Section XI and proposed to run pumps monthly and measure inlet and outlet pressure.

In addition, V, dP, and lubricant level or pressure will-be measured quarterly.

Bearing temperature will be measured annually.

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 tne i

measurement, observation, and recording of all cuantities in Table IWP-3100-1, except bearing temperature, wnich shall be measured during at least one inservice test each year.

2

Licensee's Basis for Reauesting Relief The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable'of performing their safety function. A monthly test provides such assurance; however, mnathly testing also requires additional run times and unusual operation of the eauipment necessary to drive the pump and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day per iod. Of the approximately 24 monthly tests previousiy conducted on each of the pumps in the Farley Unit No. I program, adequate assurance of operability is provided in as few as eight 3-month tests. In addition, extensive investigation has.

been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test freauency. The investigation has resulted in a proposed revision to the code which would reauire a pump test freauency of nominally once every 3 months.

The pumps will be tested and the required parameters measured nominally once every three (3) months.

If deviations fall within the " alert range" of Table IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set established per IWP-3111.

3

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent other undesirable occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-1.

Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and parameters measured in accordance with the Quarterly test interval indicated in Table P-1.

Any furtner corrective action will result from the Quarterly test parameters.

1 In order to comply with this test requirement for the Charging /HHSI pump dP, the pumps must be aligned to their fixed resistance recirculation flow path. This alignment to the test configuration requires that normal charging and RCP seal water requirements must be provided from a pump in.the other train and isolation of the pump train to be tested.

The pump now providing normal charging and seal water must be provided with its cooling water from the appropriate train source which may cause realignment in that system and its support systems. The pump now aligned in the test configuration is not available for charging or HHSI.

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In addition, the normal charging and seal supply configuration is not considered fixed resistance and adequate flow instrumentation is not provided.

4

A test parameter of dP will be determined while the pumps are operating, either normally or in accordance with the alternate testing specified in paragraph 2.1.1.2, in their

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normal operating configuration providing charging and RCP

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seal reauirements. The acceptable limit for each pump's dP j

will be equivalent to 93% of the manufacturer's curve at a maximum charging and recirculation flow of 180 GPM (dP > 2315 psi). Inability to meet this criterion will result in corrective action as provided in paragraph 2.1.1.2.

Tne dP parameter will be measured, compared, and analyzed in accordance with code nominally once every 3 months.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for charging (HHSI) pumps P002A, B, and C from the testing requirements of Section XI. The i

licensee has demonstrated through previously conducted testing that the proposed alternate testing frequency is sufficient to determine any pump degradation (the intent of Section XI). In addition, the establishment of two reference values for these pumps will provide the required degradation information whether the pump is lined up to the normal charging flow path or the recirculation flow path.

We conclude that the licensee's proposal of running pumps monthly to measure Pi and Po to ensure no pump degradation and of measuring all parameters cuarterly and bearing temperature yearly, meets the intent of the Section XI testing requirements.

8.

Residual Heat Removal (RHR) System l.

Relief Reauest The licensee has requested specific relief from measuring vibration amplitude (V) and lubricant level or pressure for 5

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RHR pumps P001A and B from the testing requirements of Section XI and proposed to measure these parameters quarterly.

Inlet pressure Pi, outlet pressure Po, differential pressure dP, and flow rate Q will be measured monthly and bearing temperature will be measured yearly.

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 Reauesting Relief The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides such assurance; however, monthly testing also requires additional run times and unusual operation of the equipment necessary to drive the pump and to align the system for the test. A penalty for increased usage and run t me is increased equipment degradation and possible f ailure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service

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lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. Of the

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approximately 24 monthly tests previously conducted on each of the pumps in the Farley Unit No.1 program, adequate assurance of operability is provided in as few as eight 3-month tests. In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for 6

1 1

inservice testing of pumps and valves concerning the optimization of the test frequency. T'he investigation has resulted in a proposed revision to the code which would require a pump test frequency of nominally once every 3 months.

The pumps will be tested and the required parameters measured nominally once every tnree (3) montns.

If deviations f all within the " alert range" of Table IWP-3100-2, tne frequency of testing snall be increased to montnly until the cause of the deviation is determined and corrected and either the, existing reference values reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent other undesirable occurrences. The test will reauire the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate.

In cases of multiple pump operation within a system or train of 3 system, a. system or train parameter will be measured and used to verify that the pumps are operating su'ficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-1.

Any pumps wnose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and parameters measured in accordance with the quarterly f'

test interval indicated in Table P-l.

Any further corrective action will result from the quarterly test parameters.

In order to satis'fy the test requirement for dP, each pump must be aligned to a fixed resistance recirculation flow path. In the event the system is providing reactor Coolant 7

L____________-___________-__-__-_____-____-__-_-_____-________-_-____-___--_-____-___-_-___-_-_______-__-_--_--_--_______,

flow or is aligned to do so, eacn of the pumps must be realigned for the test while the other pump is realigned to satisfy reactor coolant flow requirements. 'The test configuration also requires the train to be isolated from the RCS and aligned to the RWST. This test configuration jeopardizes the overpressurization protection requirements outlined in the Technical Specifications.

Test parameters will be measured and acceptability.

determined 'n accordance with the following:

Pump Parameter Acceptance Criteria Test RCS Function Measured Criteria Basis (1)

Power Operation or ECCS dP, each Per Test Code 1

j Pressure >450 psig pump Requirement (2.1.11)

(2)'

Pressure <450 psig

'ligned to dP, each

>l26.5 psid 0.934 Pc*

i and/or temperature 7CS for RHR pump Qc*=3000

>310*F,RCPump(s)

GPM Operating.

(3)

Pressure <450 psig Reactor Q, each

>3000 GPM Tech. Spec.

and/or. temperature Coolant Flow pump

>310*F, RC Pump Not Operating.

l Where Qc and dPc.are points on the mfg. curve.

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Inability 20 meet these criteria will result in corrective-action as provided in paragraph 2.1.1.2.

The alternate tests (2) or -(3) will not be conducted coincidently with the quarterly recuirements of Table P-1 and paragragh 2.1.1.2.

In.the event the cuarterly requirements of Table P-1'and

. Test (1)'are required when the RCS condition is as specified in tests (2) or (3), tests (2) or (3) will be conducted in lieu of the quarterly requirements. The Quarterly Test Parameters and the test (11 parameter will then be measured, compared, and enalyzed in accordance with the test requirement (2.1.11) within one (1) week after the plant is returned to normal operation.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for RHR pumps P001A and B from the testing requirements of Section XI. The licensee nas demonstrated through previously Conducted testing that the proposed alternate testing frequency is sufficient to determine any pump degradation. We conclude that the proposal of running pumps monthly to measure Pi, Po, dP, and Q to ensure pum, degradation has not occurred, and to measuring all parameters cuarterly, and bearing temperature yearly meets tha intent of'the Section XI testing requirements. Also, we agree that the proposed operating and acceptability criteria meets the intent of tne Section XI requirements.

I i

C.

Component Cooling Water (CCW) System l.

Relief Request 1,

The licensee nas requested specific relief from measuring i

inlet pressure Pi, outlet pressure Po, differential pressure dP, vibration amplitude V, and lubricant level or pressure, 9

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for Component Cooling water pumps P001A, B, and C from tne testing recuirements of Section XI and proposed to run these pumos monthly and neasure flowrate Q to 1etermine pump degradation. In addition, Pi, Po, dP, Q, V, and lubricant level or pressure will be measured cuarterly and bearing temperature will be measured yearly.

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 cuantities in Table IWP-3100-1, except bearing teeperature, which shall be measured during at least one inservice test each year.

Licensee's Basis for Recuesting Relief The intent of imposing the pump testing progran is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides such assurance; however, monthly testing also recuires additional run times and unusual operation of the eauipment necessary to drive the pumo and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would provide assurance of pu p operability and have the least impact on the normal

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degradation of equipment expected over its service lifetime. Operating experience nas. indicated that pum s l

will not degrade over a single 30-day period. Of tne

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approximately 24 monthly tests previously conducted on each of the pumps in the Farley Unit No.1 program, adequate 10 l

assurance of operability is provided in as few as eight 3-month tests.

In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test frequency. The investigation has resulted in a proposed revision to the code which would require a pump test frequency of nominally once every three (3) months.

The pumps will be tested and the required parameters-measured nominally once every three (3) months.

If deviations f all within the ' alert range" of Table IWP-3100-2, the frecuency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of.-the pump bearings and to prevent other undesirable occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in.which they operate.

In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system reauirements. The parameters to be measured monthly are indicated in Table P-1.

Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> e

and parameters measured in accordance with the cuarterly test interval indicated in Table P-l.

Any further c

corrective action will result from the Quarterly test parameters.

11

The flow measuring devices for the Component Cooling Water System are located downstream of the CCW heat exchangers and are neither designed nor strategically located to provide flow indication within sufficient accuracy to accommodate the test requirement. As a result, CCW pump dP must be measured while the pumps are aligned in a fixed resistance recirculation flow path in order to satisfy the test requirement. This alignment to the test configuration requires that each pump be manually isolated from its normal flow path each month. CCW system requirements must be met by the other CCW pumps which may cause train supply switchover for certain systems such as RHR or Charging.

This alignment to a test configuration on a monthly frequency reduces pump availability and is contrary to justification for quarterly testing provided in paragraph 2.1.1.1.

A test parameter of flow (Q) will be measured while the pumps are operating, either normally or in accordance with the alternate testing specified in paragraph 2.1.1.2, in their normal operating configuration. Due to variable resistance in the system and the accuracy of the flow measurement, the flow parameter will be required to meet or exceed a heat exchanger discharge flow corresponding to hot shutdown loads (Q > 6400 GPM). Inability to meet this criterion will result in corrective action as provided in paragraph 1.1.12.

Tnis alternate test will not be conducted coincidently witn the quarterly requirements of Table P-1 1

i and paragraph 2.1.1.2.

Evaluation l

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

relief should be granted for Component Cooling Water pumps 12

P001A, B, and C from the testing requirements of Section XI. The licensee has dem,onstrated through previously conducted testing the proposed alternate testing frequency should determine any pump degradation. We conclude that the proposal to run pumps montbly and measure Q to ensure no pump degradation and to meastre all parameters cuarterly and measure bearing ter.;perature yearly meets the intent of the Section XI testing requirements.

D.

Service Water (SW) System 1.

Relief Reauest The licensee has requested specific relief from measuring inlet pressure Pi, outlet pressure Po, differential pressure dP, vibration amplitude V, flowrate Q, and lubricant level or pressure for Service Water Pumps-P001A-E from the testing requirements of Section XI and proposed to measure these parameters quarterly and measure bearing temperature yearly.

~ Code Reauirement An inservice test shall be conducted on all safety related pumps, nominally once each month during normal plant operation. Each inservice test snall include tne 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 Reauesting Relief P

The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of 13

performing their safety function. A monthly test provides such assurance; however, monthly testing also requires additional run times and unusual operation of the equipment j

necessary to drive the pump and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. Of the approximately 24 monthly tests previously conducted on each of the pumps in the Farley Unit No. I program, adequate assurance of operability is provided in as few as eight 3-month tests.

In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test frequency. The investigation has resulted in a proposed revision to the code which would require a pump test frequency of nominally once every 3 months.

The pumps will be tested and the required parameters measured nominally once every three (3) months. If deviations fall within the " alert range" of Table IWP-3100-2, the frecuency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent other undesirable occurrences. The test will require the pumps to be run in either their test or norral s.

14 1

operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they

~

operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-1.

Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and parameters measured in accordance with the Quarterly test interval indicated in Table P-1.

Any further.

corrective action will result from the quarterly test parameters.

The service water pumps are of vertical design with no means of direct inlet pressure measurement as required by IWP-4200.

Indirect inlet pressure measurement will be obtained utilizing service water structure wet pit station level instrumentation. The level is then converted to pump inlet pressure by the following calculation:

Inlet Pressure = Wet m Level W.) - 52.5 n.

2.3066 ft/psig l

Due to the demands of dependent systems, the individual f

testing of service water pumps as required by IWP-3400 would jeopardize safe plant operation and be impossible to l

accomplish during plant shutdown.

1-Tests involving combinations of two pumps within each train l

indicate the hydraulic condition of the pumping system. The combinations are arranged such that each pump is included in e

at least one combination test in each train. The initial i

15

tests are run on all combinations in each train including the swing pump to provide base line data for any subsequent tests.

In the event of a detection of hydraulic change by a test, the test results are applied to both pumps in the combination. Each of the pumps is then tested in combination with another appropriate pump to assess the individual pump operational readiness.

As indicated in paragraph 2.1.3.1, the service water pumps cannot be individually tested. The pumps must be tested quarterly by train [two (2) pumps] as a variable resistance system. This is accomplished by throttling the flow to a repeatable quantity and measuring the dP. The monthly measurement of a single hydraulic parameter, as allowed in paragraph 2.1.1.2 and comparison per the test requirement, is meaningless since either flow (Q) or differential pressure (dP) is readily attainable regardless of pump operability. The monthly measurement of both hydraulic parameters imposes extended abnormal operating conditions on the pumps and system in order to attain the repeatable values and defeats the purpose implementing quarterly tests as provided in paragraph 2.1.1.1.

A test parameter of flow (Q) will be measured for each train

[two(2)pumpsoperatingineachtrain]. The swing pump will be operated with either of the pumps in the train to which it is aligned and flow will be measured for the train. The pumps will be operationally acceptable if the test flow meets or exceeds a cuantity equivalent to the cold shutdown requirements for that system train (Q > 15,200 GPM).

Inability to meet these criteria will result in corrective action as provided in paragraph 2.1.1.2.

The flow parameter will be measured, compared, and l

analyzed in accordance with the Code nominally once every 3 months.

l 16 T'

Evaluation

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

. relief snould be granted for Service Water Pumps P001A-E from the testing requirements of Section XI. The licensee has demonstrated that through previously conducted testing the proposed alternate testing frequency is sufficient to determine any pump degradation. Due to present piping configurations, installed instrumentation, and system flow requirements, we agree tnat the service water pumps can only be tested using two pumps in parallel instead of tadividually as required by Section XI. We conclude that since these pumps are. running continously during power operation performing their required safety function that measuring Pi, Po, dP, Q, V, and lubricant level or pressure quarterly, and bearing temperature yearly is sufficient to ensure no pump degradation and does meet the-intent of the Section XI testing reauirements.

E.

Auxiliary Feedwater 1.

Relief Reauest The licensee has requested specific relief from measu-ing vibration amplitude V, and lubrient level or pressure for the motor driven Auxiliary Feed Pum;s P001A & B in accordance with the requirements of Section XI and proposed to measure inlet pressure Pi, outlet pressure Po, and differential pressure dP monthly, and measure V and lubricant' level or pressure qua terly. Bearing temperature r

will be measured annually.

l l

17 L

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 l'#-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.

Licensee's Basis for Reauesting Relief The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides such assurance; however, monthly testing also requires additional run times and unusual operation of the equipment necessary to drive the pump and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. Of the approximately 24 monthly tests previously conducted on each of the pumps in the Farley Unit No.1 program, adequate assurance of operability is provided in as few as eight 3-month tests.

In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test frequency. The investigation has resulted in a proposed revision to the code which would require a pump test frequency of nominally once every 3 months.

18 t

The pumps will be tested and the recuired parameters measured nominally once every three (3) montns. If deviations fall within the " alert range" of Table IWP-3100-2, the frecuency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference valu's reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent other undesirable occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate.

In cases of multiple pump operation within a system or train of~a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system recuirements. The oarameters to be measured monthly are indicated in Table P-1.

Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and parameters measured in accordance with the Quarterly test interval indicated in Table P-1.

Any further corrective action will result from the Quarterly test I

parameters.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be grante.3 for the motor driven Auxiliary Feed Pumps P001A-A & B from the testing requirements of Section XI. The licensee has demonstrated through previously conducted testing that the proposed alternate 19

testing frecuency is sufficient to determine any pump degradation. We conclude that running pumps monthly to measure Pi, Po, and dP to ensure pump degradation has not occurred and to measure all parameters cuarterly and bearing temperature yearly meets the intent of the Section XI testing recuiremer.ts.

2.

Relief Recuest The licensee has requested specific relief from measuring differential pressure dP, flowrate Q, vibration amplitude V, lubricant level or pressure, and speed for the turbine

' driven Auxiliary Feed pump P002 in accordance with the reouirements of Secticn XI and proposed to measure inlet pressure Pi, outlet pressure Po, (dP and Q with more limiting recuired action ranges) monthly, and V, lubricant level or pressure and speed cuarterly. Bearing tem erature will be measured annually.

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

Licensee's Basis for Requestino Relief The intent of imposing the pump testing prograti is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of

~

performing their safety function. A monthly test provides 20

sucn assurance; however, monthly testing also requires additional run times and unusual operation of the equipment necessary to drive the pump and to align the system for the

~

test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. Of the approximately 24 monthly tests previously conducted on each of the pumps in the Farley Unit No.1 program, adequate assurance of operability is provided in as few as eight 3-month tests. In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test freauency. The investigation has resulted in a proposed revision to the code which would require a pump test freauency of nominally once every 3 montns.

The pumps will be tested and the required parameters measured nominally once every three (3) months.

If deviations fall within the " alert range" of Table IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is determined and l

corrected and either the existing reference values l

reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent other undesirable occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a l:

21 l

single nydraulic parameter to be measured to detect any gross degradation of tne pumps or the system in which tney operate.

In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that tne pumps are operating sufficiently to satisfy system requirements. Tne parameters to oe measured monthly are indicated in Table P-1.

Any pumps whose "lasured parameters indicate unsatisfactory perfor.nce will be retested witnin 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and parameters measured in accordance with the cuarterly test interval indicated in Table P-1.

Any further corrective action will result from the cuarterly test parameters.

The plant Tecnnical Specifications recuire that the pumps be tested at least once per 31 days by verifying that the puco develops a differential pressure of at least 93% for the applicable flow rate as determined from the manuf acturer's pump performance curve when the secondary steam supply pressure is greater than 90 psig. A test in accordance witn the Code recuires a different nydraulic test circuit tnan tne Tecnnical Specification test in order to obtain a fixed resistance recirculation flow path because the flow device used in the Tech. Spec. test is not designed for tne accuracy limitations of the Code. As a result, tests performed monthly and quarterly as described in paragraph 2.1.1 would recuire two (2) separate tests witn two (2) separate system alignments and an increased test duration.

The monthly test required by the Tech. Spec. acconolishes the same purpose as the Code test with a nore conservative allowable range for test cuantities in the recuired action range. For example:

22

i Code Tech. Spec.

l Reg'd. Action if APc0.90 Pr or> 1.03A Pr aPc0.93 APc*

Rea'd Action if.

Q<0.90 Qr or >l.03 - Qr Q 7 Qc*

Where Qc and dPc are points oj1 the mfa. curve.

Evaluation i

i We agree with the licensee's basis, and therefore feel that relief should be granted for the turbine driven Auxiliary Feed pump P002 from the testing requirements of Section XI.

The licensee has demonstrated through previously conducted testing that the proposed alternate testing frecuency is sufficient to determine any pump degradation. We conclude that the proposal of running pumps monthly to measure Pi, Po, dP, and Q to ensure pump degradation has not occurred and to measure all parameters quarterly and bearing temperature yearly meets the intent of the Section XI testing requirements. Also, we agree that the proposed dP and Q re' quired action ranges are more restrictive than the Section XI requirements, thus the code intent is met.

F.

Containment Spray a

Relief Request i

The licensee has reauested specific relief from measuring vibration amplitude V, and lubricant level or pressure for the Containment Spray pumps P001A-A & B in accordance with the requirements of Section XI and proposed to measure inlet pressure.

l Pi, outlet pressure Po, and differential pressure monthly, and measure V and lubricant level or pressure quarterly. Bearing temperature will be measured annually.

23

,rrr.

-m

,,-,y-w--m.

w

,,.-ry,.

,,n.,,

m

.me,

+..

- -, - - - ~, = -

, ~

.-rw.

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 it.clude 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 intent of imposing the pump testing program is to provide assurance cf an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides such assurance; however, monthly testing also requires additional run times and unusual operation of the eouipment necessary to drive the pump and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would~ provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime.

Operating experience has indicated that pumps will not degrade over a single 30-day period. Of the approximately 24 montnly tests previously conducted on each of the pumps in the Farley Unit No.1 program, adequate assurance of operability is provided in as few as eight 3-month tests.

In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the

~

optimization of the test frequency. The investigation has resulted in a proposed revision to the code which would require a pump test frequency of nominally once every 3 months.

24

The pumps will be tested and the required parameters measured nominally once every three (3) months.

If deviations fall within the " alert range" of Table IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set establishen per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and'to prevent other undesirable occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate.

In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used.to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-1.

Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and parameters measured in accordance with the quarterly test interval indicated in Table P-1.

Any further corrective-action will result from the quarterly test parameters.

Evaluation We agree with the licensee's basis, and therefore feel that relief should he granted for the Containment Spray pumps P001A-A & B from the testing requirements of Section XI. The licensee has demonstrated through previously conducted testing that the proposed alternate testing frequency is sufficient to determine pump degradation has not occurred. We conclude that the proposal to measure Pi, Po, and dP monthly, and to measure all parameters quarterly and bearing temperature yearly meets the intent of the Section XI testing requirements to demonstrate pump operability.

25

m.

G.

~ River Water Relief Request j

The licensee has requested specific relief from measuring inlet pressure Pi, outlet pressure Po, differential pressure dP, vibration amplitude V, and lubricant level or pressure for the River Water pumps P004-B, P005-B, P008-A, P009-A, and P010-A in accordance with the requirements of Section XI and proposed to measure Po monthly, and Pi, dP, V, and lubricant level or pressure quarterly. Bearing temperature will be measured annually.

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 cuantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.

1 Licensee's Basis for Requesting Relief The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety function.. A monthly test provides such assurance; however, i

nonthly testing also requires additional run times and unusual I

~

]

-operation of the equipment necessary to drive the pump and to align the system for the test. A penalty for increased urage and run time,

increased equipment degradation and possible t.

failure. An ortimized testing program would provide assurance of pump operability and have-the least impact on the normal

+

26

degradation of eruipment expected over its service lifetine.

Operating experience has indicated that pumps will not degrade over a single 30-day period. Of the approximately 2'4 monthly tests previously conducted on each of the pumps in the Farley Unit No. I program, adequate assurance of operability is provided in as few as eight 3-month tests. In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test frecuency. The investigation has resulted in a proposed revision to the code which would require a pump test frequency of nominally once every 3 months.

The pumps will be tested and the required parameters measured nominally once every three (3) months.

If deviations fall within the " alert range" of Table IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent other undesirable occurrences. Thc test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate.

In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly aie indicated in Table P-1.

Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> and parameters measured in accordance with the quarterly test interval indicated in Table P-1.

Any further corrective action will result from the quarterly test parameters.

27

The river water pumps are of vertical design with no means of direct inlet pressure measurement as required by IWP-4200.

Indirect inlet pressure measurement will be obtained by using river water structure wet pit station level instrumentation. The level is then converted to pump inlet pressure by the following calculation:

Inlet Pressure = Wet Pit Level (f t.) - 62.5 f t.

2.3066 ft/psig Due to a continuously fluctuating river level and the fixed resistance associated with the system, the determination of readily duplicated points of operation as required by IWP-3110 is not possible.

Each pump's test results are maintained as reference values.

When subsequent results provide an inlet pressure within +2% of a previous test inlet pressure, the tests are compared and an assessment of the pump hydraulic condition is made.

Since discharge pressure instrumentation is provided for each train, single pump tests are required in order to satisfy the test requirement for dP. Starting and stopping of individual pumps and aligning the system into a test configuration for testing on a monthly basis defeats the intent and purpose of quarterly testing provided in paragragh 2.1.1.

A test parameter of discharge pressure (Po) will be measured for each train with two (2) pumps operating and providing normal pond supply. All pumps will be operated with another pump in that particular train. Tne pumps will be operationally acceptable if

^

the test discharge pressure (Po) meets or exceeds a quantity corresponding to a dP for the system at minimum river level with two (2) pump flow. Inability to meet these criteria will result 28

in corrective action as provided in paragraph 2.1.1.2.

This

• alternate test will slot be conducted coincidentally with tne quarterly requirements of Table P-1 and paragragh 2.1.1.2.

Evaluation We agree with the licensee's basis, and therefore feel that relief should he granted for the River Water pumps P004-B, P005-B, P008-A, P009-A, and P010-A from the testing requirements of Section XI. The licensee has demonstrated through previously conducted testing that the proposed alternate testing methods and frequency is sufficient to determine any pump degradation. We conclude that calculating Pi, measuring Po with 2 parallel pumps, running pumps monthly for Po measurements to ensure pump Jegradation has not occurred, and measuring all parameters quarterly and bearing temperature yearly meets the intent of the Section XI testing requirements.

o 9

e o

29

III. Valve Testing Program Evaluation The IST program submitted by Alabama Power Company was examined to verify that all 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 all Class I, 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 frecuency 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 are the NRC position and valve listings for the leak testing of valves that perform a pressure isolation function and a procedure for the licensee's use to incorporate these valves into the IST program. Each Alabama Power Company request for relief from testing valves, the code requirement for testing, Alabama Power Company basis for requesting relief, and the EG&G evaluation of that reauest is summarized (B through Q) below and grouped according to each specific system.

A.

General Considerations 1.

Testing of Valves which Perform pressure Isolation Function There are several safety systems connected to the reactor coolant pressure boundary that have design pressures that are belou the reactor coolant system operating pressure.

There are redundant isolation valves forming the interface between these high and low pressure systems to prevent tne

~

inw pressure systems from being subjected to pressures which exceed their design limit.

In this role, the valves are performing a pressure isolation function.

i

~

i 30 j

It is the NRC view that the redundant isolation provided by these valves regarding their pressure isolation is important. The NRC considers it necessary to provide

~

assurance that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For this reason tne NRC believes that some method, such as pressure monitoring, radiography, ultrasonic testing, leak testing, etc. could be used to ensure that the condition of each valve is satisfactory to maintain this pressure isolation function.

In the event the leak testing is selected as the appropriate method for achieving this objective, EG&G 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:

8998A, B, & C 8973A, B, & C 8993A & B 8988A & B 8997A, B, & C 8995A, B, & C We have discussed this matter and identified the valves listed above to the licensee. The licensee has agreed to consider testing each of these valves and to categorize these valves with the appropriate designation depending on the testing method selected. Whatever the licensee selects as the testing method to be used to determine 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.

31

2.

ASME Code Section XI Reauirements Subsection IW-3410(a) of the Section XI Code (which discusses full stroke and partial stroke) requires that Code Category A and B valves be exercised once every three months, with the exceptions as defined in IW-3410(b-1),

(e), and (f).

IW-3520(a) requires that Code Category C valves be exercised once every three months, with the exceptions as defined in IW-3520(b). IW-3700 requires no regular testing for Code Category E valves. Operational checks, with appropriate record entries, shall record the position of these valves before opera'. ions are performed 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 witt IWV-3410(c). In the above exceptions, the code permits the valves to be tested'at cold shutdown where:

a.

It is not practical to exercise the valves to the position reautred to fulfill their function or to the partial position during power operation.

b.

It is not practical to observe the operation of the valves (with f ail-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 licensee and agreed to by the staff), the check valve shall be partial stroked. Since disc position is not always observable, the NRC staff stated 32

that verification 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 disc 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 tests 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 received the valve most 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.

Cold Shutdown Testing a.

Inservice valve testing at cold shutdown is defined as: 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 shutdwn should be performed during the subsequent cold shutdowns to meet the code required testing frequency.

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

33

b.

~ The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three mor.ths for Category A and B valves and once every nine months for Category C valves. It is the NRC 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, 8, and C valves."

4.

Changes to the Technical Specifications In a November 1976 letter to the licensee, the NRC provided an attachment entitled "NRC 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 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 operaton in some plants, there are stated minimum requirements for systems which allow certain limiting conditions for oparation to exist at any one time and if the system is not restored to meet the requirements within the time period specified in a plant's Technical Specifications (T.S.), the reactor is required to be put in 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 could be contrary to the NRC guideline as stated in the document mentioned above.

34

The licensee has agreed to review the plant's T.S. and to consider the need to propose T.S. changes which would have the effect of precluding such testing.

After making this review, if the licensee determines that the T.S. should be changed because the guidelines are applicable, the licensee will submit to the NRC, in conjunction with the proposed T.S. change, the.

inoperable condition for each system that is affected which demonstrates that the valve's failure would cause a loss of system function or if the licensee determines

~

that the T.S. should not be changed because the guidelines are not applicable'or cannot be followed, the licensee will submit the reasons that led to their determination for each potentially affected section of the T.S.

5.

Safety Related Valves a

This review was limited to sa'aty-related valves.

Safety-related valves are deffned as those valves that are needed to mitigate the consequences of an accident and/or to shut down the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2 and 3 valves and could include some non-code I

Class valves.

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

35

6.

For those valves that are impractical to test quarterly, the licensee has proposed to test them at cold shutdowns or refueling outages.

In NRC and EG&G discussions with the licensee (September 26'and 27, 1979) 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 SER.

B.

Reactor Coolant j

1.

Category A and A/C Valves a.

Relief Request The licensee has requested specific relief from exercising Category A valves V026A & B, pressurizer pressure transmitter to dead weight pressure generator i

isolations, in accordance with the requirements of Seciton XI.

t l

Code Reauirement 1

i Refer to valve testing paragraph A.2.

Licensee's Basis for Reauesting Relief The operability testing (full or partial stroke) during normal operation or' cold shutdown provides no assurance of an increase in safety. These' valves are containment

[..

isolation valves which are normally closed and passive.

i 36

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A valves V026A &

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 requesteJ specific relief from exercising Category A/C valves, V038 reactor make-up water to pressurizer relief tank check, and V054 charging pump relief valve line check, in accordance with the requirements of Section TI and proposed to verify valve closure during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Due to plant design it is not practical to verify by any positive means, either directly or indirectly, the operability of these normally open check valves per the requirements of IWV-3520. Valve closure will be verified during the-performance of the valve leak-rate 37

test which shall be conducted at the same frequency as reactor refueling outages per the plant Tecnical Specifications.

Evaluation We agree with the licensee's basis, and therefore feel that relief.should be granted for Category A/C valves V038 and V054 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify vulve closure (their safety related position) is during leak testing. These' valves are not equiped with valve position indicators and test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

C.

Residual Heat Removal / Low Head Safety Injection 1.

Category A and A/C Valves a.

Relief Reauest The licensee has reauested specific relief from performing leak rate testing and valve position indicator checks for Category A valves V025A & B, RHR pump (LHSI) suctions from conta'nment sump, in

[

accordance with the requirements of Section XI and proposed to leak test these valves by applying a pressure between the primary and secondary isolations.

38

Code Reauirement Refer to valve testing paragraph A.2.

Licensee's Basis for Reauesting Relief These valves provide primary isolation for containment-sump penetrations with no provisions for leak rate testing with the differential pressure in the same direction as applied when the valves are performing their function as required by IWV-3420(c).

Leak riite testing will be performed by applying the differential pressure between the primary and secondary isolation valves.

Remote position indicators will be used to verify valve position per IWV-3300. However, visual observation of valve operation is not practical. Such observation would require removal of the valve protective chamber which is also considered to be a portion of the containment pressure boundary. Since the valve is provided with redundant indicators, position is accurately reflected by the remote indications.

The leak rate test during each refueling outage will verify that the remote position indicators accurately

~

reflect the closed position of the valves. No practical means exist to verify the open position of the valves. However, following each leak-rate test the air pressure will be relieved by opening these valves, thus verifying that the disk moves away from the seat.

e 39

- - - ~

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A valves V025A and B from the leak testing requirements of Section XI. The licensee has demonstrated that with the present piping configurations these valves can only be leak tested by applying a' pressure between the valves. We conclude that this method of leak testing should verify the leak tight integrity of these valves. However, we do not agree with the licensee's basis for not checking valve position indicators in accordance with the requirements of Section XI. These valves have a dual safety function, to be full open and permit LHSI pump recirculation and to shut for containment isolation. We conclude that the valve

~

position indicators must be checked to verify these valves are fully open and fully shut and that 'he proposed test method does not verify this.

b.

Relief Reauest The licensee has requested specific-relief from' exercising Category A/C. valves V021A, B, and C, RHR pump discharge to cold leg safety injection checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

Code Requirement 4

Refer to valve testing paragraph A.2.

40

Licensee's Basis for Requesting Relief The operability testing of these normally closed check valves per IWV-3520 reauires flow verification under LHSI into each RCS loop. These valves cannot be exercised during power operation because the LHSI/RHR pumps cannot overcome RCS pressure. During cold shutdown, these valves cannot be full stroke exercised because design flow cannot be verified through the valve unless all intitial test conditions can be met (i.e., suction from RWST through both pumps to the RCS with the RCS at atmospheric pressure).

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valves V02A, B and C from the exercising requirements of Section XI. The licensee has demonstrated that RHR/LHSI pump discharge pressure cannot overcome RCS operating pressure to establish flow and exercise these valves. Also during cold shutdown,. specific initial conditions must be met to permit full flow / full stroke-exercising. The vessel head must be removed, to place the RCS at atmospheric pressure and provide an adeauate expansion volume to accomodate full LHSI flow. We conclude that the proposed alternate testing frequency of full stroke exercising the valves during refueling outages should verify proper valve operability.

c.

Relief Request The licensee has requested specific relief from exercising Category A/C valves V051A, B, and C, boron 41

injection to RCS cold leg checks, in accordance with the requirements 07 Section XI and proposed to full stroke exercise these valves during refueling outages.

Code Reauirement Refer to velve testing paragraph A.2.

Licensee's Basis for Requesting Relief The operability testing of these normally closed check valves per IWV-3520 reauires flow verification under f

HHSI or LHSI into each RCS loop. This flow verification cannot be accomplished during normal operation or cold shutdown. During normal operation with the Reactor Coolant System at operating-pressure, these valves cannot be full stroke exercised because the HHSI pumps cannot provide-design flow and the LHSI pumps cannot provide any flow. During normal operation, partial-stroke exercising these valves with the HHSI pumps would induce undesired thermal shock to the safety injection nozzles.

During cold shutdown, design flow (full stroke exercising) cannot be verified because the Reactor Coolant System is pressurized.

The valve will be verified as operable by comparing HHSI flow through the BIT to the sum of the established individual reactor loop injection flows. The valve

~

test will coincide with the testing of the HHSI system via the BIT at each refueling cutage.

42

Evaluation We agree witit the licensee's basis, and therefore feel relief should be granted for Category A/C valves V051A, B, & C from the exercising requirements of Section XI.

The licensee has demonstrated that these valves cannot be exercised during power operation because the LHSI cannot overcome RCS pressure and partial stroking with the HHSI would result in thermal shock and damage to.

the injection nozzles. These valves cannot be exercised during cold shutdowns because the flow required for full stroke exercising could result in a low temperature overpressurization of the RCS. During refueling outages with the vessel head removed to provide an adequate expansion volume and with tne RCS-at atmospheric pressure full design flow / full Stroke

+

exercising can be accomplished. We conclude that the proposed alternate testing frequency to full stroke exercise the valves during refueling outages should demonstrate proper valve operability.

2.

Category B Valves a.

Relief Request The licensee has reauested specific relief from stroke timing Category R valves V032A and B, residual heat exchanger tube side discharges, and V033A and B, residual heat exchanger bypasses, in accordance with the requirements of Section XI.

Code Reauirement Refer to valve testing paragraph A.2.

43

Licensee's Basis for Reauesting Relief

'The measurement of stroke time for these flow control valves provides no increase in tha level of safety for this system. The valves have no active function when the system is aligned for the LHSI function. The operability testing of these valves every 3 months will verify that the valves will operate from a closed to an open position.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category B valves V032A and B, and V033A and B from the stroke timing requirements of Section XI. The licensee has demonstrated that the only time these valves are required to function as modulating valves is during RHR operation. The above function is tested quarterly.

Once the system is aligned for the LHSI flow path, these valves become passive and are not required to change position to perform their safety function. We conclude that the operability of these valves is inconsequential with regard to the safety functon they perform and that stroke time measurements for passive valves is meaningless.

3.

Category C Valves a.

Relief Request

~

The licensee has requested specific relief from exercising Category C valves V042A and B, RHR pump discharge to cold leg injection checks, in accordance

~

44 y-e

+-

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 Reauesting Relief The operability testing of these normally closed check valves per IWV-3520 reouires flow verification under LHSI into each RCS loop. These valves cannot be-exercised during power operation because the LHSI/RHR pumps cannot overcome RCS pressure. During cold shutdown, tnese valves cannot be full stroke' exercised because design flow cannot be verified through tne valve unless all' initial test conditions can be met a

(i.e., suction from RWST through both pumps to the RCS with the RCS at atmospheric pressure).

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category C valves V042A and 8 from the exercising requirements of Section XI. The licensee has demonstrated that RHR/LHSI pump discharge pressure cannot overcone RCS' operating pressure to establish flow and exercise these valves. Also during cold shutdown, specific initiL1 conditions must be met to permit full flow / full' stroke i-exercising. The vessel head must be removed to place the RCS at atmospheric pressure and provide an adequate.

expansion volume to accomodate full LHS1 flow. We 45 1

r-<m

-.w..r-,

mg r*7

+2r.y-w

,-w-y

-n - w, w t e r*-r ee e e -r-tv ----

• v *v

+ m t

conclude that the proposed alternate testing fr?quency of full stroke exercising these valves during refueling outages should verify proper valve operability.

D.

Containment Spray 1.

Category A Valves a.

Relief Request The licensee has reouested specific relief from performing leak rate testing and valve position indicator checks for Category A valves, V025A and B containment spray pump suctions from the containment sump, in accordance with the requirements of Section XI and propose' to leak test these valves by applying a pressure between the primary and secondary isolations.

A Code Recuirament Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief These valves provide primary isolation for containment sump penetrations with no previsions for leak rate testing with the differential pressure in the same direction as applied when the valves are performing their function as required by IWV-3420(c). Leak rate testing will be performed by applying the differential pressure between the primary and secondary isolation valves.

46

Remote position indicators will be used to verify valve position per IWV-3300. However, visual observation of valve operation is not practical. Such observation would requiro removal of the valve protective enamber which is also considered to be a portion of the-containment pressure boundary. Since the valve is provided with redundant indicators, position is accurately reflected by the remote indications. The leak rate test during each refueling outage will verify that the remote position indicators accurately reflect the closed position of the valves. No practical means exist to verify the open position of the valves.

However, following each leak-rate-test the air pressure will be relieved by opening these valves, thus verifying that the disk moves away from the seat.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A valves V025A and 8 from the leak testing requirements of Section XI. The licensee has demonstrated that with the present piping configurations these valves can only be leak tested by applying a pressure between the valves. We conclude that this method of leak testing should verify the leak tight integrity of these valves. However, we do not agree with the licensee's basis for not checking valve position indicators in accordance with the requirements of Section XI. These valves have a dual safety function, to be full open and permit LHSI pump recirculation and to shut for containment isolation. We conclude that the valve position indicators must be checked to verify these valves are fully open and fully shut and that the proposed test method does not verify this.

47

2.

Category C Valves a.

Relief Request The licensee has requested specific relief from exercising Category C valves V007A and 8, containment spray additive to eductor checks, in accordance with the reauirements of Section XI and proposed to manually full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Operability testing of these normally closed check valves per IWV-3520-during normal operation or cold shutdown is not practical. During normal operation, exercising these valves with flow would introduce sodium hydroxide into the RWST (ECCS water supply).

During cold shutdown, both trains of the system would have to be made inoperable in order to drain the system for bonnet removal and manual exercising of the valve disk. The valves will be verified as operabla by removing the bonnet and manually full stroke exercising the disk at each refueling outage.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category C valves V007A and B from the exercising requirements of 48

Section XI. The licensee has demonstrated that exercising these valves during power operation would contaminate the RWST/ECCS water supply with sodium

~

hydroxide resulting in corrosion of the ECCS systems.

Draining of the system to manually exercise these valves would render the system inoperable. During cold shutdown, draining the system to perform valve testing could result in a delay of reactor startup. We conclude that with the present plant design, manual exercising is the only available method to full stroke exercise these valves without system contamination or rendering the system inoperable. Also, we conclude' that the proposed alternate test method and frequency should demonstrate proper valve operability.

b.

Relief Request The licensee has requested specific relief from exercising Category C valves V002A and B, containment spray pump discharge checks, in accordance with the requirements of Section XI and proposed to manually full stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Reauesting Relief Operability testing of these normally closed check valves per IWV-3520 during power operation or cold shutdown is not practical. During power operation, the CMTC is not available. During cold shutdown, valve 49

~

disassembly or an air test for flow verification requires draining a portion of the system. The valves will be verified as operable by removing the bonnet and manually full stroke exercising the disk at each refueling 6utage.

Evaluation We agree-with the licensee's basis, and therefore feel that relief should be granted for Category C valves-V002A and B from the exercising reauirements of j

Section XI. The licensee has demonstrated that exercising these: valves by establishing flow through the system would result in spraying down the containment resulting in equipment damage. Also, we conclude that the only other available methods of exercising are by valve disassembly and manual disc exercising or by using air to move the disc. These

~

tests reauire containment entry and partial system draining which is not possible during power operation and could result in a delay of reactor startup durina cold shutdown. We conclude that the proposed alternate test method and frecuency to disassemble these valves and manually full stroke exercise during refueling i

should demonstrate proper valve operability.-

c.

Relief Reavest The-licensee has reauested specific relief from-j exercising Category C valve V014, containment spray suction from the RWST, in accordance with the l.

requirements of Section XI and proposed to partial stroke exercise this valve quarterly.

50 i

Code Reautrement Refer to valve testing paragraph A.2.

e Licensee's Basis for Reauestina Relief The operability testing (full stroke) of this normally closed check valve per IWV-3520 during plant operation, cold shutdown, or refueling is not practical. The only-means of full stroking the valve is by-initiating the Containment Spray System which would cause excessive damage to eauipment in CTMT. Manually exercising the valve would reauire removing the valve bonnet after draining the RWST. This action would put the plant in an unsafe condition. The valve will be verified as operable during the auarterly testing of the Containment Spray Pumps. Due to system design, the valve can only be partial stroke tested.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category C valve V014 from the exercising requirements of Section XI during power operation and cold shutdown. The licensee has demonstrated that exercising this valve during power operation or cold shutdown would result in spraying down the containment and thus would cause excessive damage to electrical eauipment inside the containment.

We conclude that with the present piping design only partial stroke exercising during the auarterly pump test can be accomplished. However, Le recommend that the utility further investigate a method to full stroke exercise this valve during each refueling outage.

51

E.

Containment Isolation System 1.,

Category A/C Valves e

a.

Relief Request The licensee has reavested specific relief from

' exercising Category A/C valve V001, containment air sample check, in accordance with the recuirements of Section XI and' proposed to verify valve closure during refueling outages.

Code Recuirement Refer to valve testing paragraph A.2.

Licensee's Basis for Recuesting Relief Due to plant design it is not practical to verify by any positive means, either directly or indirectly, the operability of these normally open check-valves per the requirements of IWV-3520. Valve closure will be verified during the performance of the valve leak-rate test which snall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valve V001 from the exercising requirements of Section XI.

The licen,see has demcnstrated that due to plant design the only method available to verify valve closure (its 52

safety related position) is leak testing. These valves

.are not equipped with valve position indicators and test connections'are located inside the containment.

We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

F.

High Head Safety Injection / Chemical and Volume Control 1.

Category A/C Valves-a.

Relief Request The licensee has requested specific relief.from exercising Category A/C valve V052, SIS accumulator

'I tanks fill line, in accordance with the requirements of Section XI.

Code Requirement Refer tn valve testing paragraph A.2.

Licensee's Basis for Requesting Relief This valve is a passive containment isolation valve whose safety function is to remain closed. Valve leak rate tests shall be conducted each refueling outage.

~'

Evaluation-We agree with the licensee's basis, and therefore feel relief should be granted for Category A valve V052 from the reau!rements of Section XI. This valve is in its 53

safety related position and is not required to open or close to mitigate the consequences of an accident or-safely shut down the plant. Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. 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 exercising Category A/C valves, V058 nitrogen supply to accumulators, Vll5 A, B, and C CVCS seal injections to RCP's, V119 CVCS charging pump discharge to regen heat exchanger, and V213 seal water from RCP's, in accordance with the reauirements of Section XI and proposed to verify valve closure during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Due to plant design it is not practical to verify by any positive means, either directly or indirectly, the operability of these normally open check valves per the requirements of IW/-3520. Valve closure will be

~

verified during the performance of the valve leak-rate r

test which shall be conducted at the same frequency as reactor refueling outages per.the plant Technical Specifications.

54

/

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Catego'y A/C valves r

V058, Vll5 A,'B,-and C, V119, and V213 from the exercising reauirements of Section XI~.

The licensee has demonstrated that due to plant design the only method availaale to verify valve closure (their safety i

related position) is leak testing. These valves ~are not equipped with valve position indicators and test connections are located inside the containment. We.

conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper. valve operability.

c.

Relief Request The licensee has requested specific re;tef-from exercising category A/C valves V062 A, B, and C, SIS boron injection to RCS cold legs in accordance with the requirements of Section XI and proposed to full-stroke exercise theseivalves during refueling outages.

Code Reauirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief l

The operability testing of these normally closed check

[

valves per IWV-3520 requires flow verification under I

HHSI into each RCS loop. This flow verification cannot s

i 55

be accomplished during normal operation or cold shutdown. During normal operation, full or parital stroking would cause overboration of the RCS, possi51y causing a plant shutdown. During cold shutdown, stroking the valve would cause overpressurization of the RCS. The valve will be verified as operable by initiation of HHSI through tne BIT to the RCS during each refueling outage.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for category A/C valves V062 A, B, ar.d C from the exercising recuirements of Section XI. The licensee has demonstrated exercising these valves during power operation would inject highly borated water into the RCS causing power transients that could result in a reactor shutdown. Also, during cold shutdown injecting high head safety injection flow could result in a low temperature over-pressurization of the RCS. We conclude that full stroke exercising can only be accomplished during refueling outages with the vessel head removed providing an adequate expansion volume while the RCS is at atmospheric pressure.

d.

Relief Request The licensee has requested specific relief from exercising Category A/C valves V076 A and B, residual heat exchanger to SI to RCS hot legs, in accordance

~

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

56

Code Reauirement Refer to valve testing paragraph A.2.

Licensee's Basis for Reauesting Relief Operability testing of these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operation, tnese valves cannot be full or partial stroked because the RHR/LHSI pumps cannot overcome RCS pressure.

During cold shutdown, these valves cannot be fully or partially stroked without bypassing the core during RHR and defeating the RHR cooling function. The valves will be full-stroke tested at each refueling outage when RHR/LHSI design flow is used to fill the reactor cavity.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category A/C valves V076 A and B from the exercising requirements of Section XI. The licensee has demonstrated that exercising these valves during power operation cannot be accomplished because RHR/LHSI cannot overcome RCS operating pressure. Also, during cold shutdowr.,

exercising these valves would result in the diversion of RHR flow, thus bypassing the core resulting in a loss of the RHR cooling function. We conclude that full stroke exercising these valves during refueling outages when RHR/LHSI flow is used to fill the

~

refueling cavity should demonstrate proper valve opeaability.

57

e.

Relief Reouest Tha licensee has requested specific relief from exercising Category A/C valves V077 A, B, and C,

~

HHSI/LHSI/RHR to RCS hot legs 1 and 2, in accordance with the requirements of Section XI and proposed to full stroke exercise the valves during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Reauestino Relief Operability testing of these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operation, these valves cannot be full stroked because the HHSI pumps cannot provide design flow and the LHSI pumps cannot provide any flow. Partial strcking the valves with the HHSI pumps at power would induce thermal shock to the safety injection nozzles. During cold shutdown, full or partial stroking with the HHSI pumps could overpressurize the RCS. The valves will be full stroked by initiation of LHSI while filling the cavity during each refueling outage. Establishment of LHSI/ECCS design flow through the not leg injection 2

path will verify that the valves have sufficiently opened to perform their function.

~

i 58 i:

Evaluation We agree with the licensee's basis and therefore feel that relief'should be granted for Category A/C valves V077 A, B, and C from the exercising requirements of Section XI. The licensee has demonstrated that exercising these valves during power operation with HHSI flow would result in thermal shock to the injection nozzles causing damage. Also, during power operation LHSI/RHR cannot overcome RCS operating.

pressure to exercise these valves. During cold

~

shutdown, exercising these valves using HHSI flow could result in'a low temperature overpressurization of the RCS. We conclude that full stroke exercising these-valves while filling the refueling cavity with the vessel head removed providing an expansion volume and the RCS at atmospheric pressure should verify proper valve operability.

2.

Category B Valves a

a.

Relief Request The licensee has requested specific relief from exercising Category B valve V254, CVCS BA filter to the charging punp suction, in accordance with the requirements of Section XI and proposed to full stroke exerr.ise this valve during refueling outages.

i Code Reauirement Refer to valve testing paragrapn A.2.

s 59

Licensee's Basis for Reauesting Relief Operability testing of this valve during normal operation or cold shutdown would require that the boric acid system be made inoperable, thus placing the plant in an unsafe condition. The valve will be full stroke tested for operability at each refueling outage.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category B valve V264 from the exercising requirements of Section XI. The licensee has demonstrated that if this valve failed while exercising, the boric acid system w0uld be made inoperable. The boric acid system is reouired to be in continuous operation during power operation and cold shutdown. We conclude that exercising this valve during refueling outages when the system can be removed from service should verify proper valve operability.

3.

Category C Valves a.

Relief Request l

The licensee has requested specific relief from exercising Category C valves V066 A, B, and C, HHSI j

pump discharge to RCS cold legs, and V078 A, B, ano,

and V079 A, 8, and C, HHSI pump discharge to RCS hot legs, and proposed to full stroke exercise tnese yalves I

~

during refueling outages.

l 60 L-

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Reauesting Relief Operability testing of these normally closed Check valves per IWV-3520 during normal operation or cold shutdown is not practical. Curing normal operatinn, these valves cannot be full stroke exercisad because the HHSI pumps cannot achieve design flow against RCS pressure. Partially stroking the valves at power would induce thermal shock to the safety injection nozzles.

During' cold shutdown, full stroking would overpressurize the RCS. The valves will be verified as operable by comparing HHSI flow to the sum of the established individual reactor loop injection flows.

The valve test will coincide with the testing of tne HHSI system during each refueling outage.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C valves V066 A, B, and C, V078 A, B, and C, and V079 A, B, and C from the exercising requirements of Section XI. The j

licensee has demonstrated that exercising these valves during power operation would result in thermal shocking of the injection nozzles causing nozzle damage. Also, during cold shutdown, exercising these valves with HHSI l

flow could result in a low temperature l

overpressurization of the RCS. We conclude that full stroke exercising these valves during refueling outages l

with the vessel head removed providing an adequate 61 I

L

expansion volume to prevent low temperature over-pressurization and the RCS at atmospheric pressure should verify proper valve operability.

b.

Relief Request The licensee has reouested specific relief from exercising Category C valve V026 HHS1 suction from the RWST in accordance with the requirements of Section XI and proposed to full stroke exercise this valve during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Reauesting Relief The operability testing of this normally closed check valve per IWV-3520 requires flow verification under HHSI into each RCS loop. This flow verification cannot be accomplished during normal operation or cold shutdown. During normal operation, full or partial stroking would cause overboration of the RCS, possibly causing a plant shutdown. During cold shutdown, stroking the valve would cause overpressurization of the RCS..The valve will be verified as operable by initiation of HHSI through the BIT to the RCS during each refueling outage.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category C valve V026 62

from the exercising requirements of Section XI. The licensee has demonstrated exercising this valve during power operation would inject hignly borated water into tiie RCS causing power transients that could result in a reactor shutdown. Also, during cold shutdown injecting high head safety injection flow could result in a low temperature over-pressurization of the RCS. We conclude that full stroke exercising can only be accomplished during refueling outages with the vessel head removed providing an adequate expansion volume while the RCS is at atmospheric pressure, c.

Relief Reauest The licensee has requested specific relief from exercising Category C valves V032 A, B, and C, accumulator discharge to RCS cold legs, in accordance with the requirements of Section XI and proposed to partial stroke exercise these v.:<es during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief The operability testing of these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operation, these valves cannot be full-or partial-stroke exercised because the accumulators cannot overcome PCS pressure. During cold shutdown, these valves cannot be fully or partially stroked without overpressurizing the t

63

RCS. During refueli.1g outages, these valves cannot be full-stroke exercised at accumulator operating pressure without causing internal core damage due to excessive flow rates. Disasembly of the valves during refueling outages reauires the draining of the accumualtors and associated piping. The valves will be partial-stroke exercised at each refueling outage by discharging the accumulators into the RCS with the accumulators at atmospheric pressure. The valves will be verified as closed prior to the exercising by testing for leakage with a differential pressure >100 psi across the valves. A decrease in accumulator level when the system is discharged to the RCS will verify a partial st oke.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C valves V032 A, B, and C from the exercising requirements of Section XI during power operation and cold shutdown.

The licensee has demonstrated that during power operation these valves Cannot be exercised because accumulator pressure cannot overcome RCS. operating pressure. During cold shutdown exercising these valves I

with accumulator flow could result in a low temperature over-pressurization of the RCS. We also agree that full stroke exercising these valves with accumulator flow during refueling outages with the vessel head removed to provide an adequate expansion volume could result in internal core damage because of the excessive flow rates. We conclude that with the present piping

~

configurations, only partial stroke exercising of these valves is possible. However, we recommend that the 64

utility further investigate a method to full stroke exercise these valves-(i.e. manual exercising during refueling outages).

d.

Relief Request The licensee has requested specific relief from exercising Category C valves V037 A, B, and C, accumulator discharge to RCS cold legs, in accordance with the requirements of Section XI and proposed to partial stroke exercise these valves during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Reauesting Relief The operability testing of these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operation, these valves cannot be full-stroke exercised because the accumulators cannot overcome RCS pressure. The valves cannot be partial-stroke exercised during normal operation without making the accumulators inoperable, thus placing the plant in an unsafe condition. During cold shutdown, these valves Cannot be fully or partially stroked without overpressurizing the RCS.

During refueling outages, these valves cannot be full-stroke exercised at accumulator operating pressure without causing internal core damage due to excessive

. flow rates. Disassembly of the valves during refuelina j

j outages requires the draining of the accumulators and l

65

associated piping. The valves will be partial-stroke exercised at each refueling outage by discharging the accumulators into the RCS with the accumulators at atmospheric pressure. The valves will be verified as closed prior to the exercising by testing for leakage with a differential pressure >100 psi across the valves. A decrease in accumulator level when the system is discharged to the RCS will verify a partial stroke.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C valves V032 A, B, and C from the exercising requirements of Section XI during power operation and cold shutdown.

The licensee has demonstrated that during power operation these valves cannot be exercised because accumulator pressure cannot overcome RCS operating pressure and the accumulators cannot be removed from service. During cold shutdown exercising these valves with accumulator flow could result in a low temperature overpressurization of the RCS and the accumulators are isolated, which prevents partial stroking through the test line. We also agree that full stroke exercising these valves with accumulator flow during refueling outages with the vessel head removed to provide an adequate expansion volume could result in internal core damage because of the excessive flow rates. We conclude that with the present piping configurations, only partial stroke exercising of these valves is possible. However, we recommend that the utility further investigate a method to full stroke exercise these valves (i.e., manual exercising during refueling outages).

66

e.

Relief Reauest The licensee has requested specific relief from exercising Category C valve V210, CVCS BA filter to charging pump suction, from the exercising requirements of Section XI and proposed to full stroke exercise this valve during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Operability testing of this normally closed check valve per IWV-3520 during normal operation or cold shutdown would require that the boric acid system be made inoperable, thus placing the plant in an unsafe condition. The valve will be full-stroke tested at

~

[

each refueling outage. A flow or differential pressure greater than or equal to the manufacturer's minimum full-open values (Flow 2; 10 GPM, dP 2: 5 psig) will be verified.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C valve V210 from the exercising requirements of Section XI. The licensee has demonstrated that exercising this valve requires isolation of the boric acid system. The boric acid system is required to be insservice at all times during power operation and cold shutdown. We conclude that full stroke exercising this valve during refueling outages when the boric acid system can be removed from service should verify proper valve operability.

67

,-.,.-,,y

,+--n 9,.

a,-

. -,, ~

4

- G.

Post Accident Containment Venting and Sampling 1.

Category B Valves a.

Relief Request The licensee has reauested specific relief from exercising Category B valve V021, CTMT pressurization line, in accordance with the requirements of Section XI and proposed to full stroke exercise this valve during refueling outages.

Code Reauirement Refer to valve testing paragraph A.2.

Licensee's ' Basis for Requesting Relief The operability testing (full stroke) of this valve during normal operation or cold shutdown could cause a loss of system function. During normal operation, opening the valve dumps all instrument air into the CTMT atmosphere causing a loss of RCS pressure control for spray and a loss of 1etdown control. During cold shutdown, exercising the valve would cause loss of pressure control and level control. Valve design does not facilitate a partial-stroke test.

The valve will be full stroke tested for operability it each refueling _ outage.

t l

t 68 e

m

+

.s,-a

--y,-

w-.--e, n-y

,e

,- ~-

,.,m.-

,,,-e a-

- -,,-, -, < - m

Evaluation We agree.with the licensee's basis and therefore feel that relief should be granted for Category B valve V021 from the exercising requirements-of Section XI. The licensee has demonstrated that exercising this valve during power operation would cause a loss of spray for RCS pressure control and a loss of letdown and pressurizer level control which could result in a reactor trip. Also, exercising this valve during cold shutdown would cause a loss of RCS pressure and level control which could result in a RCS low temperature overpressurization. We conclude that full stroke exercising this valve during refueling outages with the vessel head removed and the RCS at atmospheric pressure should demonstrate proper valve operability.

H.

Liould Waste Disposal 1.

Category A and A/C Valves 1

a.

Relief Reauest The licensee has requested specific relief from exercising Category A valve V005, reactor coolant drain tank control valve, in accordance with tne requirer.1ents of Section XI.

Code Reauirement Refer to valve testing paragraph A.2.

69

.~

Licensee's Basis for Requesting Relief The operability testing (full or partial stroke) during normal operation or cold shutdown of these valves provides no assurance of an increase in safety. The valve is a containment isolation valve which is normally closed and passive. The valve's closed position will be verified during the performance of the leak-rate tests at each refueling outage.

Eva hation We agree with the licensee's basis, and therefore feel relief should be granted for Category A valve V005 from the requirements of Section XI. This valve is in its safety related position and is not required to open or close to mitigate the consequences of an accident or safely shutdown the plant. Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. 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 exercising Category A/C valves V204, containment sump recire, and V291, containment sump pump discharge in accordance with the requirements of Section XI and

~

proposed to verify valve closure (their safety related position) during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

70

Licensee's Basis for Requesting Relief Due to plant design it is not practical to verify by any positive means, neither directly por indirectly, the operability of these normally open check valves per the requirements of IWV-3520. Valve closure will be verified during the performance of the valve leak-rate test whicn snall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

Evaluation We agree with the licensee's basis, and tnerefore feel that relief should be granted for Category A/C valves V204 and V291 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (their safety related position) is leak testing. These valves are not equipped with valve position indicators and test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at l

refueling outages should demonstrate proper valve operability.

l I.

Spent Fuel Pool Cooling and Clean-up 1.

Category A and A/C Valves f*

a.

Relief Request l

l The licensee has requested specific relief from exercising Category A valve V012, spent fuel pool clean-up-loop isolation, in accordance with the reauirements of Section XI.

71

Code Reautrement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief The operability testing (full or partial stroke) during normal operation or cold shutdown of this valve provides i:o assurance of an increase in safety. The valve is a containment isolation valve which is normally closed and passive. The valve's closed position will be verified during the performance of the leak-rate tests at each refueling outage.

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A valve V012 from the requirements of Section XI. This valve is in its safety related position and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability i

of this valve is inconsequential with regard to the safety function which it performs. We conclude that the quarterly stroke and stroke time measurements are meaning 1ess for passive valves, b.

Relief Reauest The licensee has requested specific relief from

~

exercising Category A/C valve V013, spent fuel pool

~

1 cooling clean-up loop check, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety related position) each refueling outage.

72 4

Code Reauirement Refer to valve testing paragraph A.2.

+

Licensee's Basis for Reauesting Relief _

Due to plant design it is not practical to verify by any positive means, either directly or indirectly, the operability of these normally open check valves per the requirements of IWV-3520. Valve closure will be verified during the performance of the valve leak-rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

~

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valve V013 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve 4

closure (its safety related position) is leak testing.

This valve is not equipped with valve position indicators and test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

J.

Auxiliary Feedwater 4

1.

Category B Valves 73

a.

Relief Request The licensee has requested specific relief from exercising Category B valves V013 A and B, and V014 A, B, and C, service water to auxiliary feedwater_ pump suction, 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 It is not practical to exercise these valves during

~

normal plant operation or at cold shutdown per IWV-3410. The exercising of these valves would introduce chlorides and fluorides into the Steam Generators, jeopardizing the secondary water chemistry which would result in Steam Generator mechanical damage. These valves will be exercised at reactor refueling outages.

i Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category B valves 4

V013 A and B and V014 A, B, and C from the exercising requirements of Section XI. The licensee has demonstrated that exercising these valves during power operaton or cold shutdown could introduce service water into the AFW suction piping resulting in the introduction of chlorides and fluorides int-the steam 74

generators. Tnus, secondary water chemistry auld be out of specification and steam generator mechanical stress damage could occur. We conclude that exercising o.

~

these valves during refueling outages when the AFW suction piping can be isolated and flushed prior to its return to service should demonstrate proper valve operability.

K.

Service Water 1.

Category A/C Valves a.

Relief Request The licensee has requested specific relief from exercising Category A/C valve V075, service water to RCP motor coolers, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety related position) during refueling outages.

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Due to plant oesign it is not practical to verify by any positive means, neither directly por indirectly, 1

the operability of these normally open check valves per the requirements of IWV-3520. Valve closure will be verified during.the performance of the valve leak-rate.

test wnich shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specification.

4 75

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valve V075 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (its safety related position) is leak testing.

This valve is not equipped with valve pcrition indicators and test connections are located inside the containment. We conclude that the proposed alternate '

testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages I

should demonstrate proper valve operability.

~

L.

Condensate and Demineralized Water Transfer and Storage 1.

Category A/C Valves a.

Relief Reouest The licensee has requested specific relief fro.7 l

exercising Category A/C valve'V002, deminerlized water to reactor vessel head storage, in accordance with the i

requirements of Section XI and proposed to verify valve closure (its safety related position) each refueling i

outage.

i i

Code Requirement l

~

Refer to valve testing paragraph A.2.

k e

76

s Licensee's Basis for Reauesting Relief Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve per tne requirements of IWV-3520. Valve closure wi,ll be verified during the performance of the valve leak-rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valve V002 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (its safety related position) is leak testing.

This valve is not eauipped with valve position i

indicators and test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

M.

Component Cooiing 1.

Category A/C Valves O

a.

Relief Request i

The licensee has requested specific relief from exercising Category A/C valves VIS9, CCW supply to 77 L

excess letdown heat. exchanger, and V083, CCW supply to RCPs, in accordance with the reauirements of Section XI and propned to verify valve closure (their safety related position) during refueling outages.

Code Requirements Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of these normally open check valves per the requirements of IWV-3520. Valve closure will be verified during the performance of the valve leak-rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valves V083 and V159 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (their safety related position) is leak testing. These valves are not equiped with valve position indicators and test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying. valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

78

l N.

Service Air System l.

Category A Valves t

a.

Relief Request The licensee has reauested specific relief from exercising Category A valves V001 and 002, service air I

to pipe penetration room and containment, from the exercising reauirements of Section XI.

l Code Reauirement

. Refer to valve testir.g paragraph A.2.

l Licensee's Basis for Requesting Relief The operability testing (full or partial stroke) during normal operation or cold shutdown of these valves provides no assurance of an increase in safety. The valves are containment isolation valves which are-normally closed and passive. The valves' closed position will be verified during the performance of the leak rate tests at each refueling outage.

Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A valves V001 and 002 from the requirements of Section XI.

i 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 shutdown the plant. Therefore, the operability of these valves is i

7 79 c

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inconsequential with regard to the safety function which they perform. We conclude that the cuarterly stroke and stroke time measurements are meaningless for passive valves.

O.

Instrument Air 1.

Category A/C Valves a.

Relief Request The licensee has requested specific relief from exercising Category A/C valve V002, containment instrument air supply, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety related position) during refueling outages.

5 i

Code Requirement Refer to valve testing paragraph A.2.

Licensee's Basis for Requesting Relief Due to plant design it is not practical to verify by any positive means, either directly or indirectly, the operability of these normally open check valves per the requirements of IWV-3520. Valve closure will be verified during the performance of the valve leak-rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

e 80 L.

Evaluation We agree with the licensee's basis, and therefore feel tnat relief should be granted for category A/C valve V002 from the exercising requirements of Section XI.

The licensee has demonstrated that due to plant design the only method available to verify valve closure (its safety related position)'is leak testing. This valve is not equipped with valve position indicators and test I

connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

P.

Containment Cooling and Purge 1.

Category A Valves a.

Relief Request i

The licensee has requested specific relief from exercising Category A valves V002A and B, containment leak rate test, in accordance with the requirements of-i Section XI.

Code Reairement i

j Refer to valve testing paragraph A.2.

1 Licensee's Basis for Reauesting Relief-The operability testing (full or partial stroke) during normal operation or cold shutdown of thesd valves 81

provides no assurance of an increase in safety. The valves are containment isolation valves wnich are normally closed and passive. The valves' closed

~

position will be verified during the performance ~of the

~

leak rate tests at each refueling outage.

Evaluaticn We agree with the licensee's basis, and'therefore feel relief should be granted for Category A valves V002A and 8 from the requirements of Section XI. Tnese valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shutdown the plant.

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

Q.

Miscellaneous 1.

Valves Exercised During Cold Shutdowns and Refuelings a.

Relief Recuest i

The licensee has requested specific relief for all valves that require stroke timing, that can only be exercised during cold shutdowns or refueling outages from the exercising requirements of Section XI and proposed to test these valves once each cold shutdown,

~

not to exceed once each month, if this testing

-frequency is required by IW-3410(c).

4 e

82

Code Reauirement IWV-3410(c) states that if an increase in Stroke time of 25% or ma-e from the previous test for valves with stroke times greater than ten seconds or 50% or more for valves witn stroke times less than or equal to ten seconds is observed, test frequency shall be increased to once each montn until corrective action is taken.

Licensee's Basis for Requesting Relief Valves that are normally tested during cold shutdown or refueling cannot be tested once each month. Stroking these valves during power operation may place the plant in an unsafe condition. The test freauency shall be increased to once each cold shutdown, not to exceed once each month.

Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for all valves that require stroke timing that can only be exercised during cold shutdowns and refueling outages from the exercising requirements of IQWV-3410(c). Tne licensee has provided the specific technical basis why each of these valves cannot be exercised during power operation. We

,clude that the proposed alternate testing freau..

y to exercise valves once each cold shutdown, not to exceed once cach month, if required by IWV-3410(c), meets the intent of Section XI.

O 83

b.

Relief Recuest The licensee has requested specific relief for all

~

valves that can only be exercised during cold shutdowns or refueling outages from the requirements of Section XI, IWV-3410(g) and IWV-3520(c), and proposed to use plant Technical Specifications to determine the conditions for plant " tart-up.

Code Reauirement IWV-3410(g) and IWV-3aIO(c) state that when corrective action is reacired as a result of tests made during cold shutdown, the condition shall be corrected before startup. A retest showing acceptable operation shall be run following any required corrective action'before the valve is returned to service.

Licensee's. Basis for Reauesting Relief The plant Technical Specifications provide the requirements and plant conditions necessary for plant startup. The test recuirement will be satisfied before tne valve is required for plant operability as defined in the plant Technical Specifications.

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

that relief'should be granted for all valves, that can l

only be exercised during cold shutdowns and refueling outages, from the requirements of Section XI, IWV-3410(g)- and IWV-3520(C). The Josepn M. Farley Technical Specifications nave been previously reviewed 84 T

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• and approved by the NRC. We conclude that using plant Technical Specifications to establish limiting conditions of operations meets the intent of the requirements of Section XI and should assure system availability.

O e

4 o

O 85

d IV. Attachment !

The following are Category A, 8, and C valses 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 the 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.

4 A.

Residual Heat Removal / Low Head Safety injection l.

Category A valves V001A and B, reactor coolant to RHR pumps and Category B valves V016A and B, RHR pump suctions cannot be exercised during power operation. These valves are interlocked shut when RCS pressure is greater than 3

402.5 psig to prevent overpressurizing the P!R system.

Also, these valves are not designed for partial stroke exercising. These valves are full stroke exercised during cold shutdowns and refueling outages.

l 2.

Category B valve V044, residual heat exchanger discharge to RCS hot leg, cannot always be exercised during power operatien. The operability testing (full or partial stroke) of this valve during normal operation could subject the RHR system to pressure in excess of its design pressure (600 psig).

It is assumed for the purpose of the cycling test that the upstream check valves have failed. Venting of l

the upstream pressure cannot be accomplished under any I

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conditions because of the radiation hazard to plant personnel. Once every three (3) months the upstream pressure will be measured.

If the pressure is less than or equal to 550 psig, then the valve will be full stroke exercised.

If the pressure is greater than 550 psig the valve not will be exercised that quarter.

If the upstream pressure prohibits quarterly testing, the valve will be full stroked at cold shutdowns and refueling outages.

B.

Containment Isolation System 1.

Category A valves V002, HV3657, and HV3658, containment air samples, cannot be exercised during power operation. The operability testing (full stroke shutting) of these valves during normal operation could cause a loss of system function. A failure while cycling in a nonconservative position would cause a loss of the CTMT radiation monitoring system. The valve design does not facilitate a partial-stroke test. The valves will be full-stroke tested for operability at each cold shutdown and refueling outage.

This system is reauired for accident mitigation.

2.

Category A valves V003 and V004, containment differential pressure detector isolations, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation could cause a loss of system function. A failure while cycling in a nonconservative position would cause a loss of the CTMT Pressure Instrument System. The valve design does not facilitate a partial-stroke test. The valves will be

~,

full-stroke tested for operability at each cold shutdown and refueling outage. The containment pressure instrument system is required for power operation and accident mitigation.

87 1

C.

Hign Head Safety injection / Chemical and Volume Control 1.

Category B valves Vn'+5, boron injection recirculation to

~

boron injection tank, and V056A and B, boron injection tank recirculation isolations, cannot be exercised during power operation. The operability testing (full stroke) of this valve during normal operation could cause a loss of system function. A failura while cycling in a nonconservative (closed) position would render the boron injection system inoperable. The vo'ume of the BIT could not be assured.

Valve design does na+ facilitate a partial-stroke test. Tne valves will be full stroke tested for operability at each cold shutdown.

2.

Category B valves Vn63, HHSI to RCS cold legs, and V068 and

^

V072, HHSI to RCS hot legs, cannot be exercised during power operation. The ope ability testing (full stroke) of these valves durino norma' operation could put the plant in an unsafe condition. These normally closed valves provides back-up safety-inje-tion into the RCS bypassing the BIT.

Failure during cycling in a nonconservative position would jeopardize the normal safety injection function. The valve -

design does not facilitate a partial-stroke test. These valves will be full-stroke tested for operability at each cold shutdown.

3.

Category A valves V249A and B seal water from RCPs, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation could cause a loss of system function. The failure of these valves in a nonconservative position during a cycling test would cause the loss of the RCP seal water cooling function resulting in pump damage or forcing the RCP to be stopped resulting in a reactor trip. The design of the valve will not facilitate a partial-stroke test. The valves will be full-stroke tested for operability at each cold shutdown.

88

4.

Category A valves V254, RC from regen heat exchanger, and V257Jand 258,'CVCS charging pump discharges to the regen heat exchanger, and Category B valves V376A and B, charging s

pump suctions from the VCT, cannot be exercised during power operation. Failure of these valves in an unconservative position while exercising would eliminate the VCT as a source of cnarging make up water which would result in a loss of pressurizer level control and could cause a reactor scram. The design of these valves does not facilitate partial stroke exercising. These valves will be full-stroke tested for operability at each cold shutdown.

D.

Main Steam 1.

Category B valves V001A-C and V002A-C, MSIV's cannot be fuM stroke exercised during power operation. Shutting these valves would result in a turbine trip and could result in a reactor trip. These valves are partial stroke exercised during power operation and full stroke exercised during cold shutdowns.

2.

Category B valves V003A-F cannot be exercised during power

~

operation. The operability testing (full stroke) of these valves during normal operation is not possible. The bypass valves are interlocked with the MSIVs such that when the MSIVs are open, the bypass valves are closed. The design of the valves will not facilitate a partial-stroke test. The valves will be full-stroke tested for operability at each cold shutdown.

m E.

Condensate and Feedwater 1.

Category B valves FCV 478, 488, and 498, main feedwater isolations, and FCV 479, 489, and 499, main feedwater bypass isolations, and category C valves V001A-C, main feedwater 89

checks, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation would cause an interruption of feedwater to the Steam Generators and introduce unwarranted transi'ents to the primary as well as the secondary systems that could result in a reactor trip. The design of the valves will not facilitate a partial-stroke test. The valves will be full-stroke tested for operability at each cold shutdown.

F.

Auxiliary Feedwater-1.

Category C valves V002A, B, C, E, and G, MDAFW discharge to S/Gs, and V0llA, B, and C, auxiliary feedwater to S/Gs, cannot be exercised during power operation. The only positive means of exercising these normally closed valves is by directing AFW flow into the Steam Generators. The initiation of AFW during power operation will result in onnecessary thermal. shock to the Auxiliary Feedwater-to-Main-Feewater connection. An introduction of cold water into the secondary system will also cause power transients. AFW flow will be directed through the valves at the design flow rate.

of the AFW system at cold shutdown. Verification of this I

flow through the valves in conjunction with verification that the control valve position is the same for each test i

will provide assurance that the valves have opened sufficiently to perform their function.

2.

Category C valves V002D, F, and H and V003, TDAFW discharge to S/G's, cannot be exercised during power operation. The only positive means of exercising (full or partial stroke)

~

of these normally closed valves is by directing AFW flow

~

into the Steam Generators. The initiation of AFW during power operation will result in unnecessary thermal shock to the Auxiliary Feedwater-to-Main Feedwater connection. An introduction of cold water into the secondary system will

- 90

also cause power transients. The operation of the Turbine Driven AFW pump during cold shutdown is not possible because Turbine Drive steam is not available. AFW flow will be directed through the valves at the design flow of the AFW system during a mode of operation approaching cold shutdown or leaving cold shutdown in which steam is available.

Verification of this flow through the valves in conjunction with verification that the control valve position is the same for each test will provide assurance that the valves have opened sufficiently to perform their function.

3.

Category C' valves V007A and 8, MDAFW pump suction checks, cannot be full stroke exercised during power operation. No instrumentation is provided for the determination of differential pressure across the valves. A partial-stroke test will be accomplished during the quarterly testing of the MDAFW pumps. Acceptance of the pump test will provide assurance that the valves have partially opened. A full-stroke test will be accomplished by providing MDAFW pump design flow to the Steam Generators during cold

^

shutdown. Verification that design flow is reached provides assurance that the valves have opened in order to perform their function.

G.

Service Water 1.

Category A valves V071, service water to RCP motor coolers, and V072 and 81, service water return from RCP motor coolers cannot be exercised during power operation. The operability testing of these valves during normal operation could cause a loss of system function. The failure of one of these valves in a nonconservative (closed) position would cause overheating of the RCP motors and would require the shutodwn a

of RC Pumps and of the Reactor. Valve design does not facilitate partial-stroke testing. Thsse valves will be full-stroke tested for operability at each cold shutdown.

91

H.

_ Component Cooling Water 1.

Category A valves V082, CCW to RCP's, ar.d V097 and 99, CCW.

from RCP's Pearings, and HV3045 and 3184, CCW return from-RCP's thermal barriers, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation would jeopardize the RCP cooling function. Cycling of the valves would interrupt the CCW supply to the reactor coolant pumps. Also the failure of.the valves in a nonconservative position during the

~

cycling test would result in a loss of the system function.

This would require stopping RCPs to. prevent overheating and damage resulting in a reactor shutdown. The design of the motor-operated valves will not facilitate a partial-stroke test. The valves will be full-stroke tested for operability at each cold shutdown.

I.

Instrument Air 1.

Category A valve HV3611, containment instrument air supply, cannot be exercised during power operation. The operability testing (full stroke) of'this-valve during normal operation would cause an interruption of instrument air supply to i

instruments and equipment associated with the RCS. Also, a failure in a nonconservative position during a cycling test would cause a complete loss of instrument air supply to the containment resulting in a loss of RCS control and could force a reactor shutdown. ~The design of the valve will not facilitate a partial-stroke test. The valve will be full-stroke tested for operability at each cold shutdown.

O i

e 92

f V.

Attachment II The P& ids listed below were used during the course of this review.

System P&ID Rev.

Post Accident Containment Combustible Gas D-175019 9

Safety injection D-175038

-(sheet 1) 12

~

(sheet 2) 10-(sheet 3) 6 Penetration and Filtration (HVAC)

- D-175022 Containment Cooling and Purge 0-175010 (sneet 1) 9 (sheet 2) 5 Chemical and Volume Control D-175039 (sheet 1) 8 (sheet 2) 11 Service Water D-17-119 (sheet 2)

(sheet 3)

River Water D-170119 (sheet 7)

Waste Processing D-175042 8

C Containment Drains and Vents D-175004 i'

(sheet 1) 13 Spent Fuel Pool Cooling D-175043 8

Main and Auxiliary Steam D-175033 (Sheet 1) 11 (sheet 2) 9 93

- - _ _ _ _ ~ -

System P&ID Rev.

Main Feedwater D-175073 6

Auxiliary Feedwater D-175007

. 12-Demineralized Water -

D-175047 12 4-Sampling 0-175009 (sheet 1) 13

(' sheet 2) 9

~

4 Component Cooling Water

.D-175000 l

(sheet 1) 13 (sheet 2) 11 i

r.

Service Air D-175035 5

Instrument Air.

D-175034 (sheet 2)-

0 (sheet 3) 0 HVAC and Filter D-205012 6

HVAC and Filter D-175012

- 10 Reactor Coolant D-175037 (sheet 2) 9 4

Residual Heat Removal D-175041 9

.(

t Service Water D-175003 (sheet 1) 9 (sheet 2) 9 i

e se 94

4 VI. Attachment III A.-

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

i.

1.

V014 containment spray suction from RWST 2.

V032 A, B, and C accumulator discharge to RCS cold legs i

B.

Relief requests with insufficient technical basis where relief was not recommended:

L 1.

Valve Testina Program a.

D.2.c

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b.

F.3.c c.

C.l.a d.

D.l.a t

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