ML19347E927
| ML19347E927 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/30/1981 |
| From: | Fehringer J, Rockhold H EG&G IDAHO, INC., EG&G, INC. |
| To: | Nerses V Office of Nuclear Reactor Regulation |
| References | |
| CON-FIN-A-6258 EGG-EA-5415, NUDOCS 8105140297 | |
| Download: ML19347E927 (39) | |
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INTERIM REPORT Accession No.
Report No. EGG-EA-5415 i-Contract Program or Project
Title:
Systems Engineering Support Subject of this Document Safety Evaluation of the Inservice Testing Program for Pumps and Valves at the Surry Power Station Unit 1 (Docket No. 50-280) for the Period 8-1 4-30-81
.and Surry Power Station Unit 2 (Docket No. 50-281) for the Period 1-1 8-31-82.
Type of Document:
Safety Evaluation Report Author (s):
J. M. Fehringer H. C. Rockhold
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XRC Researc'1 am Tec'anical April 1981 Assistance Repor: '
Responsible NRC Individu'ai 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 uccument should not be considered final.
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 INTERIM REPORT BMMO9'7
o CONTENTS I. I N TRO D U C T I O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. ~ PUMP TESTING PROGR AM EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
- 1. High'Hea'd Safety. Injection ................................. 2
- 2. Low Head Safety Injection ................................... J2
- 3. -Outside Re:irculation' Spray-................................ 3 0
- 4. Insid. Recirculation Spray ................................. 3
- 5. Component Cooling .......................................... 4
- 6. Boric Acid Transfer ........................................ 5 r
- 7. Charging Pump Cooling Water ................................ .5
- 8. Charging Pump Service Water ................................ 6
- 9. Eme rg e n cy Se r v i c e W at e r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 ,
III. VALVE TESTING PROGRAM EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
- 1. Gene ra l Con s i de rat i on s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1
l 1.1 Testing of Valves which Perform a Pressure Isolation Function ................................... 8 l 1.2 ASME Code,Section XI, Requirements .................. 9 1.3 Stroke Testing of Check Valves ....................... 9
! 1.4 Stroke Testing of Motor-0perated Valves .............. 10 l.5 Test Frequency of Check Valves Tested at Cold Shutdowns ....................................... 10 1.6 Licensee Request for Relief to Test Valves at Cold Shutdowns .................................... 10 1.7 Changes to the Technical Specifications .............. 10 1.8 Safety-Related Valves ................................ 'll
, l.9 Valve Testing at Cold Shutdowns ...................... 11 1.10 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIVs) .............. 12 1.11 Application of Appendix J Testin l
the IST Program ................g to
...................... 12 t
- 2. Aux i l i ary Steam and Ai r Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . .- 12 l
. 2.1 Category A/C Valves .................................. 12
- 3. Component Cooling .......................................... 13 3.1 Category B Valves .................................... 13 ii i
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_e '4.' ~ j Ve n t s L a nd D ra l A s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . 13 .
c 4.1 iCategory.A/E Valves ............................... .. 13
- 5. Containment and Recirculation Spray ........................ 14 5.1 = Catego ry. A, A/E, and A/C Valves . . . . . . . . . . . . . . . . . . . . . . 14
. 6. Containment' Vacuum and-Leakage Monitoring .................. -lS -
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.6.1 Category A and A/E Val ves ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . ' 15
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-0 ; 7. : Reactor ~ Coolant ............................................ 15
'7.1 Category A/C Valves .................................. 15
- 8. Chemical and-Volume Control ................................ 16 8.1 Category A Valves .................................... 16 .;
8.2- Category C. Valves .................................... 17 ;
- 9. Safety Injection ........................................... 17 9.1 Category A, A/C, and.A/E Valves ...................... 17 9.2 Category C Valves .................................... 19
- 10. Ge ne r i c R e l i e f s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
> o 10.1 Solenoid- and Air-0perated Valves .................... 22
- 11. : Purge and Ventilation ..................,................... *1 c
11.l~ Category A Valves .................................... 23 IV. APPENDIX A .................. ................................... 24
! . l .- Code Requirement--Valves ................................... 24 2
- 2. . Code Requirements--Pumps ................................... 24 V. ATTALHMENT I .................................................... 25
- 1. Main Steam ................................................. 25 i
, 'l.1 Category B Valves .................................... 25 1.2 Category C Valves .................................... 25
- 2. Feedwater .................................................. 25
- 2. l ' Category C Valves .................................... 25
- 3. S e rv i c e W a t e r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 3.1 Category 8 Valves .................................... 26 iii
- 4. LComponent Cooling 1.......................................... 26- t
' 4.1; Category C Valves .................................... "26'
~ 5 .~ - Chemical and Volume Control ................................ E26 ,
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5.1 . Category A Va1ves'.................................... 26 5.2 ' Category B Va1ves .................................... 27
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- 6. S)fetyLin.jection .............................'............. 27' .
6.1 Category A Valves ........................'............ 27 ,
6-6.2- Category B Valves .......................;............ 27
- 7. L R W S T C ro s s -T i e . . . . . . . . . . . . . . . . . . . . . . . . . . . ~. . . . . s . . . . . '. . . . . . . 28 7.1 Category.C. Valves .................................... 28- .
-8. S te am Ge ne rato r B lowd own . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 128 :
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'8.1 C a t eg o ry B Va l ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - 12 8 t VJ. ATTACHMENTLII ......~............................................. 29-VII. ATTACHMENT III .................................................. 30 VIII. ATTACHMENT IV ................................................... 31 .
- IX. ATTACHMENT V .................................................... . ,
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I. INTRODUCTION.
Contained herein is a safety evaluation of the pump and valve inservice
.- testing (IST) program submitted by the Virginia Electric and Power Company on 5-17-79 for its Surry Power Station Unit 1 and on 9-28-79 for its Surry Power Station Unit 2. . The program applies to Unit 1 for the period 8-1-79 through 4-30-81 and to Unit 2 for the period 1-1-80 through 8-31-82. The working session with Surry Power Station' and Virginia Electric and Power Company representatives was conducted on ~4-15/16/17-80. The licensee resub-o- mittal was issued on 12-15-80 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 Sciler and Pressure Vessel o- Code,Section XI, 1974 Edition, through the Summer of.1975 Addenda.
Virginia Electric and 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 evalua!'on of the pump testing program and associated relief
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requests is contained in Section II; the evaluation of the valve testing program and associated relief requests is contained in Section III. All-evaluations for Sections II and III are the recommendations of EG&G Idaho, Inc.
A summary of pumo and valve testing requirements is contained in Appendix A.
Category A, B, and C valves that meet the requirements of the.ASME Code,Section XI, and are not exercised every three months are Contained in Attachment I.
Appendix J valves and valves that should be reviewed by the NRC Appen-cix J review committee 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 requests with insuf-ficient technical basis where relief is not recommended are summarized in Attachment III A listing of P&I0s used for this review are contained in Attachment IV.
Items discussed with the licensee which may appear as diffeences between this report and the Surry Power Station Units 1 and 2 IST Program are discussed in Attachment V.
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II. PUMP TESTING PROGRAM
. The IST program submitted by Virginia Electric and Power Company for its Surry Power Station Units 1 and 2 was e'xamined to verify that Class 1, 2, and 3 safety-related pumps were included in the. program and that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that Class 1, 2, and 3 safety-related pumps
- were included in the IST program and, except-for those pumps identified '
below for which specific relief from testing has been requested, the pump tests and frequency of testing comply with the code. Each Surry Power Station basis for requesting specific relief from testing pumps' and the EG&G' evaluation of that request is summarized (Sections 1 through 9) below~-
and grouped according to the system in which the pumps reside. .
- 1. High Head Safety Injection 1.1 Relief Request The licensee has requested specific-relief from measuring inlet pres-sure (Pj) for the HHSI pumps 1/2-CH-P-1A, B, and C-in accordance with the requirements of Section XI and proposed to observe VCT pressure to assure repeated initial test conditions.
1.1.1 Code Requirement. Refer to Appendix A.
1.1.2 Licensee's Basis for Requesting Relief. Suction pressure instrumentation is net installed nor required. These pumps are capable of'
. proaucing greater then '2400 psig discharge pressure, while the suction pressure is nominally 15 to 20 psig. Therefore, the AP developed by the pump is more than 100 times the suction pressure and a gage for suction pressure would not provide significant data. We propose to observe VCT pressure using control room indication to assure repeated initial conditons for testing the pumps. This indication is approximately 4% accurate.
1.1.3 Evaluation. We agree with the licensee's basis and, therefore, fer chat relief should be granted for the HHSI plumps 1/2-CH-P-1A, B, and C from the Section XI requirement to measure Pj . The licensee had demon-strated that, since no suction pressure instrumentation is installed, obser-ving VCT pressure to establish repeated test Conditions is an acceptable alternative. We conclude that observing VCT pressure to establish repeated test conditions for Pj and measuring all other parameters required by Section XI should provide sufficient data to determine any pump degradation (the intent of Section XI).
, 2. Low Head Safety Injection 2.1 Relief Request The licensee had requested specific relief from measuring inlet pres-sure (Pj) for the LHSI pumps 1/2-SI-P-1A and B in accordance with the requirements of Section XI and proposed to establish a reference level in the RWST to assure repeated test conditions.
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2.1.1 Code Requiremen . Refer to Appendix A.
2.1.2 Licensee's Basis for Requesting Relief. No inlet pressure instrumentation is installed for these pumps that take a suction from the RWST for performance testing. This tank has a minimum lavel required by the technical specifications which is observed from the contNI room. Tank level will be used to establish initial conditicns for testing.
?.l.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief snould be granted for the LHSI pumps 1/2-SI-P-1A and B from the Section XI requirement to measure Pj. The licensee has demon-strated that, since no suction pressure instrumentation is installed, o observing RWST level to establish repeated test conditions is an acceptable alternative. We conclude that observing RWST level to establish repeated test conditions for Pj and measuring all other parameters required by Section XI should provide sufficient data to determine any pump degradation (the intent of Section XI).
- 3. Outside Recirculation Spray 3.1 Relief Request The licensee has requested specific relief from measuring inlet pres-sure (Pj ) for the outside recirculation spray pumps 1/2-RS-P-2A and B in accordance with the requirements of Sectior: XI and proposed to assure repeated test conditions by filling the pump casing to the same level for each test.
3.1.1 Code Requirement. Refer to Appendix A.
3.1.2 Licensee's Basis for Requesting Relief. These pumps are flow
-tested at shut of head (as required by T.S. 4.5.A.3) by filling pump casings with water and running them on recirculation flowpath. Suction pressure is the same for each test (head of water with casing filled) and thus will not be measured.
3.1.3 Evaluation. de agree with the licensee's basis and, therefore, feel that relief should be granted for the outside recirculation spray umps 1/2-RS-P-2A and B from the Section XI requirement to measure P .
he licensee has demonstrated that repeated test conditions are established by filling the pump casing to the same level for each test and that this alternate for Pj is acceptable. We conclude that filling the pump casing to the same level for each test establishes repeated test conditions and, thus, measuring Pj would not provide any additional meaningful data. In addition, we feel that using the proposed alternate for Pj and measurirg all other parameters required by Section XI should provide sufficient data to determine any pump degradation (the intent of Section XI).
- 4. Inside Recirculation Spray 4.1 Relief Request The licensee has requested specific relief f rom measuring all parameters for the inside recirculation spray pumps 1/2-RS-P-1A and B in 3
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accordance with the-requirements of Section XI and propose'd to measure motor current to determine pump operability.
4.1.1 Code Requirement. Refer to ' Appendix A.
4.1.2 Licensee's Basis for Requesting Relief. These pumps cannot be tested to code requirements as the test would require filling the sump and spraying water on components in the containment. Pump current is the only
- pump parameter measured; this test is performed monthly. This system is
- always dry, which prevents longer pump run time (30 seconds maximum) and prevents performing periodic flow testing.
4.1.3 Evaluation. We agree with the licensee's basis and, therefore,
- feel that temporary relief should be granted for the inside recirculation spray pumps 1/2-RS-P-lA and B from the requirements of Section XI. The licensee has demonstrated that with the present plant design all parameters required by Section X,I cannot be measured. We conclude that the licensee's proposed alternate test of measuring motor current to . demonstrate pump operability is the only practical test available. However, we also feel that the licensee should further investigate alternate test methods and possible plant modifications to allow pump testing that will provide more adequate data to detemine if any hydraulic or mechanical degradation of these pumps has occurred.
- 5. Component Cooling 5.1 Relief Request The licensee has requested specific relief from measuring inlet pres-
, differential pressure (aP), and flowrate (Q) for the compo-
.sure (Pj) ling pumps 1-CC-P-1A and B,-and 1-CC-P-lC and D in accordance with nent coo the requirements of Section XI and proposed establishing a set of reference flowrates for pump testing.
5.1.1 Code Requirement. Refer to Appendix A.
5.1.2 Licensee's Basis for Requesting Relief. Flowrates from these pumps vary to meet the unit heat load requirements. Instead of varying the system resistance (as required by IWP-1300) to establish a reference flow, sets of referer.ce values will be established to cover the range of system flowrates.
5.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for the component cooling pumps 1/2-CC-P- r IA and 8 from the Section XI requirements to measure P , AP, and.Q with .
only one set of initial conditions. Thelicenseehasdemonstratedthatthe load requirements'of this system change frequently, thus system resistance i AP, and Q change. We conclude that the licensee's changes, proposal tothus estabPj,lish a set of reference values for flowrate to be compared
- with Pj and AP for the varying load requirements should provide the ,
required data to determine any pump degradation (the intent of Section XI).
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- 6. Boric Acid Transfor '
6.1 Relief Request The licensee has requested specific _ relief from measuring inlet pressure-(Pi ), vibration amplitude (V), and_ bearing temperature (Tb) for the boric acid transfer pumps 1-CH-P-2A and B and.2-CH-P-2C and 0 in accordance with the requirements of Section XI and proposed to observe boric acid storage tank level to establish initial test conditions.
- 6. l'.1 Code Requirement. Refer to Appendix A. .
O 6.1.2 Licensee's Basis for Requesting Relief. ' No ' inlet' pressure instrumentation is installed for these pumps. These pumps take suction from the Boric Acid Storage Tanks. Tank levels will be observed from the control room to establish initial conditions for testing. The pumps are totally encased in-insulation making vibration and bearing. temperature impractical to measure. Bearing lubrication is provided by pump flow.
16.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that temporary relief should be granted for the boric acid transfer pumps 1-CH-P-2A and B, and 1-CH-P-2C and D from the Section XI requirements to measure.Pj, V, and Tb . The licensee has demonstrated that using boric acic storage tank level to establish repeated test conditions is an ;
acceptable alternate for Pj measurements. We conclude that the hydraulic ;
characteristics of these pumps can be sufficiently analyzed to determine '
any pump degradation. However, we feel the licensee should further investigate some means to determine the mechanical characteristics (V, Tb) of these pumps to assure that mechanical ' degradation has not occurred.
- 7. Charging Pump Cooling Water 7.1 Relief Request The licensee has requested specific relief from measuring inlet pressure (Pj) for the charging pump cooling water pumps-l/2-CC-P-2A and B in accordance with the requirements of Section XI and proposed to use surge tank level to establish a constant suction head pressure.
7.1.1 Code Requirement. Refer to Appendix A.
7.1.2 Licensee's Basis for Requesting Relief. No inlet pressure instrumentation is installed for tnese pumps. The charging pump seal cooling surge tank maintains a constant suction head for these pumps;
, therefore, it is not considered necessary to measure inlet pressure.
7.1.3 Evaluation. We agree with the licensee's basis and, therefore.
f eel that relief should be granted for the charging pump cooling water pumps 1/2-CC-P-2A and B from the Section XI requirement to measure Pj .
The' licensee has demonstrated that, since no suction pressure ;
instrumentation is installed, observing surge tank level to establish repeated test conditions is an acceptable alternative. We conclude that measuring surge tank level to establish repeated test conditions for P j 1
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and measuring all other parameters required by Section XI should provide sufficient data to determine any pump degradation (the intent.of .
Section XI)...
- 8. Charging Pump Service-Water 9.1 ' Relief Request The licensee has requested specific relief from measuring inlet pres-
- sure (Pj) and differential pressure (AP) for the charging pump service water pumps 1/2-SW-P-10A and. B in accordance with the requirements of Sec-tion XI and proposed to measure flowrate (Q) and vibration' amplitude (V) +.o assure adequate pump performance.
- 8.1.1 Code Requirement. Refer to Appendix A.
8.1.2 Licensee's Basis for Requesting Relief. No inlet or ' outlet pressure instrumentation is installed for these pumps. Flowrate and vibra-tion amplitude will be measured to assure adequate pump performance. Also, a system low pressure alarm is provided to alert the operator of inadequate system flow.
. '8.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for the charging pump service water-pumps 1/2-SW-P-10A and B from the Section XI requirements to measure Pj and AP. The licensee has demonstrated that, since no suction or discharge pressure instrumentation exists, Pj and AP measurements cannot be taken.
We conclude that measuring Q and V under repeated test conditions should provide the required data to detennine any pump degradation (the intent of Section XI).
- 9. Emergency Service Water 9.1 Relief Request The licensee has requested specific relief from measuring inlet pres-sure (Pj), bearing temperature (T b ), and libricant level or pressure f or the emergency service water pumps 1-SW-P-1 A, B, and C in accordance with the requirements of Section XI and proposed to use river level to establish initial test conditions and observe lubricant flow and pressure.
9.1.1 Code Requirement. Refer to Appendix A.
9.1.2 Licensee's Basis for Requesting Relief. No inlet pressure instrumentation is installed for these pumps. These pumps take suction ,
f rom the James River. The river water level will be used to establish initial conditions for testing.
The service water pumps are open lineshaft pumps that depend primarily
- on the liquid being pumped for the lubrication of the pump and lineshaf t bearings. The bearing lubricating water flow can be verified by sight glass and pressure can be monitored. All pump bearings are submerged and lubricant is allowed to leak off into the sump and is not piped back, such that bearing or lubricant outlet temperature cannot be monitored.
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. 9.l.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief.should be granted for the emergency service water
. pumps.1-SW-P-1A, B, and C from the Section XI requirement to measure P ,
.Tb , and' lubricant level or pressure. The licensee has demonstrated that instrumentation does not exist to measure these parameters but some alter-nate parameters can be monitored to evaluate ppep performance and degrada-tion. We conclude that'using river level to establish initial test condi-
.tions for Pj is an adequate alternate parameter. Also, we-feel that, Esince pumps are submerged and the-bearings are cooled by the liquid pumped, monitoring sight glass-flow and seal leak off should be sufficient to deter-
.mine adequate lubrication. Thus, we feel that adequate data is available to determine any pump degradation (the intent of Section XI). -
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III. VALVE TESTING PROGRAM EVALUATION The IST program submitted by Virginia Electric and Power Company for its Surry Power Station Units 1 and 2 was examined to verify that Class 1, 2, and 3 safety-related valves were included in the program and that those valves are suojected to the periodic tests required by the ASME Code, Sec-tion XI, and the NRC positions and guidelines. Our review found that Class 1, 2, and 3 safety-related valves were included in the IST program and, except for those valves identified below for which specific relief
- from testing has been requested, the valve tests and frequency of testing comply with the code requirements and the NRC positions and guidelines listed in Section 1. Also, included in Section 1 is the NRC position and valve listings for the leak testing of valves that perform a pressure iso-
- lation function and a procedure for the licensee's use to incorporate these valves into the IST program. Each Surry Power Station Units 1 and 2 basis for requesting specific relief from testing valves and the EG&G evaluation of that request is summarized (Section 2 through 11) below and grouped according to each specific system.
- 1. General Considerations b
1.1 Testing of Valves which Perform a Prassure isolation Function Several safety systems connected to the reactor coolant pressure boun-dary have design pressures below the reactor coolant system operating pres-sure. Redundant isolation valves within the Class I boundary forming the
'nterface between these high- and low-pressure systems prevent the low-pressure systems from experiencing pressures which exceed their design limit. In this role, the valves perform a pressure isolation function.
The NRC considers the redundant isolation provided by these valves to be important. The NRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For these reasons, EG&G and the NRC believe that some method, such as pressure monitoring, leak testing, radiography, or ultra-sonic testing, should be used to assure the condition of each /alve is satisf actory in maintaining this pressure isolation function.
If leak testing is selected as the appropriate method for achieving this objective, the NRC and EG&G Idaho, Inc., oelieve that the following valves should be categorized as A or A/C and leak tested according to IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are:
1/2-SI-79, 82, 85, 88, 91, and 94 1/2-SI-241, 242, and 243 1/2-51-235, 236, 237, 238, 239, and 240 1/2-107,109,128,130,145, and 147 1/2-RH-4/
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M0V-1700, 1701, and 1720A and B L
M0V-2700, 2701, and 2720A and B
,The_NRC and_EG&G Idaho, 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-3 designation, depending on the testing 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 demonstrates the condition of each valve.
1.2 ASME Code,Section XI, Requirements Subsection IWV-3410(a)-of the Section XI Code (which discusses full stroke and partial stroke testing) requires that Code Category A and B _
valves be exercised once every three months, with the exceptions as defined in IWV-3410(b-1), (e), and (f). IWV-3520(a) requires tnat Code Category C valves ~be exercised once every three months, with the exceptions as defined 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 performad and after operations are completed and shall verify that each valve is locked or sealed. The limiting value of full stroke time for each power-operated valve shall be identified by the owner and tested in accordance with IWV-3410(c). In the above exceptions, the code permits the valves to be tested at cold shutdown where:
- 1. It is not practical to exercise the valves to the position required to fulfill their function, or to the partial position, during power operation
- 2. It is not practical to observe the operatioJ. of the valves (with fail-safe actuators) upon loss of actuator power.
1.3 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 limi-ted operation is possible (and it has been demonstrated by the licensee and agreed to by the NRC), the check valve shall be partial stroked. Since disk position is not always observable, the NRC staff stated that verifica-tion of the plant's safety analysis design flow rate through the check valve would be an adequate demonstration of the full stroke requirement.
Any flow rate less than design will be considered part stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would be equivalent to or greater than the design flow rate 3 through the valve. The licensee agreed to conduct flow tests to satisfy I the above position. j I
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-1. 4 Stroke Testing of Motor-0perated Valves
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The licensee has reques.ed relief from the part stroke requirement of Section XI for all power-ope ated valves. The licensee has stated that none of the Category A or B Jower-operated valves' identified can De part stroked because of-the design logic of the operating circuits. These cir-cuits are such that when an open or 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 direction. We find that the above ralief request 8
from part stroking is warranted and should be granted because the required function of the valves involves only full open or full closed positions.
1.5 Test Frequency of Check Valves Tested at~ Cold Shutdowns e The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Cate-gory A and B valves and once every nine months for Category C valves, it is the NRC's position tnat 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 his procedures on cold shutdowns to read, "In the Case of frequent cold shutdowns, valve testing need not bel performed more often than once every three_(3) months for Category A, B. and C valves."
1.6 Licensee Request for Relief to Test Valves at Cold Shutdowns The Code permits-valves to be tested at cold shutdowns, and 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 require-ments of the ASME Code, 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 'e u noted that the NRC dif-ferentiates, for valve testing purposes, be ween the cold-shutdown mode and the refueling mode. That is, for testing purposes, the refueling mode is not considered as a cold shutdown.
1.7 Changes to the Technical Specifications in a November 1976 letter to the licensee, the NRC provided an attach-ment 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 the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not be cycled if their failure in a non-safe position would cause a loss of total system function. For example, during power operation in some plants, '
there are stated minimum requirements for systems which allow certain limi-ting conditions for operation to exist at any one time and, if the system
- is not restored to meet the requirements within the time period specified i 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
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required to be tested to demonstrate operability immediately and periodi-cally thereaf ter during power operation. For some plants, this situation could be contrary to the NRC guideline as stated in the document mentioned above. It should be noted that a 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 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 licen-see determines that the T.S. should be changed because the guidelines are 4 applicable, the licensee will submit to the NRC, in conjuction 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.
1.8 Safety-Related Valves This review was limited to safety-related valves. Safety-related valves are defined as those valves that are needed to mitigate the cense ,
quences 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 class valves. It should be noted that the licensee may have included non safety-related valves in their IST program as a decision on the licensee's part to expand the scope of their program.
1.9 Velve Testing at Cold Shutdowns Inservice valve testing at cold shutdowns is acceptacle when the fol-lowing conditions are met:
- 1. It is understood that the licensee is to commence testing as soon as the cold-shutdown condition is achieved but r9t later than 48 nours af ter shutdown, and continue until complete or plant is ready to return to power
- 2. Completion of all valve testing is not a prerequisite to return to power
- 3. Any testing not completed at one cold shutdown should be perfonned 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.
e 1.10 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIVs)
All CIVs shall oe classified as Category A valves. The Category A valve-leak rate test requrements of IWV-3420(a-e) have been superseded by 11 i
~
Appendix J. requirements for CIVs. The NRC has concluded that the applicable leak-test procedures 'and requirements for CIVs are determined by 10'CFR 50,
. Appendix J. Relief from Paragraph IWV-3420(a-e) for CIVs presents no safety-problem since the intent of IWV-3420(a-e) is met by Appendix J requirements.
The' licensee shall comply with Sections f and g of IWV-3420 until-relief is requested f rom 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 e of valve operability intended by the Code and that the relief thus granted will. not endanger life or property or the common defense and security of tha.public. e 1.11 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 has determined that the current IST program as submitted by the licensee correctly reflects the Nkt, s interpretation of Section XI vis-a-vis Appendix J. The licensee has agreed that, should the Appendix J program De amended, they will amend their IST program accordingly.
- 2. Auxiliary Steam and Air Removal 2.1 -Category A/C Valves
-2.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 1/2-VP-12, air removal divert to reac-tor containment check, in accordance with the requirements of Section XI and proposed to test these valves each refueling autoge.
2.1.1.1 Code Requirement. Refer to Appendix A.
2.1.1.2 Licensee's Basis for Requesting Relief. These are pas -
sive valves and are not required to cnange position to perfonn their sa0ety-related function. As an alternate, these valves will-be tested during each refueling outage. .
2.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel relief should be granted for Category A/C valves 1/2-VP-12
' f rom the requireneats 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. ;
l 12 I
- 3. Component Cooling 3.1 - Category B Valves 3.1.1 Relief Request. The licensee has requested specific relief from exercising Category B valves 1/2-CC-1, 58, and 59; TV-CC-105A, B, and
. C; TV-CC-205A, B, and C; and TV-CC-107 and -207, component cooling to and
- from RCP checks, in accordance with the requirements of Section XI and preposed to exerciseithese valves during cold shutdowns that RCPs are secured and during refueling outages.
- C 3.1.1.1 Code Requirement. Refer to Appendix A.
3.1.1.2 Licensee's Basis for Requesting Relief. Component cooling water flow to the reacto coolant pumps is required at all times the pumps are in operation; Failure of one of these valves in a closed position during cycling would result in a loss of the cooling flow to the pump. These valves will be tested during cold shutdown when the reactor coolant pumps are secured and during refueling outages.
3.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category B valves 1/2-CC-1, -58, and -59; TV-CC-105A, B, and C; TV-CC-205A, B, and C; and TV-Cr-107 and -207 from the exercising requirements of Section XI. The licensee tas demonstrated that exercising any of these valves while RCPs are running would result in a loss of RCP cooling which could result in RCP damage requiring a reactor shutdown for repairs. We conclude that exercising these valves during cold shutdown when RCPs are secured and at least once each refueling outage should demonstrate proper valve operability.
- 4. Vents and Drains 4.1 Category A/E Valves 4.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/E valves 1-VA-1 and -6, and 2-VA-1 and -9, con-tainment isolations, in accordance with the requirements of Section XI, and proposed to test these valves each refueling outage.
4.1.1.1 Code Requirement. Refer to Appendix A.
4.1.1.2 Licensee's Basis for Requesting Relief. These are pas-sive valves and are not required to change position to perform their safety-related function. As an alternative, these valves will be tested during
! each refueling outage.
4.1.1.3 Evaluation. We agree with the licensee's basis and, a therefore, feel relTeTshould be granted for Category A/E valves 1-VA-1 l
and -6, and 2-VA-1 and -9 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 q- 'erly.
stroke and stroke time measurements are meaningless for passive vahes.
13
- 5. Containment and Recirculation Spray 5.1 Category A, A/E, and A/C Valves 5.1.1 Relief Request. The licensee has requested specific relief f rom exercising category A/E valves MOV-RH-100 and -200, RHR to RWST, in accordance with the requirements of Section XI, and proposed to test these valves each refueling outage.
5.1.1.1 Code Requirement. Refer to Appendix A.
5.1.1.2 Licensee's Basis for Requesting Relief. These are pas-sive valves and are not required to change position to perform their safety
- function. As an alternative, the valves will be tested each refueling outage.
5.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/E valves MOV-Rii-100 and -200 from the exercising 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 tne plant. Therefore, the operability of these valves is inconse-quential with regard to th1 safety function which they perform. We con-clude that the quaterly stroke and stroke time measurements are meaningless for passive valves.
5.1.2 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 1/2-RS-ll and -17, recirculation spray pump discharge checks; 1/2-CS-13 and-24, containment spray pump discharge checks; and 1-CS-104 and -105, and 2-C5-204 and -205, containment spray header checks, in accordance with the requirements of Section XI, and proposed to manually full stroke these valves during refuelir.g outage.
5.1.2.1 Code Requirement. Refer to Appendix A.
5.1.2.2 Licensee's Basis for Requesting Relief. These valves are located inside the containment and are not accessible during power operation. Using flow to exercise thtse valves would result in spraying the ContainM.nt; manual exercising requires building scaffolding that requires venting the containment that, in turn, requires leak testing both doors prior to plant startup to establish subatmospneric containment pres-sure. As an alternative, these valves will be manually full stroke exer-cised during refueling outages.
5.1.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that reliet should be granted for Category A/C valves 1/2-RS-Il and -17, 1/2-CS-13 and -24, and 1/2-CS-104, 105, 204, and -205 from the exercising requirements of Section XI. The licensee has demonstrated that these valves Cannot be exercised using system flow during
- any mode of reactor operation without causing electrical equipment damage and an extensive containment clean-up. We conclude that, with the present plant design, disassmebly and manual exercising is the only test method available. Also, we feel that manually exercising these valves during refueling outages snould demonstrate proper valve operability.
14
- 6. Containment Vacuum and Leakage Monitoring 6.1 Category A and A/E Valves 4
6.1.1 Relief Request. The licensee requested specific relief from exercising Category A valves HCV-CV-100 and -200, containment vacuum air ejector isolations, and 1/2-GW-156 and -175, gaseous waste isolations, and Category A/E valves 1/2-CV-2, containment vacuum air ejector isolations, and 1/2-GW-174 and -183, gaseous waste disposal isolations, in accordance with the requirements of Section XI, and proposed to test these valves each refueling outage.
O 6.1.1.1 Code Requirement. Refer to Appendix A.
6.1.1.2 Licensee's Basis for Requesting Relief. These are pas-sive valves and are not required to cnange position to perform their safety function. As an alternative, these valves will be tested during each refueling outage.
6.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel relief should be granted for Category A valves HCV-CV-100 and -200,1/2-6W-155 and -175, and Catege,ry A/E valves 1/2-CV-2, and 1/2-GW-174 and -183 from the requirements of Section XI. These valves are in their safety-relattd position and are not required to open or close to mitigate the consequances of an accident or safely shut down the plant.
Therefore, the operability of these valves is inconsequential with regard M the safety function which they perform. We Conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
- 7. Reactor Coolant 7.1 Category A/C Valves 7.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 1/2-RC-160, primary water to PZR relief tank checks, in accordance with the requirements of Section XI, and pro-posed to verify valve closure (their safety-related position) during each refueling outage.
7.1.1.1 Code Requirement. Refer to Appendix A.
7.1.1.2 Licensee's Basis for Requesting Relief. Plant design does not permit verification of valve position during power operation or cold shutdown. The only way to verify their safety position is during leak rate testing at refueling outages.
7.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C valves 1/2-RC-160 from the exercising requirements of Secticn XI. The licensee has demonstrated that, due to plant design, the only method avail-able to verify valve closure (their safety-related position) is leak testing. These valves are not equipped with valve position indication and some of the required test connections are located inside the containment.
15
We conclude that the proposed alternate testing frequency of verifying valve closure curing the performannce of leak rate testing at refueling outages should demonstrate proper valve operability.
- 8. Chemical and Vclume Control 8.1 Category A Valves 8.1.1 Relief Request. The licensee has requested specific relief from exercising Category A valves FCV-Il60 and FCV-2160, RCS loop fill '
i header isolations, in accordance with the requirements of Section XI, and proposed to test these valves each "9 fueling outage. ,
8.1.1.1 Code Requirement. Refer to Appendix A.
8.1.1.2 Licensee's Basis for Requesting Relief. These are pas-sive valves and are not required to change position to perform their safety function. As an alternative, these valves will be tested during each refueling outage.
8.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel relief should be granted for Category A valves FCV-ll60 and FCV-2160 from the requirements of Section XI. These valves are in their safety-related position and are not required to open or close to mitigage consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function whicn they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
8.1.2 Relief Request. The licensee has requested specific relief from exercising Category A valves MOV-1381 and MOV-2381, RCP seal water return isolations, in accordance with the requirement! Jf Section XI, and proposed to exercise these valves during refueling outoges.
8.1.2.1 Code Requirement. Refer to Appendix A.
~8.1.2.2 Licensee's Basis for Requesting Relief. These valves cannot be shut down wnen the RC system is above atmospheric pressure or when the RCS is being filled. Closure of these valves would cause loss of RCP seal flow resulting in pump seal damage. As an alternative, these valves will be tested at refueling outages.
8.1.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valves MOV-1381 and MOV-2381 from the exercising requirements of Section XI. The licensee has demonstrated that RCP seal flow is required at all times when the RCS is above atmospheric pressure to prevent seal damage. We conclude that '
exercising these valves during refueling outages when the RCS is at atmos- ,
pheric pressure and seal damage will not occur should assure proper valve
- operability. ,
i 16 .
b
8.2 Category C Valves 8.2.1 Relief Request. The licensee has requested specific relief from exercising Category C valves 1/2-CH-258, -267, and -276, charging pump discharge checks, in accordance with the requirements of Section XI, and proposed partial stroke exercising these valves during power operation and full stroke exercising during refueling outages.
8.2.1.1 Code Requirement. Refer to Appendix A.
8.2.1.2 Licensee's Basis for Requesting Relief. With the present plant design, these valves can only oe partial stroke exercised during power operation because the charging pumps cannot achieve design accident flow when pumping into the RCS at operating pressure. The only available flowpath to test these valves is into the RCS.
During cold shutdown, full stroke exercising these valves could result in an overpressurization of the RCS and could force a safety system (PORVs) to function. These valves will be full stroke exercised during refueling outages when the vessel head is removed providing an adequate expansion volume.
8.2.1.3 Evaluation. We agree with the licensee's basis and, t*. refore, feel that relief should be granted for Category C valves 1/2-CH-258, -267, and -276 from tne exercising requirements of Sec-tion XI. The licensee has demonstrated that only partial stroke exercising is possible during power operation because the only available flowpath is into the RCS and the pumps cannot achieve design flow against operating p ressure. During cold shutdown, pumping design flow into the RCS could cause a low-temperature overpressurization accident forcing the PORVs to function. We conclude that partial stroke exercising these valves during power operation and full stroke exercising during refueling outages with the vessel head removed to provide an expansion volume should demonstrate proper valve operability.
- 9. Safety Injection 9.1 Category A, A/C, and A/E Valves 9.l.1 Relief Request. The licensee has requested specific relief from exercising category A valves 1/2-51-150, boron injection containment isolation, and 1/2-51-174, high head safety injection to RCS containment isolations, in accordance with the requirements of Section XI, and proposed to test these valves each refueling outage.
9.l.1.1 Code Requirement. Refer to Appendix A.
9.1.1.2 Licensee's Basis for Requesting Relief. These are pas-sive valves and are not required to change position to perform their safety function. As an alternative, these valves will be tested during each refueling outage.
17
9.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel relief should be granted for Category A valves 1/2-51-150 and 1/2-S1-174 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 concluie that the quarterly stroke and stroke timing measurements are meaningles', for passive valves.
9.1.2 Relief Request. The licensee has requested specific relief f rom exercising Category A/C valves 1/2-51-234, nitrogen accumulator con-tainment isolations, in accordance with Section XI, and proposed ta verify valve cicsure (their safety-related position) during refueling outages. ,7 9.1.2.1 Code Requiremen,t,. Refer to Appendix A.
9.1.2.2 Licensee's Basis for Requesting Relief. These valves cannot be verified shut (their saf ety-related position) during power opera-tion or cold shutdown. The only method available to verify valve closure is during a leak test at refueling outages.
9.1.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C valves 1/2-SI-234 from the exercising requirements of Section XI. The licensee has demonstrated that, due to plant design, the only method avail-able to verify valve closure (their safety-related position) is during leak rate testing. In addition, these valves are not equipped with valve posi-tion indicators. 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.
9.1.3 Relief Request. The licensee has requested specific relief f rom exercising Category A/E valves 1/2-SI-32 and 1/2-SI-73, accumulator isolations, in accordance with the requirements of Section XI and proposed to test these valves during each refueling outage.
9.1.3.1 Code Requirement. Refer to Appendix A.
9.1.3.2 Licensee's Basis for Requesting Relief. Taese are pas-sive valves and are not required to change position to perform their safety function. As an alternative, these valves will be tested during each refueling outage.
9.1.3.3 Evaluation. We agree with the licensee's Dasis and, therefore, feel relief should be granted for Category A/E valves 1/2-SI-32 and 1/2-51-73 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.
l 18
9.1.4 Relief Request. The licensee has reques+.ed specific relief f rom exercising Category A/E valves MOV-1869A and B, MOV-1842, M0V-2869A and B, and M0V-2842, high head safety injection / charging to RCS containment isol=tions, in accordance wi;h the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.
9.1.4.1 Code Requirement. Refer to Appendix A.
9.1.4.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation; opening the<e valves would allow charging flow into the RCS, thermally shocking the HHSI nozzles and g causing reactivity transients. During cold shutdown, the; charging (HHSI) flow could cause an overpressurization of the RCS and could force a safety system (PROVs) to function. These valves are full stroke exercised during refueling outages.
9.1.4.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/E valves MOV-1869A and B MOV-1942, MOV-2869A and L, and MOV-2842 from the exer-cising requirements of Section XI. The licensee has demonstrated that exercisir.g these valves during power operation would thermally shock the injection nozzles and could result in nozzle damage, In addition, injec-ting this cold water would cause power transients . hat could result in a reactor trip. During cold shutdown, the charging /HHSI pump flow could cause an overpressurization accident and force the PORVs to function. We conclude that exercising these valves during refueling outages, when the vessel head is removed to provide an expansion volume, and thennal shock is not a problem, should demonstrate proper valve operability.
9.2 Category C Valves 9.2.1 Relief Request. The licensee has requested specific relief from exercising Category C valves 1/2-SI-47 and -56, low head safety injec-tion pump suctions from the containment sump, in accordance with the requirements of Section XI, and proposed to partial stroke exercise these valves during refueling outages.
9.2.1.1 Code Requirement. Refer to Appendix A.
9.2.1.2 Licensee's Basis for Requesting Relief. These normally-closed check valves cannot be exercised without isolating suction to the LHSI pumps and draining a portion of the system. These valves will be part stroke exercised during each refueling ou+. age using the leakage monitoring test connections.
9.2.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel temporary relief should be granted for Category C valves 1/2-SI-47 and -56 f rom the requirements of Section XI. The licensee has demonstrated that, with the present plant design, isolation and draining is required and only partial stroke exercising is possible. We conclude that the licensee is performing the only test possible with the present plant design. However, we feel that the licensee should further investigate a method to full stroke exercise these valves (manual full stroke exercise) at least once during each refueling outage.
0 19
W 9.2.2 Relief Request. The licensee has requested specific relief-f rom exercising category c valves 1/2-SI-46A and 8,1-SI-50 and -58, and 2-SI-43 and -50, low head safety injection pump suction from the RWST ano discharge checks, in accordance with the requirements of Section XI, and
! proposed to partial stroke exercise these valves quarterly and full stroke exercise these valves during refueling outages.
9.2.2.1 Code Requirement. Refer to Appendix A.
9.2.2.2 Licensee's Basis for Requesting Relief. These valves '
cannot be full stroke exercisec during power operailon; the only full flow path is-into the RCS and the LHSI pumps cannot overcome RCS operating pres-sure. These valves are partial stroxe exercised quarterly through the pump U recirculation line. During cold shutdown, the RCS pressure is greater than design accident pressure and the LHSI pump cannot achieve design flow. 1 These valves are full streke exercised durirg refueling outages with the vessel head removed, which provides minimum RCS back pressure, which allows full LHSI flow.
9.2.2.3 Evaluation. We agree with the licensee's basis and,,
therefore, feel that relief should be granted for Category C valves 1/2-SI-46A and 8,1-SI-50 and -58, and 2-SI-43 and -50 from the exercising requirements of Section XI. The licensee has demonstrated _that the low head safety injection (LHSI) pumps cannot overcome operating RCS pressure.
During cold shutdown, the LHSI pumps cannot achieve design flow because the j RCS pressure is greater than design accident pressure. We conclude that partial stroke exercising these valves quarterly on pump recirculation and full stroke exercising'these valves during refueling outages, with the vessel head removed to provide minimum back pressure and permit design flow, should demonstrate proper valve operability 9.2.3 Relief Request. The 14 ...see has requested specific relief f rom exercising Category C valves 1/2-SI-88, -91, -94, -238 -239, and -240, safety injection to RCS hot legs, and 1/2-SI-79, -82, and -85, safety injec-tion to RCS cold legs, in accordance with the requirements of Section XI, and pron;seu to full stroke exercise these valves during refueling outages.
9.2.3.1 Code Requirement. Refer to Append 1x A.
9.2.3.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operaIJun, HH51 flow through these valves would thermal shock the injection nozzies. luring cold shutdown, the RCS pressure is greater than accident pressure and full design flow cannot be achieved. These valves are full stroke exercis.d during refueling outages when the vessel head is removed.
9.2.3.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category C valves 1/2 i 88, -91, -94, -238, -239, -240, -79, -82, and -85 f rom the exercising -
raquirements of Section XI. The licensee has demonstrated that initiating
{
flow through these valves during power operation would thermal shock the '
, injection nozzles and could~ result in nozzle damage. During cold shutdown, full flow cannot be achieved because the RCS pressure is greater than 20 ;
i
design accident pressure. --We conclude that: full stroke exercising these valves during refueling outages, with the vessel head removed and the RCS at minimum pressure,~ should demonstrate proper valve operability.
9.2.4 Relief Requesti. The licensee has' requested specific relief
'f rom exercising category c valves 1/2-51-107, -109, -128. -129, -145, and -147,, accumulator discharge checks, in accordance with the requirements of Section XI, and proposed to partial stroke exercise these valves during refueling outages.
9.2.4.1 Code-Requirement. Refer to Appendix'A.
'd 9.'2.4'.2 Licensee's Basis for Requesting Relief. These valves
^
cannot 'be. exercised.during power operation because accumulator pressure cannot overccme RCS pressure. ' The 3/4-inch test line will not partial stroke these valves. These valves cannot be exercised during cold shutdown ,
because an overpressurization accident could occur. These valves are par-tial stroke exercised during refueling outages.
9.2.4.3 Evaluation. -We agree with the licensee's basis and, therefore, feel that temporary ' relief should be granted for Category C valves 1/2-SI-107, -109, -128, -130, -145, and -147 from the exercising requirements of Section XI. The licensee has demunstrated that these valves cannot be exercised during-power operation Decause the accumulators cannot overcome RCS prenare; During cold shutdown, exercising these valves could result in an RCS low-temperature overpressurization accident. - We conclude that, with the present plant design, a partial stroke exercise during refuelinq outages is the only test possible. However, we recommend that the licensee further investigate some alternate test method to full stroke exercise these valves at least once each refueling outage.
9.2.5 Relief Request. The licensee has requested specific relief from exercising category C valves 1/2-SI-235, -236, and -237, high head safety injection to RCS cold legs, and 1/2-SI-224, -225, -226, and -227, high head safety injection containment checks, in accordance with the requirements of Section XI, and proposed to full stroke exercise these valves durin? refueling outages.
9.2.5.1 Code Requirement. Refer to Appendix A.
9.2.5.2 Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation; exercising valves requires flow into the RCS, thermal shocking the injection nozzles. Exercising these valves during cold shutdown could result in an overpressurization of the RCS and force a safety system (PORVs) to function. These valves are full T
stroke exercised during refueling outages when the vessel head is removed.
9.2.5.3 Evaluation. We agree with the licensce's basis and, therefore, feel ~ that relief should be. granted for Category C valves 1/2 235, -236, -237, -224, 225, -226, and -227 f rom the exercising requirements of Section XI. The licensee has demonstrated that exercising these valves during power operation would result in thermal shock to the injection noz-zles and possible nozzle damage. Also, during cold shutdown, a low-j temperature overpressurization accident could occur while exercising these 21
val'es.
v We conclude that full stroke exercising these valves during refueling outages, when the vessel head is removed to provide an adequate expansion volume, should demonstrate proper valve operability.
9.2.6 Relief Request.- The licensee has requested specific relief from exercising Category C valves 1/2-SI-241. -242, and -243, low head sefety injection to RCS cold legs, and 1/2-SI-228 and -229, low head safety injection containment checks, in accordance with the requirements of Sec-tion XI, and proposed to full stroke exercise these valves during refueling g [
outages.
9.2.6.1 Code Requirement. Refer to Appendix A.
V ,
9.2.6.2' Licensee's Basis for Requesting Relief. These valves cannot be exercised during power operation or cold shutdown as the only full flow path is into the RCS and RCS pressura is greater than accident p ressure. Inese vslves are full stroke exercised during refueling outages ,
with the vessel head removed.
9.2.6.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should De granted for Category C valves 1/2-SI-241, -242, 243, -228, and -229 from the exercising requirements of Sec-tion XI. The licensee has damonstrated that the LHSI pumps cannot overcome operating RCS pressure. Also, during cold shutdown, RCS pressure is greater than design accident pressure and the LHSI pumps cannot achieve design flow ,
through these valves. We Conclude that full stroke exercising these valves during refueling outages, when the vessel head is removed and the RCS has minimum back pressure, should demonstrate proper valve operability.
- 10. Generic Reliefs 10.1 -Solenoid- and Air-Operated Valves :
10.1.1 Relief Request. The licensee has requested specific relief from stroke timing all f ast acting solenoid- and air-operated valves in accordance with the requirements of Section XI, and proposed to establish a maximum stroke time to determine when corrective action is necessary.
10,1.1.1 Code Requirement. Refer to Appendix A and ;
IWV-3410(c)(3).
10.1.1.2 Licensee's Basis for Requesting Relief. The stroke times of solenoid-controlled, air-operated valves is both extremely rapid t and subject to considerable variation. Exception is taken to complying with stroke variations defined by Article IWV-3410(c)(31 The valve stroke timing tolerance specified is based on a reference value, and this will not exceed the maximum Stroke time limit.
10.1.1.3 Evaluation. We agree with the licensee's basis and, '
tnerefore, feel relief should be granted-for all fast-acting solenoid- and -
air-operated valves from the timing requirements of Section XI. The licen-see has demonstrated that large variations in V&lve stroke timing Can occur due to the accuracy of timing equipment (hand-held stop watch), and these f
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v'ariations could result in excessive maintenance and corrective action when the valve is actually performing satisfactorily. We conclude that estab-lishing a maxii.1um stroke time to determine valve degradation and when'cor-rective action would be required meets the' intent of the Section XI timing requirements for these fast-acting valves,
- 11. Purge and Ventilation 11.1 Category A Valves
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11.1.1 Relief Request. The licensee has requested specific relief-from exercising category A valves 1-M0V-75-100A, -1008,100C -1000, -101, y - and -102, and 2-MOV-VS-200A, -200B, -200C, -2000, -201, and -202, purge and ventilation containment isolations, in accordance with the requirements of Section XI and proposed to exercise these valves during refueling outages.
11.1.1.1 Code Requirement, Refer to Appendix A.
11.1.1.2 Licensee's Basis for Requesting Relief. These are passive valves and are not required to cnange position to perform their safety function. As an alternative, these valves will be tested at -
refueling outages.
11.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel relief should be granted for Category A valves 1-MOV-VS-100A, -1008, -100C. -1000 -101, and -102, and 2-M0V-VS-200A, -2008, -200C,
-2000, -201, and -202 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. fWe conclude that the quarterly stroke and stroke timing-measurements are meainingless for passive valves.
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I IV. APPENDIX A .
- l. Code Requirement--Valves
. Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code
- (which discussed full stroke and partial stroke-requirements) requires that Code Category A and B valves be exercised once every t' rse months, with exceptions as defined in IWV-3410(b)(1), (e), and (f). IWV-3520(a) (which.
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discusses full stroke'and partial stroke requirements) requires that Code Category C valves be exercised once every three months, with exceptions as ( '
definedinIWV-3520(b). In the above exceptions, the Code permits the
. valves to be tested at cold shutdown where: ;
- 1. It is not practical to exercise the valves to the position required to fulfill tt.eir function or to the partial position. .
during power operation.
- 2. It is not practical to observe the operation of the valves (with f ailsafe actuators) upon loss of actuator power.
~ Subsection IWV-3410(c) requires all Category A'and B power-operated valves to be stroke-time tested to the nearest second or 10% of the maximum '
allowable owner-specified time.
- 2. Code Requirements--Pumps 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 quan-tities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.
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e V. ATTACHMENT I The following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not full stroke exercised every three months during plant operation. These valves are specit ically identified by the owner and are full stroke exercised during cold shutdowns and refueling outages. EG&G has reviewed all valves in this littdchment 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 that these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they v are 10cated.
- 1. Main Steam 1.1 Category B Valves Category B valves TV-MS101A, B, and C; and TV-MS201-A, B, and C, main steam line trip valves, cannot be exercised during power operation. A full stroke or partial stroke exercise of these valves during power operation could result in a turbine and reactor trip. As an alternative, they will be full stroke exercised during cold shutdown.
1.2 Category C Valves Lategory C valves SV-MSl0lA, B, and C; SV-MS102A, B, and C; SV-MS103A, B, and C; SV-M5104A, B, and C; SV-MS105A, B, and C; SV-MS201A, B, and C; SV-MS202A, B, and C; SV-MS203A, B, and C; SV-MS204A, B, and C; and SV-MS205A, B, and C, main steam safety valves, cannot be exercised during power operation. A full or partial stroke exercise of these valves during power operation could result in a turbine and reactor trip. As an alter-native, they will be full stroke exercised during cold shutdown.
Category C valves NRV-MS101A, B, and C; and NRV-MS201A, B, and C, main steam non-return valves, cannot be exercised during power operation. A full or partial stroke exercise of these valves during power operation could result in a turbine and reacto" trip As an alternative, they will be full stroke exercised during cold $hutdt .n .
- 2. Feedwater 2.1 Category C Valves
~ Category C valves 1/2-FW-27, -58, and -89, auxiliary feedwater to main feedwater checks; l/2-FW-131, -133, -136, and -138, auxiliary feedwater header checks; and 1/2-FW-142, -157, and -172, auxiliary feedwater pumps
' discharge checks, cannot be exercised during power operation. Opening these valves during power operation would introduce cold and out-of-chemistry specification auxiliary feedwater to the steam generators, resulting in thermal stress and possible system degradation. As an alternative, they will be tested during cold shutdown.
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I Category C valves 1/2-FW-10, -12, -41, -43, -72, and -74, main feed-water checks, cannot be full stroke exercised during power operation.
Closure of these valves during power operation would require securing feed- '
water (resulting in a reactor trip) and initiation of auxiliary feedwater flow to back-seat the disc. These valves will be tested during cold shutdown.
Category C valves 1/2-FW-272 and -273; l-FW-309 and -310; and 2-FW-305 and -306, auxiliary feedwater cross-connects, cannot be exercised during \
power operation. Opening these valves during power operation would intro-duce cold and out-of-chemistry specification auxiliary feedwater to the steam generators, resulting in thermal stress and possible system degrada- O tion. As an alternative, th2y will be tested during cold shutdown.
- 3. Service Water 3.1 Category B Vahes Category B valves MOV-SW-103A-D, and MOV-SW-203A-D, service wat'.r to recirculation spray heat exchanger isolations, cannot be exercised during power operation. Opening these valves would result in the introduction of service water into the recirculation spray heat exchangers and cause fouling of the heat exchanger tubing. As an alternative, these valves will be tested during cold shutdown when portions of the service water system can be secured.
- 4. Component Cooling 4.1 Category C Valves l Category C valves 1/2-CC-176 and -177, component cooling to RHR heat exchanger checks, cannot be exercised during power operation. These check valves are located in the containment and may be normally-open or -closed depending on system lineup. A containment entry and manipulation of other system valves is necessary to test these valves. This is cc'sidered imprac-tical during power operation and, therefore, they will be testsd during cold shutdown.
Category C valves 1/2-CC-242, -233, and -224, component cooling to A reactor containment air recirculation cooler checks, cannot be exercised during power operation. These valves remain open during normal plant opera-tion. It is not practical to test for closure unless the containment air coolers are taken out of service. As an alternative, these valves will be tested during cold shutdown.
- 5. Chemical and Volume Control 5.1 Category A Valves r
Category A valves MOV-1289A and B and MOV-2289A and B, normal charging header isolations, cannot be exercised during power operation. Failure of either of these valves in a closed position during exercising would cause a loss of charging flow and could result in an inability to maintain reactor coolant inventory. These valves will be exercised during cold shutdown.
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Category A valves TV-1204 and TV-2204, RC letdown isolation trip valves, cannot be exercised during power operation. Exercising these valves closed during power operation could result in a loss of RC inventory and pressurizer level control. These valves will be exercised during Cold shutdown.
5.2 Category B Valves y Category B valves LCV-lll5C and E, and LCV-2115C and E, charging pump
. suction from the RWST, cannot be exercised during power operation. Exer-cising these valves during power operation would require the charging pump suctions to be aligned with the refueling water storage tank. This would O cause a sudden increase in RCS boron inventory, resulting in power transi-ents ane a possible reactor trip. They will be exercised during cold sht.;-
do w when the RCS is barated to shutdown conditions.
Category B valves MOV-1373 and -2373, charging pump recirculation neader stops; MOV-1275A, B, and C; and MOV-2275A, B, and C, charging pump recirculation flowpath isolations, cannot be exercised during power opera-tion. These valves cannot be exercised without possible damage to the charging pumps. As an alternative, they will be exercised when the charging pumps are secured during cold shutdown.
- 6. Safety Injection 6.1 Category A Valves Category A valves MOV-1867C and D, and MOV-2867C and D, boron injec-tion tank outlet isolations, cannot be exercised during power operation.
Opening these valves during power operation would allow concentrated boric acid to flow into the piping systems that are not heat traced and a boron build-up could crystalize and block system flow. These valves are full stroke exercised during cold shutdowns when the boric acid system can be secured.
Category A valves MOV-1890C, and MOV-2890C, low head safety injection to RCS cold legs, cannot be exercised during power operation. If either of these Valves failed in the closed position, LHSI to the cold leg would be rendered inoperable. These valves are full stroke exercised during cold shutdowns.
6.2 Lategory B Valves Category B valves MOV-1867A and B, and MOV-2867A and B, boron injec-tion tank inlet isolations, cannot be full stroke exercised during power operation. Opening these valves during power operation would allow concen-trateo boric acid to flow into the piping systems that are not heat traced and a boron build-up could crystalize and block system flow. These valves 8 are full stroke exercised during cold shutdowns when the boric acid system can be secured.
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- 7. RWST Cross-Tie
. 7.1 Category C Valves Category C valves 1/2-SI-25,1-SI-410, and 2-51-400, charging pump suction checks from the RWST, cannot be exercised during power operation.
Exercising these valves during power operation would require thc charging peso suctions to be aligned with the refueling water storage tank. .This 4 would cause a sudden increase in the RCS boron inventory that would cause power transients and a possible reactor trip. They will be exercised during.
cold shutdown when the RCS is borated to shutdown conditions. ,,
- 8. Steam Generator Blowdown 8.1 Category B Valves Category B valves TV-BD-100A-F, and TV-BD-200A-F, steam generator blowdown trips, cannot be exercised during power operation. Closing these valves during power operation causes the downstream piping to become empty
'due to drainage and water flashing to steam. When the valves are reopened, a flow surge occurs which automatically isolates the inner valves due to '
high flow. ..Then, a containment entry is necessary to reset these valves and, upon reopening, the process may occur again. As an alternative, these valves will be exercised during cold shutdown.
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V I .' ATTACHMENT II 1.1 _ All Category A,-A/C, and A/E valves included in the IST program.
-submittal . dated 12-1E-80, are leak tested in accordance with the requirements off Appendix J-of 10 CFR 50 in' lieu of the Section XI requirements.
2.- EG&G Idaho, Inc., feels that the following valves should be r '4 reviewed by the NRC. Appendix J review committee, _to determine if they should be Categorized A, A/C, or A/E-as indicated, leak .
tested in accordance with the requirements of Appendix J, and O' exercised'in accordance with' the requirements of.Section XI.
Canponent Cooling 1/2-CCil, -58, -59, -176,-177 A/C TV-CC-105A, B, C A TV-CC-205A,'B, C A TV-CC-107 TV-CC-207 A TV-CC-108A, B TV-CC-109A, 8 A 1/2-CC-224, -233, -242 A/C TV-CC-Il0A, B, C- A/C'
_TV-CC-210A, B, C A/C 1/2-HCV-CC-101A, -102A A Chemical and Volume Control MOV-1370, -2370 should be included in Category A l/2-CH-278 should be included in Category A
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VII. ATTAC MENT III.
- 1. The following items concern valves,that'are never full stroke exercised or that have a testing frequency greater'than each refueling outage.
- a. Valve Testing Program
~1. 9.2.1 p-
- 2. - 9.2.4
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VIII. ATTACHMENT'IV
-The following P& ids were used during the' course of this ; review.
Main Steam FM-64A Auxiliary Steam FM-66A Feedwater FM-68A
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,. Auxiliary Feed FM-688
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' Circulating and Service Water . FM-71A and B Component Cooling Water FM-72A through D Fuel Pit ,
FM-81A Sampling FM-828 Vents and Drains FM-83A and B Containment-Vacuum and Leakage Monitoring FM-85A Reactor Coolant FM-86A and 8 Residual Heat Removal FM-87A Chemical and Volume Control FM-88A through C Safety -Inject 'on FM-89A and B
.RWST Cross-Tie- FM-106C Chemical Feed FM-123A Steam Generator Blowdown FM-124A
-Radiation Monitoring FM-100A Chilled and Condenser Water F8-41A Gaseous Waste-Disposal FM-90A 3.
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IX. 'ATTACHMENI V
. ~ The following items were discussed with Rick Bount of Surry Station Units 1 and 2 on 3-5-81, and may appear as differences between this report
. and their. IST Program. .The licensee has agreed to send revised pages of their report to the NRC to reflect the below-listed changes.
- 1. The licensee has agreed to delete Relief Request No. 7 from the pump testing program and Relief Request Nos. 9,10, and 11 from
' the valve testing program. The RHR system is located inside the V containment and is not a safety-related system. ,
- 2. Valves 1-CS-104 and -105 will be included in the Containment and o Recirculation Spray System as Category A/C valves with Relief Request No. 8. ,
- 3. -Velves MOV-1275A, B, and C, and MOV-2275A, B, and C will have Relief Request Basis No.13 insread of No.17, which' does not c.ompletely apply to these valves. ,
4 -The licensee has agreed to add the purge and ventilation valves '
discussed in Item 11 to the IST program, t
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