ML19340B976

Ser,Inservice Testing Program,Salem Nuclear Generating Station Unit 1, May 1979-Nov 1980

ML19340B976
Person / Time
Site:	Salem
Issue date:	10/31/1980
From:	Fehringer J, Rockhold H ENERGY, DEPT. OF, IDAHO OPERATIONS OFFICE
To:	Nerses V Office of Nuclear Reactor Regulation
References
CON-FIN-A-6258 EGG-EA-5265, NUDOCS 8011130018
Download: ML19340B976 (48)

Text

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FORM EG&G398 (Rev 1179; fNTERIM REPORT Accession No. ____

Report No. EGG-EA-5265 2

Contract Program or Project

Title:

Systems Engineering Support Subject of this Document:

Safety Evaiaation of the Inservice Testing Program for Pumps and Valves at the Salem Nuclear Ge' erating Station Unit 1 (Docket No. 50-272) for the Period 5-1-79 through 12-1-80 Type of Document:

j Safety Evaluation Report Author (s):

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

October 1980 Responsible NRC Individual and NRC Office or Division:

Victor Nerses, NRC-DE This document 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.

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EG&G Idaho, Inc.

Idaho Falls. Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.

Under DOE Contract No. DE-AC07-761D01570 NRC FIN No. A6258 i

INTERIM REPORT

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20 CONTENTS l

. I. 111roduction ........... ........................ . . . . . . . . . . . . , , 1 II. P t.sp Tes t i n g P r:;9 ram . . . . . . . . . . . . . . . . . . . . . . . . . . .

............... 3 III. Velve Testin9 Pro 9 ram .. ........................ ............... 4 i

IV. A.tachment I ............ ....................... ............... 35 l

1 V. Aitachment II ................................... ............... 37

, VI. A t t a c h m en t I I I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 V I I . A t t a c hm e n t I V . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 e

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jn_troduction sr 6 '

Cx tained herein is a sa; ty evaluation of the po p and valve im ervice testing (IST) ; Tgram submitted by the ublic Service E 9ctric and Gas Company (PSE&G) on February 9,1379 for its Salem,

, Vait I nuclear plant. TM program applies to Salem, Unit 1 for the '

period. The working ses oq with PSE&G and Saler. , Unit 2 ranresentatives was conduted on January 30 and 21,1980. The-licensee resubmittal was issued on March 10, 1980 and was reviewed by E M G Idaho Inc., to verity compliance of proposed tests of safety related class 1, 2, and .: pamps and valves with r quirements of the A3ME Boiler and Pressure Vessel Code,Section XI,1974 Edition, through the Summer of 1975 Addenda. PSE&G has also requested relief f ecm the ASME Cor'e from testing specified valves s' ecause 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 is contained in Section II; the evalution of the valve testing program and associated relief requests is contained in Section III. All evaluations for Sections II j and III are the recommendations of EG&G Idaho, Inc.

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Category A, A/C, and A/E valves that are currently being leak tested per Technical Specifications (Appendix J) or are currently exempted from leak rate testing by Technical Specifications are contained in Attachment I.

4 Valves that should be reviewed by the NRC to determine if they should 3 be categorized A are contained in Attachment I.

], Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not exercised every 3 months are esatained in l Attachment II.

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

Valves that are never full stroke exercised or that have a testing .

interval greater than each refueling outage relief requests with insufficient technical basis where relief is not recommended are

, sumarized in Attachment IV.

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i l II. Pu w Testing Program l

j - Ti. IST program submitted by PSE&G Company was ext a:ned to verify that j Cl at,s 1, 2, and 3 saf ety > el ated pumps were inclu. : in the program an i that those pumps are subjected to the periodic tests as required by the ASME Code,Section X'. Our review found tt 't all Class 1, 2, l anti 3 safety related pumpi 1:ere included in the I$ program and the picp tests and frequency of testing comply with the code.

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III. Valve Testing Program Evaluation The IST program submitted by PSE&G Company for Sa'em Unit 1 was .

examined to verify that Class 1, 2, and 3 safety r elated 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 1, 2, and 3 safety related valves were included in the IST program and, except for those valves identified below for which specific relief from testing has been requested, the velve tests and frequency of testing comply with the code requiremercs and the NRC positions and guidelines listed in Gereral Section A. Also, included in the General Section A is the NRC position and valve listing 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 PSE&G request for relief from testing valves, the code requirement for .

testing, PSE&G basis for requesting relief, and the EG&G evaluation of that request is summarized (B through K) below and grouped according .

to each specific system.

A. General Considerations

1. Testing of Valves Which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure boundry have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class 1 boundary forming the interface between these high and low pressure systems prevent the low pressure systems from pressure.s which exceed their design limit. In this role, the valves perform a pressure isolation function. ,

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o The NRC consicers the redundant isolation provided by these valves to be important. The NRC considers it necessary to

, ensure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For these reasons, EG&G believes that some method, such as pressure monitoring, leak testing, radiography and ultrasonic testing, should be used to ensure the condition of each valve is satisf actory in maintaining this pressure isolation function.

If leak testing is selected as the appropriate method for achieving this objective, and EG&G Inc. believes that the following valves should be categorized as A or AC and leak tested according the IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are:

11-14SJ139 11-14SJ156 11 + 12SJ40 11-14SJ144 11-14SJ55 13 + 14RH27 11-14SJ56 11-14SJ43 1RH1 + 2 1RH26 The NRC and EG&G Inc. have discussed this matter with the licensee and identified the valves listed above. The licensee agreed to consider testing and categorizing each of these valves with the appropriate designation depending on the testng method selected. Whatever method the licensee selects for determining the condition of each valve, the licensee will provide to the NRC for evaluation the details of the testing method which clearly demonstrate the condition of elch valve.

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2. ASME Code Section X! Requirements Subsection IWV-3410(a) of the Section XI Coda (which ,

discusses full stroke and partial stroke) requires the Code Category A and B valves be exercised once every 3 months, .

with the exceptions as defined in IWV-3410(li-1), (e), and (f ) . IWV-3520(a) r. quires that Code Category C valves be exercised once every 3 months, with the exccptions as dor ed in IWV-3520(b). IWV-3700 requires no regular ,

testing for Code Category E valves. Operational checks, with appropriate record entries, shall record the position of these valves before operations 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 with IWV-3410(c). In the

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above exceptions, the code permits the valves to be testeo at cold shutdown where:

a. It is not practical to exercise the valves to the position required to fulfill their function or to the partial position 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.

3. Stroke Testing of Check Valves The NRC 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 6

t tiRC) the check *alves shall be partial 't"oked. Since disk position is not always observable, the td.: staff stated that j- . verification of the plant's safety analy is design flow rate through the che a valve would be an adecpTte ':enonstration

- of the full stroke requirement. Any fire rate less than

design will be

onsidered part stroke e>.urcising unless it can be shown th1t the check valve's disk position at the lower flow rate w]uld be equivalent to 1 r greater than the design flow rato through the valve. The licensee agreed to conduct flow teit to satisfy the above position.

4. Strokt sting af Motor Operated Valves The licensee har, requested relief from the part-stroke requirement of Section XI for all power operated valves.

The licensee has stated that none of the Category A or B power operated valves identified can be part-stroked because of the design logic of the operating circuits. These circuits are such that when an open er close signal is received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other 4 direction. We find that the above relief request from part-stroking is warranted and should be granted because t;ie required function of the valves involves only full open or full closed positions.

5. Test Frequency of Check Valves Tested at Cold Shutdowns The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Category A and B valves and once every nine mc 'hs for Category C valves. It is NRC's position that the Code is inconsistent and the Category C valves should be 7

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tested on the same schedule as Category A and B valves. The licensee has agreed to modify his procedures on cold shutdowns to read, "In the case of frequent cold shutdowns, ,

valve testing will not be performed more of ten than once every three (3) months for Category N, B and C valves." -

6. Licensee Request for Relief to Test Valves at Cold Shutdown The Code permits valves to be tested at cold shutdown, and the Code conditions under which this is permitted is noted in Appendix A. These valves are specifically identified by the licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Ccae, it will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it was not practical to exercise these valves during power operation ,

and that we agree with the licensee's basis.

It should be noted that the NRC differentiates for valve testing purposes between the cold shutdown mode and the refueling mode. That is, for testing purposes the refueling mc4 9 is not considered as a cold shutdown.

7. Changes to the Technical Specifir.ation In a November 1976 letter to the licensee, the NRC provided an attachment entitled, "NRC Guidel-:nes for Excluding Exercising (Cycling) Tests of Certair. Valves During Plant Operation." The attachment stated that when one train of a redundant system such as the Emergency Core Cooling System .

(ECCS) is inoperable, nonredundant valves in the 8

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t remaining train should not be cycled if their failure in a l non-safe position would cause a loss of total system

! function. For example, during power operation in some

? wnts, there are stated minimum requirements for systems j~ wt .. allow certain limiting conditions for operation to exist at any one time and if the system is not restored to i 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 c. ode. Furthermore, prior to initiating repairs all valves and interlocks in the system that provide a duplicate functic,n are required to be tested to demcnstrate 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. It should be noted that reduction in redundancy is not a basis for a T.S.

change nor is it by itself a basis for relief from exercising in accordance with Section XI The licensee has agreed to review the plant's i.S. and to consider the need to propose T.S. changes which would have the effect of precluding such testing.

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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 f or each system that is effected which demonstrates that the valve's f ailure would cause a loss of system ,metion 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.

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8. Safesv Related Valves This review was limited to safety-related vaives.

Safety-related valves are defined as those valves that are needed to mitigate the consequences of an accident and/or to -

shutdown the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2 and 3 valves and could include some non-code Class valves.

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 progran.

9. Valve Testing at Cold Shutdown Inservice valve testing at cold shutdown is acceptable when the following conditions are met: It is understood that the licensee is to connence testing as soon as the cold shutdown condition is achieved but 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 shutdawn should be performed during any subsequent cold shutdowns that may occur before refueling to meet the Code specified testing frequency.

For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken. .

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10. Category A Valv,t.eak Check Recuirement, for Containment l Isolation Valve L(CIV)

All CIVs shall be classified as Category A valves. The Category A valec leak rate test requirenents of

. IWV-3420(a-e) have been superseded by A;,pendix J requirements for CIVs. The NRC has con <luded that the applicable leak test procedures and reg'tirements for CIVs are determined by 10 CFR 50 Appendix J. Relief from paragraph IWV-3420 (a-e) for CIVs preset.ts no safety

, problems since the intent of IWV-3420 (4-e) .is met by Appendix J requirements.

The licensee shall canply with Sections f and 9 of IWV-3420

- until relief is requested from these paragraphs. It should be noted that these paragraphs are only applicable where a Type C Appendix J leak test is performed.

Based on the considerations discussed above the NRC concludes that the alternate testing proposed above will give the reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property of the common defense and security of the public.

11. Application of Appendix J Testing to the IST Program The Appendix J review for this plant is a completely separate review from the IST program review. However, the determinations made by that review are directly applicable

! to the IST program. Our review has determined that the l current IST program as submitted by the licensee correctly reflects our interpretation of Section XI vis-a-vis j Appendix J. The licensee has agreed thats should the Appendix J progrea be amended, they will amend their IST progran accordingly.

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i B. Ay iliary Feed

1. Category C Valves ,

a. Relief Request The licensee has requested specific relief from exercising Category C valves 11-13AF53, demineralized water check valves, in accordance with the requirements of Section XI and proposed to manually full stroke exercise during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief The line in which this valve is installed is maintained empty and vented to the atmosphere. We do not fill this line except in need as it is routed through a vital relay room and a leak would cause extensive damage and trip the reactor. These valves will be manually full stroke exercised per Section XI during refueling.

E /aluation We agree with the licensee's basis and therefore eel re'ief should be granted from the Categora C valves 11-13AF53 from the exercising requirements of a

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l Section XI, The licensee has oeinoratrated that the

! only method available to axercise tuse valves is by

- disassembly and manual full stroke xercising. This

! portion of the system is normally k<pt drained and

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vented to prevent the possibility c2 leakage into the vital relay room which could resul'. in equipment damage -

and a reacMr trip. We conclude ti.at disassembly and manual full stroke exercising durir ', refueling outages should demonstrate proper valve opo ability.

b. Relief Requ;.Lst, The licensee has requested specific relief from exercising Category C valve 13AF4,113 auxiliary feed pump suction check, in accordance with the r'quirements of Section XI and proposed to p.trtial stroke during power operation and manually full stroke during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

1 Licensee's Basis for Requesting Relief l

This valve cannot be full stroke exercised during Power f

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Operation without thermal shocking the feed nozzles.

The normal feed path to the SGs is the only available full flow path. The valve cannot be tested in Cold Shutdown or Refueling because the steam must be available to drive the turbine to operate the #13

. Auxiliary Feed Pu..m to exercise 13AF4. This valve is partial stroked through the recirculation path during power operation. This valve will be manually full stroke exercised per Section XI during refueling.

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

relief chould be grantec for Category C valve 13AF4 from the eneccising requircments of Section XI. The -

licensee has denonstrated that the only available full flow path is into the steam generators which would result in thermal shocking of the feed nozzles. Only partial stroke exercising is possible during power operation due to the limited size of the pump recirculation line. Exercising during cold shutdown or refueling with auxiliary feed system flow is not possible because steam is not available to operate the turbine driven pump. We conclude that disassembly and manual full stroke exercising during refueling outages should demonstrate proper valve operability,

c. Relief Request The licensee has requested specific relief from exercising Category C valve 13AF8, #13 auxiliary feed pump discharge check, in accordance with the requirements of Section XI and proposed to manually full stroke exercise during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

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' Licensee's 3a. sis for Requesting Relief

- This valve cannot be tested durirg ;ower operation withcut tharnal shocking the feed razzles on the SGs.

It cannot 3e flow tested during co'!d shutdown or refueling because there is no stean available to drive

- the #13 Auti'iary Feed Pump Turbin. . This valve will be manually full stroke exercised par Section XI during refueling.

Evaluation We agree with the licensee's basis and therefor' feel a

relief sho91d be granted for Catego y C valve 13AF8 from the exercising requirements of Section XI. The licensee has demonstrated that the only available full flow path is into the steam generatcrs which would

- result in thermal shocking of the feed nozzles.

Exercising during cold shutdown or refueling with auxiliary feed system flow is not possible because steam is not available to operate the turbine driven pump. We conclude that disassembly and manual full i

stroke exercising during refueling outages should demonstrate proper valve operability.

C. Chemical and Volume Control

1. Category C Valves

! a. Relief Request The licensee has requested specific relief from exercising Category C valve ICV 196, chemical addition tank outlet. check, in accordance with the requirements of Section XI.

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t Code Requireme t Rafer to valve testing paragraph A. 2. ,

Licensee's Easis for Requesting Relief .

This valve is passive, normally closed und not required to change position to perform it's safety function.

Evaluation i

We agree with the licensee's basis and therefore feel relief should te granted for Category C valve ICV 196 from the exercising requirements o'Section XI. This valve is in it's safety related prisition and not I

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 it performs. We conclude thai quarterly stroke exercising l

j is meaningless for passii,e valves.

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1. Category C Valves

a. Relief Request The licensee hac requested specific relief from exercising Category C valves11-22CS4 and 11-12CS48, I containment spray discharge header check valves, in accordance with the requirements of Sectico XI and 1

proposed to exercise these valves during refueling outages. l 1

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

Licensee's 8psis for Requesting Relief _

These va'Ives cannot be exercised dt. -ing power operation or cold shutdown without spraying c:.'wn the containment, causing equipment and lagging damag2 requiring extensive cleanup and repair. The full flow test connection is connected to the refooling cavity and can only be used during refueling.

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We agree with the licensee's basis and therefore feei relief should be granted for Category C valves11-12CS4 and 11-12CS48 from the exercising requirements of Section XI. The licensee has demonstrated that exercising these check valves auring power operation or cold shutdown is not possible without spraying borated water into the reactor containment building resulting in lagging and equipment damage. The licensee has proposed to full stroke valves11-12CS4 and 11-12CS48 during refueling outages when a test spool piece can be installed and the borated water discharged to the reactor refueling cavity. We conclude the-licensee's proposed alternate testing frequency should be sufficient to ensure proper valve operation.

b. Relief Request The licensee has requested soecific relief from exercising Category C valve 11-12CS21, spray additive tank checks, in accordance with the requirements of Section XI and p.roposed to partial stroke exercise quarterly.

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

Licensee's Basis for Requesting Relief The safety-related position is open to allow the caustic solution in the spray additive tank to be educted into the C.Sc system and sprayed into the centainment. Only partial stroke is possible due to the liniited size of the recirculation line.

Evaluation We agree with the licensee's basis and therefore feel tempora y relief should be granted for Category C valves11-12CS21 from the full stroke exercising requirements of Section XI. We conclude that with the ,

present piping configurations, only partial stroke exercising of these valves is possible. However, we recommend that the licensee further investigate a method to full stroke e.,ercise these valves, i.e.,

manual exercising during refueling outages.

E. Main Steam

1. Category B Valves

a. Relief Request The licensee has requested specific relief from exercising Category B valve 1 MSS 2, auxiliary feed pump ,

turbine steam supply valve, in accordance with the

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, requirements of Section XI.

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i Code Requirement

. Refer to v ilve testing paragraph A. ?.

Licensee's Basis for Requestin, Relief This is a passive valve. It is al says in the position required 11 allow the pump to operite during an incident.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category B salve IMS52 from'the e<ercising requirements of Section XI. This valve is in it's 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 conclLae that the quarterly stroke and stroke time measurements are meaningless,for passive valves.

b. Relief Request The licensee hus requested specific relief from stroke timing Category B valve IMSS3, auxiliary feed pump turbine governor valve, in accordance with the requirements of Section XI.

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v Licensee's Basis for Requesting Relief a Stroke time does not provide any meaningful data for .

valve degradation. Proper valve operation is verified through normal system operation 'during the auxiliary feed pump test.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category B valve IMS53 from the stroke timing requirements of Section XI. The licensee has demonstrated that stroke timing a medulati,1g valve will not provide any meaningful data for valve degradation. We conclude that verifying proper system operation is the most practical method of ensuring proper modulating valve operability.

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I The licensee has requested specific relief from exercising and stroke timing Category B valves11-14MS168, MSIV three-way pilot valves, in

, accordance with the requirements of Section XI.

Code Requirement t

Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief This is a passive valve always maintained in its .

safety-related position (i.e., open to the MS169s and HS171s). - l l

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i Evaluation I

. We agree with the licensee's basis ar:d therefore feel

[. relief should be gran!.ed for Categc y B, valves 11-14!!S168 from the requiree'nts of Section XI.

These valves are in their safety related position and are not re<iuired to open or close t.. mitigate the l consequences of an accident or safely shut down the plant. Thr.refore, the operability of these valves is inconsequential with regard to the iafety function which they perform. We conclude that the quarterly j stroke and stroke time measurements are meaningless for

. passive valves.

F. Nitrogen

1. Category A/C Valves

. a. Relief Request j

! The licensee has requested specific relief from exercising Category A/C valve INT 26, pressurizer relief tank nitrogen supply check, in accordance with the requirements of Section XI.

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

Licensee's Basis for Requesting Relief i

This valve has no position indication and is located

, inside the containment. This valve can only be

[. verified shut during refueling.

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Evaluation i

We agree with 1:1c licensee's basis and therefore feel .

relief should be granted for Category A/C valve INT 26 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 ouring leak tescing. This

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valve is not equipped with valve position indication and some of the required 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 denonstrate proper valve operability.

G. Residual Heat Removal System

1. Category C Valves

a. Relief Request The licensee has requested specific relief from exercising Category C valves 13-14RH27, hot leg injection checks, in accordance with the requirements of Section XI.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief ,

This is a passive valve. During an incident LPSI is through another path, s

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Evaluation

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. We agree with the licensee's basis :nd therefore feel relief should be granted for Catege y C, i - valves 13-)4RH27 from the exercisita requirements of Section XI. These valves are in ti. air safety related positions ad are not required to exn or close to mitigate th: consequences of an accident or safely shut down the plant. Therefore, the operability of these j valves is inconsequential with rega d to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are

meaningless for passive valves.

H. Safety Injection J .

I 1. Category C Valves I

I a. R_elief Request The licensee has requested specific relief from exercising Category C valves 11-14SJ17, and ISJ150, safety injection to the reactor coolant system, in l accordance with the requirements of Section XI and proposed to exercise these valves during refueling.

1 Code Requirement i

Refer to valve testing paragraph A. 2.

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Licensee's Basis for Requesting Relief For power operation, testing would require pumping i 2,000 ppm borated water into the RCS. This would render the reactor subcritical and would also violate d

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4 Technical Specification LC0 3.5.4.1. Foc cold shutdown, testing would ultimately require significant l

RCS dilution and boric acid recovery operation. It -

would also present a possible low-tenperature RCS overpressurization and would violate Technical Specification 3.5.4.1. and certain operating procedures. These valves will be exercised during

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refueling per Section XI.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category C valves 11-14SJ17 and ISJ150, from the exercising requirements of Section XI. The licensee has i

demonstrated that exercising these valves during power ,

operation would require injecting 2000 ppm borated water into the reactor system and would result in -

, reactor shutdown. These valves cannot be exercised during cold shutdown without the possibility of creating a low tenperature-overpressurization condition in the reactor coolant i,yst .<n. In addition, injecting 2000 ppm boron into the reactor system could delay reactor startup due to the extensive cleanup required to return reactor systen chemistry to operating s pecifications . We conclude that exercising these valves during refueling outages when an expansion volume is available and chemistry requirements do not restrict reactor operation should demonstrate proper valve operability.

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b. Relief Request

, . The licensee has requested specific relief from exercising Category C valve ISJ31, safety iniection suction check, in accordance with the requirements of Section XI and proposed to partial stroke during power operation acd full stroke exercise during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

I Licensee's Basis for Requesting Relief Only partial stroke is possible due to design of the

. recirculation line. Flow to loop cannot be done at power operation because the RCS pressure is greater than safety injection pump shutoff head. During cold shutdown, the possibility of a low temperature overpressurization of the RCS exists. This valve will be full stroke exercised during refueling.

Evaluation We agree with the licensee's basis and feel relief should be granted for Category C valve ISJ31 from the exercising requirements of Section XI. The licensee has denonstrated that the only available full flow path is into the reactor coolant system and is not possible during power operation because the safety injection pumps cannot overcome RCS pressure. Only partial stroke exercising is possible during power operation due to the limited size of the pump recirculation line.

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This valve cannot be full stroke exercised during cold shutdown without the possibility of creating a low temperature-overpressurization condition in the RCS. -

We conclude that full stroke exercising this valve during refueling outages when an expansion volume is -

available should demonstrate proper valve operability.

c. Relief Request The licensee has requested specific relief from exercising Category C valves 11-12SJ34, safety injection pump discharge checks, 11-14SJ139, 11-14SJ156, safety injection hot leg injection checks, and 11-14SJ144, safety injection cold leg injection checks, in accordance with the requirements of Section XI and proposed to full stroke these valves during refueling.

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

Licensee's Basis for Requesting Relief During power operation, testing is not possible since RCS pressure is greater than safety injection pump shutoff head. During cold shutdown, the possibility of a low temperature-overpressurization of the RCS exists. These valves will be full stroke exercised during refueling outages.

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.,.a- .

Evaluation

. We agree with the licensee's basis and therefore feel relief should be granted for Category C valves 11-12SJ34,11-14SJ139,11-14 SJ156, and 11-14SJ144 from the exercising requirements of l Section XI. The licensee has demonstrated that the only available full flow path is into the reactor coolant system and is not possible during power operation because the safety injection pumps cannot

overcome RCS pressure. These valvt s cannot be full stroke exercised during cold shutd.4n without the possibility of creating a low temparature-overpressurizatfon condition in the RCS, We conclude that full stroke exercising these valves during

, , refueling outages when an expansion volume is available should demanstrate proper valve operability.

7 d. Relief Reouest The licensee M s requested specific relief from exercising Category C valves 11-14SJ55, safety

, accumulator discharge checks, in accordance with the requirements of Section XI and proposed to partial

., stroke during refueling.

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief During power operation the RCS pressure is greater than

- accumulator pressure. During cold shutdown, testing of i

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this valve by a cumulator discharge could result in low temperature-overpressurization of the RCS. These valves will be part stroke tested during refueling per .

l Section XI.

Evaluation a

We agree with the licensee's basis and f eel temporary relief should be granted for Categcry C valves 11-14SJ55 from the exercising requirements of Section XI. The licensee has demonstrated that the only available full flow path is into the reactor coolant system and is not possible during power operation because the safety accumulator pressure cannot overcome RCS pressure, a

These valves cannot be full stroke exercised during

cold shutdown without the possibility of creating a low ,

temperature-overpressurization condition in the RCS.

We conclude that with the present piping configuration, only partial stroke exercising of these valves is possible. However, we recomend that the licensee further investigate a cethod to full stroke exercise these valves.

! e. Relief Request The licensee has requested specific relief from exercising Category C valve 1SJ70, RWST to LFSI pump suction check, in accordance with the requirements of Section XI and proposed to partial stroke exercise during power operation and full stroke during refueling, ,

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l Code Requirement i . Refer to valve testing paragraph A. 2.

l- Licensee's Basis for Requesting Relief Only part stroke exercising is possible during power l operation due to the limited size of the recirculation i

line and because LPSI pump discharse cannot overcome l RCS pressure. This valve will be full stroke exercised during refueling when the LPSI pump discharge can be lined up to fill the reactor cavity.

Evaluation We agree with the licensee's basis .and therefore feel relief should be granted for Category C valve ISJ70

. from the exercising requirements of Section XI. The licensee has demonstrated that the only full flow path available is into the reactor coolant system and 's not possible curing power operation because LPSI (RHR) pump discharge pressure cannot overcome reactor coolant system pressure. This valve cannot be full stroke sercised during power operation due to the limited size of the recirculation line. This valve cannot be full stroke exercised during cold shutdown without the possibility of creating a low temperature-overpressurization in the RCS. We conclude that full stroke exercising during refueling when the vessel head is removed and the refueling cavity is being filled (this provides an adequate expansion volume) should <

demonstrate proper valve operability.

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I. Soent Fuel Cooling I

1. Category A/E Valves .

a. Relief Request -

The licensee has requested specific relief from exercising Cattgory A/E valves ISF22 and ISF36, spent fuel co~oIINg' isolation valves, in accordance with the requirements of Section XI.

Code Requirement Refer to valse testing paragraph A. 2.

Licensee's Basis for Requesting Relief .

Passive valves not required to change position to .

fulfill their function. Valves are kept locked shut per Technical Specification 3.6.3.1, Tcble 3.6-1.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A/E valves ISF22 and ISF36 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.

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J. Station Air (Compressed Air)

.- .. Category A/E Valves

a. Relief Recuest i

The licensee has requested specifit. relief from

} exercising Category A/E valve IcA113, station air l containment isolation valve, in accordance with the requiremer.ts of Section XI.

Code Requirement 4 Refer to ulve testing paragraph A. 2.

5 Licensee's Basis for ilequesting Relief 1 ,

1 2 .

Passive valve not required to change position to j fulfill it's function. Valve is locked shut per 3

Technical Specification 3.6.3,1, Table 3.6-1.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A/E valve 1SA118 from the exercising requircnents of Section XI. This J

valve is in it's 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 4 -

passive valves.

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K. Waste Disposal - Liquid

1. Category A/[# Valves .

a. Relief Request The 1. caee has requested specific relief from exercising Category A/E valves 1WL190 and 1WL191, reactor cavity to spent fuel cooling pump containment isolation, in accordance with the requirements of Section XI. .

Code Requirement Refer to valve testing paragraph A. 2.

Licensee's Basis for Requesting Relief Passive valves not required to change position to fulfill their function. Valves are kept locked shut per Technical Specification 3.0.3.2.d, Table 3.6-1.

Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A/E valves 1WL190 and 1WL191 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 val,es.

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IV. A_tj ;chment I

, . A. The following Catenory A, A/C and A/E valves 1 e currently being i

leak tested per Technical Specification 4.6.1.2.d (Appendix J) instead of Section XI.

ICV 3, 4, 5, and 7, r eactor coolant letdown ic olations 1CV68 and 69, regen last exchanger isolations ICV 74, regen heat ex( ianger ' isolation ICV 116 and 284, RCP seal water isolations I 1CV296, seal water line overpressure protecticn isolation ICC113 and 215, excess letdown isolations ICC117,118,131,136,187 a1d 190, CC to RCP isolations ICC186 and 208, overpressure protection isola; ions 11 and 12CA330, control air isolations 1DR29, demin water isolation 1FP147, fire protection isolation

- 11-14GB4, S/G drain and blowdown isolations INT 25 and 26, pN to the PRT isolations INT 32, 2N to S.I. accumulators isolation IPR 17 and 18, PRT and gas analyzer isolations l ISJ53, 60, and 123, S.I. test line 15527, 33, 49 and 64, primary sampling isolations 155103,104,107, and 110, primary sampling isolations 4

11-14SS94, S/G drain and blewdown isolations IVC 1-6, containment ventilation isolations IVC 7, 8,11, and 12, contaiiment sample isolations 1WL96 and 97, RCDT sample isolations 1WL98, 99, and 108, PRT to waste gas isolations 1WL12 and 13, RCDT pump isolations  ;

IWL16 and 17, conteicment sump pump isolations

. 1WR80 and 81, PRT supply and RCP head tank isolations 33 l

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B. Tba following Category A, A/C, and A/E valves are currently

exempted from leak rate testing by Technical Specification I

Table 3.6-1. -

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11-14CV98, RCP seal water throttle valves

11-145593, S/G sample isolations 1SF22 and 36, spent fuel cooling isolations

ISA118, station air isolation 1WL190 and 191, reactor cavity to SPC pump isolations i

C. The folicwing valves should be reviewed by the NRC Appendix J review committee to determine if they should be categorized A, A/C or A/E and tested in accordance with the requirements of Section XI.

! IVC 9,10,13 and 14, containment sample isolations. (These valves are currently exempted from leak testing by Technical Specification.)

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1 V. f(lachmentII

. . T e f)llowing are Categor v 4, B, and C valves thct meet the requirements of the ASME : ode Section XI and are sat full stroke erfcised every three months during plant operatir1. These valves are s rifically identified tj the owner and .:re full stroke exercised i d ring cold shutdowns and refueling outages. EG&D has reviewed all i

v,1ves i ...is attachment and agrees with the licensee that testing t ese valves during power o? erat}'on is not possible due to the valve t 3ne and location, system design, or because this action would place t1 a plant in an unsafe co1dition. We feel these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.

A. Auxiliary Feed

1. Category C/E velves 11 through 14AF23, cuxiliary feedwater

. header checks, cannot be exercised during power operation.

Exercising these valves with cold auxiliary feedwater would thermal shock the feed nozzles resulting in nozzle daaage.

These valves are full stroke exercised during cold shutdown.

1

2. Category C valves 11-12AF4 and 11-12AF8, auxiliary feed pump suction and discharge checks, cannot be full stroke exercised during power operation. The only available full flow path is into the steam generators. Exercising these valves with cold auxiliary feedwater would thermally shock the feed nozzles resulting in feed nozzle damage. 11-12AF4 are partial stroke exercised during power operation through the recirculation test line. All valves are full stroke exercised during cold shutdown.

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B, 5 team Generator Feed and Condensate 4

1 Category C/E valves 11 through 14BF22, feedwater header .

checks cannot be exercised during power operation.

Exercising these valves would require 3 loop reactor -

operation which is not permitted and a reactor trip is required. These valves will be full stroke exercised during cold shutdowns, i

C. Chemical and Volune Control

1. Category A valve ICV 7, reactor coolant letdown containment isolation, cannot be exercised during power operation.

Exercising this valve would isolate normal letdown flow through the regenerative heat exchanger causing the injection of cold water into the RCS resulting in thermal .

cycling of injection nozzles and possible cracking damage.

This valve is full stroke exercised during cold shutdown. .

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2. Category A valves ICV 68 and 69, regenerative heat exchanger containment isolations, cannot be exercised during power operation. If these valves failed shut during testing, loss of pressurizer level control would result requiring a reactor trip. These valves are full stroke exercised during cold shutdown.

3. Category A valves ICV 116 and 284, reactor coolant pump seal water containment isolations, car.not be exercised during power operat!on. Shutting these valves would cause an RCP trip which would then cause a reactor trip. These valve, will be exercised during cold shutdown. I 36

. .. - __ -. . - .- . _ - - - ~ _ .

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4. Category A/C valve ICV 74, regenerative h;at exchanger l

containment isc ation, cannot be exercised d ring power ,

. operation. Shu ting this valve during :>wer operation would l

cause a loss of pressurizer level contrui anc a reactor trip j~ would result. This valve is full stroke exercised during

! cold shutdown.

i i 5. Category A/C valve ICV 296, RCP seal return line overpressure protection contairment isolation, cannot be isolated during

', power operation w thout tripping an RCP which will cause a 4

reactor trip. This valve cannot be shut without shutting j 2CV284. This valve is full stroke exercised during cold shutdown.

6. Category B valves ICV 41 and 42, VCT outlet isolations, cannot be exercised during power operation. Closing these valves during power operation requites lining up the

. alternate source of water from the refueling water storage tank to the suction of the charging pumps. This is i

2,000 ppm borated water which would render the reactor subcritical. These valves are exercised during cold i shutdown.

7. Category C valve 1CV42, VCT outlet suction check, cannot be i exercised during power operation. Exercising (clesing) would result in a loss of normal makeup to the RCS, pressurizer level control, and RCP seal flow. This would require a reactor trip. Use of the only alternate suction for the charging pumps, the RWST, which is water borated to approximately 2000 ppm, would result in a reactor shutdown.

This valve is full stroke exercised during cold shutdown.

D " ]D ]D ' T ] @

ooM d 1 1 1 Lrd o f

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8. Categcry C valves il through 14CV99, RCP seat water check valves, and cateJory A/E valves 11-14CV98, RCP seal water throttle valses, cannot be exercised during power operation -

without securing seal water to an RCP resulting in a loss of an RCP and requiring a reactor trip. These valves are ful!

• stroke exercised during cold shutdown.

9. Category C valve ICV 176, rapid boration check, cannot be

, exercised during power operation. Testing during power operation would require injecting highly borated water into the RCS resulting in a reactor shutdown. This valve is full stroke exercised during cold shutdown.

D. Component Cooling

1. Category A valves ICC117, 118, 131, 136, 187, and 190, CC to .

RCP supply and return containment isolations, cannot be exercised during power operation because if the valves f ailed shut a loss of RCP cooling would occur requiring the RCP be secured and thus requiring a reactor trip. These valves are exercised during cold shutdown when RCPs are secured.

2. Category A/C valves ICC186 and 208, overpressure protection for containment isolation piping, cannot be exercised during power operation without isolating CC to RCPs requiring RCPs to be secured which would result in a reactor trip. These valves are full stroke exercised during cold shutdown when RCPs are secured.

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E. Containnent Spray 4

- 1. Category B valvas 11 and 12CS36, LPSI to containnent spray, cannot be exercised during power operation. These valves are interlocked shut with 11 and 12SI44. containment sump i suction isolations. These valses are full stroke exercised during cold shutdown.

F. Main Steam

1. Category B valves,11 through 14MS167, main steam isolation valves, and 11 through 14MS169 and 11 through 14MS171, backup valves for shutting main steam isolations, cannot be exercised during power operation. Shutting one main steam 1 valve will cause a steam flow / feed flow mismatch in the corresponding SG because the steam flow would go to zero.

This would cause a reactor trip. Testing the shutting

- backup valves would result in the associated ma'.. steam isolation valve closure. These valves are full stroke

exercised during the startup following cold sh atdown.

G. Residual Heat Removal i

j 1. Category B valves 1RH1 and 2, RHR injection hot leg isolations, cannot be exercised during power operation.

These valves are pressure interlocked shut and cannot be

opened when RCS pressure is greater than 590 psig. These valves are full stroke exercised during startup following a

cold shutdown.

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P. Category B valve IRN26, RHR to hot leg isolction cannot be exercised during power operation because valve is shut with power removed (per Technical Specification 4.5.2) to prevent -

] overpressurization of the RHR sytem (low pressure SI system). Also if the valve f ailed open, flow would be diverted from the injection flow path. This valve will be full stroke exercised during cold shutdown.

3. Category C valves 11 and 12RH8, RHR (LPSI) pump discharge checks, cannot be full stroke exercised during operation.

To full stroke exercise these valves at power operation requires opening valve IRH21. Should this valve f ail while open or should an incident occur while testing, too much water would be diverted from the LPSI to provide sufficient cooling. These valves will be part stroke exercised during power operation and full stroke exercised at cold shutdown ,

and refueling.

H. Safety Inje;iion

1. Category B valves ISJ1 and 2, RWST to charging pump suction isolations, cannot be exercised during power operation without injecting 2000 ppm boron into the RCS resulting in a reactor shutdown. These valves will be exercised during cold shutdown.

2. Category B valves ISJ4 and 5, BIT inlet isolations, cannot be exercised during power operation. Opening these valves during power operation would dilute the BIT below 20,100 ppm boron, the concentration required by Techncial Specification 3.5.4.1 to ensure safe plant shutdown of the reactor during an incident. These valves will be exercised during cold shutdown.

40

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- - .. = _ . ._ . -. . _ . - - ._

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3. Category B valve ISJ30, RWST to SI pump suction isolation, cannot be exercised during power operation. Stroking this

. valve requires isolating the suctions of both safety injection pumps from the RWST. Failure of this valve would disable 'ath ECCS trains. This valve is full stroke exercised during cold shutdown.

4. Category B valves 11 and 12SJ44, SI pump suction containment isolations, cannot be exercised during power operation because if a valve f ailed, containment integrity would be breached to initiate a repair to the valve and the reactor would have to be shut down. These valves will be exercised during cold shutdown.

1

5. Category B valves 11 and 12SJ45, LPSI pump discharge to the SI and HPSI pumps, cannot be exercised during power operation because the 11 and 12SJ44 must be opened to exercise these valves due to interlocks between them. See relief request for 11 and 12SJ44. These valves will be exercised during cold shutdown.

6. Category B valve ISJ69, LPSI pumps suction isolatios, cannot be exercised during power operation. This is a passive valve always maintained in the open position (Technical Specification 4.5.2 requires this valve to be open with the power re11oved during power operation). Failure of this valve in the closed position during testing would render the RHR (LPSI) system inoperable. This valve will be exercised during the startup following cold shutdown.

7. Category B valve ISJ135, SI pump discharge to RCS cold legs, cannot be exercised during power operation because if it f ails shut during testing cold leg injection would be isolated. This valve will be full stroke exercised during cold shutdown. l 41 l

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8. Category B valves 11 through 14SJ54, accumulator outlet

! isolations, cannot be exercised when the accumulators are at

normal pressure and the RCS is 1000 psig to prevent a .

j possible low tepoerature-overpressurization of the RCS.

These valves will be stroke timed and exercised while:

]

a. The accumulatoes are at normal pressure and RCS l 1000 psig.

j b. The accumulators are depressurized and the RCS is j 1000 psig.

i

9. Category C valve ISJ3, prevent backflow from the VCT to the RWST check, cannot be exercised during power operation. In I order to test this valve ISJ1 or ISJ2 must be opened. ISJ1

and 2 cannot be exercised during power operation without ,

injecting 2000 ppm boron into the RCS resulting in a reactor shutdown. This valve will be full stroke exercised during .

j cold shutdown.

10. Category C valves 11-14SJ56, safety accumulator, RHR/LPSI header checks, cannot be exercised during power operation because these systems cannot ovtrcome RCS operating pressure. These valves will be t ull stroke exercised during cold shutdown when the RHR system is in service.

11. Category C valves 11 through 14SJ43, RHR/LPSI header checks, cannot be exercised during power operation because the Rhn/LPSI pumps cannot overcome RCS pressure. These valves are full stroke exercised during cold shutdown when the RHR

system is placed in service.

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I. Service Water

. 1. Category C valves 11 and 12SW51, backflow preventors from

.! the containment f an coil units to the nuclear service water l

header, cannot be exercised during power operation. Testing these valves reauires. isolating service water to 2 f an coil units. This places the plant in a limiting condition for operation (Technical Specification 3.6.2.3). These valves will be full stroke exercised during cold shutdown.

2. Category C valves 11 and 125W79, service water overload discharge checks, cannot be exercised during power operation

because both nuclear headers are required (Technical I Specificatica 3.7.4.1). If these valves failed shut while l exercising, a plant shutdown would be required. These valves are full stroke exercised during cold shutdown.

I J. Ventilation Containment

1. Category A valves IVC 1 through 6, containment ventilation isolations, need not be exercised during power operation.

These valves are passive during power operation. They cannot be opened per commitment to NRC in LER 50-272/79-55/01T. These valves will be exercised during cold shutdown.

t 4

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VI. Attact3cnt III The P&I0s listed below were used during the course of this review. .

System P&ID_

Rev.

Auxiliary Feedwater 205236 4 i

Steam Generator Feed and Condensate 205202 10 Chemical and Volume Control, Boric Acid 205?29 7 Recovery Chemical and Volume Control Operation 205228 8 Chille.1 Water 205?16 12 Component Cooling 205231 10 Containment Spray 205235 6 Reactor Containment and Penetration 205247 12 Area Control Air 4 Demineralized Water Restricted Areas 205?46 6 Fire Protection 205?22 9 Steam Generator Drains and Blewdown 205225 7 Main Reheat and Turbine Bypass Steam 205203 12 Reactor Coolant 205201 9 .

Residual Heat Removal 205232 6 Satety Injection 205234 10 Sampling 205244 5 Service Water Nuclear Area 205242 11 Spent Fuel Cooling 205233 6 Compressed Air 205217 9 Reactor Containment Ventilation 205238 8 Waste Disposal liquid 205239 8

! Chemical and Volume Control, Primary 205230 7 Water Recovery 44

VII. Attachment IV i A. The following valves are never full stroke exercised or have a testing frequency greater than each refueling outage:

1.11-12CS21, Spray additive tank checks U-14SJ55, Safety accumulator discharge checks

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