ML19351E707
| ML19351E707 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 11/30/1980 |
| From: | Fehringer J, Rockhold H IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | Nerses V Office of Nuclear Reactor Regulation |
| References | |
| CON-FIN-A-6258 EGG-EA-5274, NUDOCS 8012190061 | |
| Download: ML19351E707 (33) | |
Text
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INTERIM REPORT Accession No.._
Report No. __ LGG-EA-5%Z1. _ _ _
Contract Fagram or Project
Title:
Systems Engineering Support Subject of this Document; Safety Evaluation of the Inservice Testing Program for Pumps and Valves ai the Lacrosse Boiling Water Reactor (Docket No. 50-409) for the Period 11-1-79 through 7-31-81.
Type of Document:
Safety Evaluation Report Aathor(s):
J. M. Fehr.nger H. C. Rockhold Date of Document:
November 1980 Responsible NFiC Individual and NRC Office or Division:
Victor Nerses, NRC-DE This document was prepared primarily for prelirr.inary or internal use. lt has not received full review and approval. Since there may be substantive changes, this document should not be considered final.
I EG&G Idaho, Inc.
idaho Falls, Idahc 83415 I
Prepared for the
. U.S. f0iclear Reguichry Commission Washington, D.C.
Under DOE Coritract No. DE-AC07-761D01570 NRC FIN No.
A6258 INTERIM REPORT
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CONTENTS t
1 I.
Introduction.................................................. 1 II.
Pump Testing Program..........................................
3 Ill. Valve Testing Program........................................- 5 IV.
A t t a chm e n t I................................................. 21 V.
Attachment II................................................
22 1
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VI.
A t t a chm e n t I I I............................................... 28 -
VII. Attachment IV................................................ 29 1
VIII. Attachment V................................................. 39 E
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Introduction Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Dairyland ?ower Cooperative for its Lacrosse Boiling Water Reactor (LACBWR) nuclear generating station.
The program applies to Lacrosse for the period 1 November 1979 through 31 July 1981. The working session with Lacrosse and Dairyland Power Cooperative representatives was conducted on March 25, 1980 and March 26, 1980. The licensee resubmittal was issued on Juiy 14, 1980 and was reviewed by EGLG Idaho Inc., to verify compliance of proposed tests of safety related Class 1, 2, and 3 pumps and valves with requirement of the ASME Boiler and Pressure Vessel Code,Section XI,1974 Edition, thrcugh the Summer of 1975 Addenda. LACBWR has also requested relief from the ASME Code from testing specified pumps and valves because of pratical reasens. These requests have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed impractical.
The evaluation of the pump testing program and associated relief 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.
Category A, A/C, and A/E valves currently being leak tested to the Appendix J leak testing requirements are contained in Attachment I.
Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not exercised every 3 months are contained in Attachment II.
A listing of P&ID's used for this review are contained in Attachment III.
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Valves that are never full stroke exercised are summarized in Attachment IV.
Changes to the 14 July 1980 IST submittal are summarized in Attachment V.
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II.
Pugd"is L ing Prograin The IST program submitted by LACBWR was examined to verify that Class 1, 2, and 3 safety related pumps were included in the program and that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI.
Our review found that Class 1, 2, and 3 safety related pumps were included in the IST program and, except for those pumps identified below for which specific relief from testing has been requested, the pump tests and freauency of testing comply with the code.
Each LACBWR basis for requesting specific relief from testing pumps and the EG&G evaluation of that request is sunnarized (Item B below) and grouped according to the system in which pumps reside.
A.
Code Requirement An inservice test shall be conducted on all safety related pumps, nominally once each month during normal plant operation.
Each inservice test shall include the measurement, observation, and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.
B.
Emergency Core Spray 1.
Relief Request The licensee has requested specific relief from testing the Emergency Core Spray Pumps 53-06-001 and 002 in accordance with the requirements of Section XI and proposed to test these pumps during cold shutdown.
I Code Requirement Refer to Pump Testing Program Paragraph II.A.
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Licensee's Basis For Requesting Relief These pumps cannot be tested during power operation because the only available flow path =is into the reactor vessel which would result in thermal shock to the injection nozzles and reactivity excursions that would result in a reactor trip.
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for the Emergency Core Spray Pumps 53-06-001 and 002 from the testing requirements of Section XI. The licensee has demonstrated that since the only available flow path is into the reactor vessel, testing these pumps during power operation would result in thermal shock to the injection nozzles, reactivity excursions, and a reactor trip. We conclude that the proposed alternate testing frequency of cold shutdown testing should demonstrate proper pump operability.
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!!!. Valve Testing Program Evaluation The IST program submitted by LACBWR was examined to verify that Class 1, 2, and 3 safety related valves were included in the program and that those valves are subjected to the periodic tests required by the ASME code,Section XI, and the NRC positions and guidelines. Our review found that Class 1, 2, and-3 safety related valves were included in the IST program and, except for those valves identified below for which specific relief from testing has been requested, the valve tests and frequency of testing comply with the code requirements and the NRC positions and guidelines listed in General Section A.
Also, included in the-General Section A is the'NRC position and valve listings for the leak testing of valves that perforrn a pressure isolation function and a procedure for the licensee's use to the incorporate these valves into the IST program.
Each LACBWR basis for requesting specific relief from testing valves and the EG&G evaluation of that request is summarized (B through F) below and grouped according to each specific system.
A.
General Considerations-1.
Testing of Valves Which Perform a Pressure Isolation Function a
Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class I boundary forming the interface between these high and low pressure systems prevent the low pressure systems from pressures which exceed their design limit.
In this role, the valves perform a pressure isolation function.
The-NRC considers tne redundar,t isolation provided by these valves to be impartant. The NRC considers it necessary to 1
assure that the condition of each of these valves is adequate ta maintain this redundant isolation and system 5
integrity. For these reasons, the NRC believes that some method, such as pressure monitoring, leak testing, radiography and ultrasonic testing should be used to assure the condition of each valve is satisfactory 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.
believe that the following valves should be c.cagorized as A or AC and leak tested according to IWV-3420 of Section XI of the applicable edition of the ASME code. These valves are:
53-26-001, 002, and 003 53-25-001 38-26-001 and 002 56-25-001 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 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 demonstrate the condition of each valve.
2.
ASME Code Section XI Requirements Subsection IWV-3410-(a) of the Section XI Code (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(b-1), (e), and (f).
IWV-3520(a) requires that Code Category C valves be exercised once every 3 months, with the exceptions as defined in IWV-3520(b).
IWV-3700 requires no regular 6
testing for Code Category E valves. Operational checks, with appcopriate recora 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 above exceptions, the code permits the valves to be tested at cold shutdown where:
a.
It is not practical to exercise the valves to the position 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 fail-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 NRC) the check valves shall be partial-stroked. Since disc I
position is not always observable, the NRC staff stated that l
verification of the plant's safety analysis design flow rate
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I through the check valve would be an adequate demonstration of the full-stroke requirement. Any flow rate'less than design will-be considered'part-stoke exercising-unless it can be shown that the chec!: valve's disc position at-the-lower flow rate would be ecuivalent to or greater than the design flow rate through the valve. The-licensee agreed'to conduct flow test to satisfy the above position.
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f 4.
Stoke Testing of Motor 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 cpen 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.
5.
Test Frequency of Check _ Valves Tested at Cold Shutdowns The Codes states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Category A and B valves and once every nine months for Category C valves.
It is NRC's position that the Code is inconsistent and that Category C valves should be tested on the same schedule as Category A and B valves. The licensee has agreed to modify his procedures on cold shutdowns to read, "In the case of frequent cold shutdowns, valve testing will not be performed more often than once every tnree (3) months for Category A, B and C valves.
t 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 i
in Appendix A.
These valves are specifically identified by j
the licensee and are full stroke exercised during cold' l
shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements 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.
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It shoul<1 be noted that the NRC differentiates f at valve testing purposes between the cold ihutdown mode and the refueling mode.
That is, for testing purpnses the refueling mode is not considered as a cold shutdown.
7.
Changes to the Technical Specification In a November 1976 letter to the licensee, the NRC orovided an attachment entitled, "NRC Guidelines for Excluding Exercising (Cycling) Tests of Certain Valves During Plant Operation." The attachment stated that when one train of 3
redundant system such as in 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 minimwn requirements for systems which allow certain limiting conditions for operation to exist at any one time and if the system is not restored to meet the requireinents within the time period specified in a plants' Technical Specifications (T.S.), the reactor is required to be put in some other mode. Furthermore, prior to initiating repairs all valves and interlocks in the system that provide a duplicate function are required to be tested to demonstrate operability immediately and periodically thereafter during power operation. For such plants this situation could be contrar.y 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.
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The licensee has agreed to review the plant's T.S. and to consider the need to propose T.S. changes which would have the effect of precluding such testing.
After making this review, if the licensee determines that the T.S. should be changed because the guidelines are applicable, the licensee will submit to the NRC, in conjunction with the proposed T.S. change, the inoperable condition for each system that is affected which demonstrates that the valve's failure would cause a loss of system function or if the licensee determines that the T.S.
should not be changed because the guidelines are not applicable or cannot be followed, the licensee will submit the reasons that led to their determination for each potentially affected section of the T.S.
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 consequences of an accident and/or to shut down the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some non-code 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 l
their program.
9.
Valve Testing and Cold Shutdown l
Inservice valve testing at cold shutdown is acceptable when the following conditions are met:
It is understood that the-licensee is to comence testing as soon as the cold shutdown i
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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 /> af ter shutdown and continue until complete or plant is ready to return to power. Completion of all valve testing is not a prerequisite to return to power. Any testing not completed at one Cold shutdown should be performed during and 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.
- 10. Category A Valve Leak Check Requirements for Containment Isolation Valves (CIV)
All CIVs shall be classified as Category A valves. The Category A valve leak rate test requirements of IWV-3420(a-e) have been superseded by 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 problems since the intent of IWV-3420 (a-e) is met by Appendix J requirements.
The licensee shall comply with Sections f and 9 of TWV-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
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- 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 current IST program as submitted by the licensee correctly reflects our interpretation of Section XI vis-a-vis Appendix J.
The licensee has agreed that, should the Appendix J program be ammended, they will amend their IST program accordingly.
B.
High and Low Pressure Emergency Core Spray 1.
Category C Valves a.
Relief Request The licensee has requested specific relief from exercising Category C valve 53-26-004, high pressure service water to core spray check, in accordance with the requirements of Section XI and proposed to partial stroke exercise this valve during cold shutdown and refueling.
Code Requirement j
Refer to Valve Test 1ng Paragraph A.2.
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Licensee's Basis for Requesting Relief Full stroke exercising this valve would -introduce river water into the stainless steel Core Spray System supply line, which would require-flushing to' clean up the system to preclude conditions susceptible to stress
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corrosion. The above-stated problems apply to any 12
i plant condition.
In addition, mechanically full stroking this valve by disassembly is impossible because this valve cannot be isolated from the overhead storage tank. This valve will be part stroked with demineralized water each cold shutdown and refueling outage, but no more often than every 3 months.
Evaluation We agree with the licensee's basis and therefore feel that temporary relief should be granted for Category C valve 53-26-004 from the exercising requirements of Section XI. The licensee has demonstrated that introducing river water into the core spray system could result in excessive stress corrosion of the core spray system. We conclude that with the present piping design only partial stroke exercising is possible using the demineralized water system. However, we recommended that the utility should further investigate a method to full stroke exercise this valve at least each refueling outage.
C.
Boron Injection and Purification 1.
Category C Va!ves a.
Relief Reaucst The licensee has requested specific relief from exercising Category C valve 60-26-001, baron to core spray pump suction in accordance with the requirements of Section XI, and proposed to partial stroke exercise this valve during cold shutdown and refaeling outages.
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Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief Cycling this valve during plant operation would render both the Boron Inject and High Pressure Core Spray Systems inoperative.- Furthermore, full stroking this valve at any time would inject boron solution with the high pressure core spray pumps into the reactor coolant system. The reactor coolant system does not contain boron during normal operation.
I This valve will be part stroked with denineralized water each cold shutdown and refueling outage, but not more often than every 3 months.
Evaluation We agree with the licensee's basis and therefore feel that' temporary relief should be granted for Category C valve 60-26-001 during power operation and cold shutdown from the exercising requirements of Section XI. The licensee has demonstrated that the only available full flow exercising path would inject highly concentrated boron into the reactor system via-the emergency core spray ~ pumps During power operation, injecting highly concentratd boron-would cause a reactor shutdown. During cold shutdown-injecting highly concentrated boron would place primary water chemistry out of specification for reactor operation resulting in-a delay of reactor start-up due.
to the extensive clean-up requirement. We conclude l
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that with the present piping design only partial str cAe exercising is possible using demineralized water.
However, we reconmend that the utility further investigate a method to full stroke exercise this valve (i.e., manual exercising af ter disassembly or injecting boron when clean-up time is not a problem during refueli ng).
D.
Alternate Core Spray 1.
Category A/C Valves a.
Relief Request The licensee has requested specific relief from exercising Category A/C valves 38-26-001 and 002, alternate cc: e spray supply header checks, from the exercising requirements of Section XI and proposed to partial stroke exercise these valves during cold shutdown and refueling.
Code Requirement Refer to' valve testing paragraph A.2.
Li_censee's Basis for Requesting Relief-l l
Any exercising of these valves would require isolating the primary system from the Alternate Core Spray l
System, thus placing.the Alternate Core Spray System in j
an inoperative condition. Full stroking these valves can only be performed by injecting river water into the stainless steel clad reactor vessel causing possible l
corrosion and chemical problems requiring extensive l
clean-up.
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Disassembly for mechanical testing does not justify-breaching a reactor coolant pressure boundary on a routine basis when the valve can be periodically partial stroked with demineralized water.
These valves will be part-stroke exercised with demineralized water for operability each cold shutdown and refueling outage, but not more often than every 3 months.
Evaluation We agree with the licensee's basis and therefore feel that temporary relief should be granted for Category A/C valves 38-26-001 and 002 from the power operation and cold shutdown exercising requirements of Section XI. The licensee has demonstrated that full flow / full stroke exercising can only be performed by injecting river water into the reactor vessel resulting in chemical problems that would require a plant shutdown if performed during power operation. During cold shutdown, injecting river water would place primary chemistry out of specification for start-up and could cause. stress corrosion problems. This could result in a delay of reactor start-up due to chemistry operating specifications. We conclude that with the present plant-piping design only partial stroke exercising is possible using' demineralized water and isolating the sytem. However, we recomend that the utility further investigate a method to full stroke exercise these valves (i.e., a manual. full stroke -
exercise' af ter disassembly during refueling).
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E.. Manual Depressurization 1.
Category A/E Valves a.
Relief Request The licensee has requested specific relief from exercising Category A/E valve 62-24-005, bypass valve for 62-25-003, in accordance with the requirements of Section XI.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief
-This valve is normally locked in. the closed position and is~a passive valve, not requiring a change in position for any plant conditions. This valve will_be-leak tested and ver.ified locked, in accordance with he-
-ASME Code requirements for Categories A and E.
Evaluation
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l We agree with the licensee's basis, and _therefore feel.
l relief should be granted for Category A/E valve 62-25-003 from the requirements of Section XI._ This valve is-in its safety related position and is not-l required to open <x close-to mitigate.the consequences -
' of an accident or safely shutdown the plant.
Therefore, the~ operability of this valve is inconsequential-with. regard to the safety function which it performs.
We-' conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
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F.
Containment Isolation 1.
Category A/C Valves a.
Relief Request The licensee has requested specific relief from exercising Category A/C valve 52-26-009, seal inject make-up from condensate demineralizer containment isolation, in accordance with the requirements of Section XI and proposed to verify valve closure during refueling outages.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief The only safety related position for this valve is shut, and the only way to verify valve closure is during leak rate testing at ra*ueling outages.
This valve will be verified shut (its safety related position) during leak rate. testing performed at refueling outages.
Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for~ Category A/C valve 52-26-009 from the exercising-requirenents of Section XI. The licensee has demonstrated that due to
. lant design the only method available to verify valve p
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closure (its safety related position) is during leak testing. This valve is not equipped with valve position indicators 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 tesitng at refueling outages should demonstrate proper valve operability.
b.
Relief Request The licensee has requested specific relief from exercising Category A/C valve 65-26-001, feedwater containment isolation, in accordance with the requirements of Section XI and proposed to verify valve I
closure during refueling outages.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief Exercising this valve during plant operations would require stopping feedwater flow to the-reactor, thus placing the plant in an unstable condition resulting in a plant shutdown. The safety related function of this-valve is shut, and the only way to verify valve closure
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is by leak testing, whi_ch is beyond the scape of normal cold shutdown testing.
This valve will be verified shut during leak rate testing at refueling outages.
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Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valve 65-26-001 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 during leak
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testing. This valve is not equipped with valve position indicators 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 tesitng at refueling outages should demonstrate proper valve operability.
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IV.
AttacNnent I The following Category A, A/C, and A/E valves are leak tested to meet the Appendix J leak testing requirements in lieu of the Section XI requirements.
38-26-001 and 002 62-24-005 75-26-003 67-26-001 64-30 001 64-25-001 73-25-001, 002, 005, 006, 021, and 039 62-25-003 and 017 55-25-003 and 017 65-26-001 e
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I V.
Attachment II The following are Category A, B, and C valves that meet the testing requirements of the ASME Code Section XI and are not full stroke exercised every 3 months during plant operation. These valves are specifically identified by the owner and are full stroke exercised during cold shutdowns and refueling outages. EG&G has reviewed all valves in this attachment ind agrees with the licensee that testing these valvec during power operation is not possible due to the valve type and location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which tney are located.
A.
High and Low Pressure Emergency Core Spray 1.
Category B valve 53-25-001, low pressure core spray isolation, cannot be exercised during power operation. This valve is required to operate at low plant pressure (30 psi);
to cycle this valve during plant operations could cause an overpressure condition in the system which supplies the
~ valve ano depressurization of primary through one check valve.
In addition, to open this valve, it would require initiating a 30 psi pressure signal and a reactor low level signal, which will also actuate a reactor scram, MSIV closure, and auto start of the High Pressure Core Spray Pumps, which will thermal shock the core spray nozzle by injecting cold watar into the reactor vessel. This valve will be exercised at each cold shutdown and refueling outage, but not more often than every 3 months.
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Category B valves 53-25-002, 003, and 008, core spray pump suction and discharge isolations, cannot be exercised during power operation.
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These vaves are in the ECCS path and are normally open.
Operating these valves during reactor operation for inservice _ testing would render the High Pressure Core Spray System inoperative by isolating the pump's suction line from the overhead storage tank, or discharge line from the core spray bundle if either valve failed shut while exercising.
These valves will be exercised at each cold shutdown and refueling outage, but not more often and every 3 months.
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3.
Category B valve 53-25-004,- high pressure service water to core spray isolation, cannot be exercised during power operation. Exercising this valve during plant operation would introduce river water into the Core Spray Pump suction line. This exercising will require isolating and flushing this portion of the system which, in turn, places a backup water source for the High Pressure Core Spray System inoperative for-an extended period of time. This valve will be exercised at-each cold shutdown and refueling outage, but not more often than every 3 months.
4.
Category C valve 53-26-001, backup isolation from.the reactor plant to the low pressure core spray ~ and overhead storage tank, cannot be exercised during power operation.
Establishing flow through this valve would require opening 53-25-001 by_ initiating reactor low pressure (30 psi) and low water level signals, which would trip the reactor and close the MSIV.
In addition, to obtain flow through this check valve, the reactor pressure is required-to-be below-30 psig. This valve will be exercised at-each_ cold shutdown and refueling-outage, but not more of ten than every 3 months.
5.
Category C valves 53-26-002 and 003,' emergency core' spray-pump discharge checks, cannot be exercised during power--
operation.
l Any exercising of'these valves would require l'
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injecting cold high pressure core spray water into the reactor vessel, resulting in thermal shock to the core spray nozzle and cold water insertion to the reactor which would result in reactivity excursions and could result in a reactor trip. These valves will be exercised each cold
. shutdown and refueling outage, but not more often than every 3 months.
C.
Boron Injection and Purification 1.
Category B valves 60-25-001 and 005, boron tank outlet and outlet standby, cannot be exercised during power operation.
Valves 60-25-001 and 005 are in the Boron Injection System 4
path and are normally closed during reactor. operation. To test these valves, manual valves 60-24-004 or 010 must be closed, in order not to allow boron solution to be injected into the reactor coolant system by the Emergency Core Spray pumps. Subsequent steps after testing of 60-25-002 and 005 1
requires cicsing manual valves 60-24-003 and 60-25-001, 60-24-004, 60-24-010, 60-25-005 and out 60-23-005. Both i
Core Spray Pumps must be turned to "off" while testing and flushing valve 60-25-001, and 005 which~ places the Boron'
. Inject. System and the High Pressure Core Spray System in an inoperative condition. These valves will be exercised at each cold shutdown and refueling outage, but not more than every 3 months.
2.
Category B valves 60-25-002 and 006, boron to' primary system from core-spray, cannot be exercised during power i
operation. Valves 60-25-002 and 006 are in the Boron 1 l
Injection -System and. is normally closed.during reactor operation. To test either valve, it requires turning both Emergency Core Spray Pumps to "off'.
Also,-during the test
. opening either valve would. provide a flow path that eliminates Emergency Core Spray, which would place the Baron l
24 2
Inject System and the High Pressure Core Spray System inoperative if either valve f ailed in the open posj, tion during exercising.
These valves will be exercised at each cold shutdown and refueling outage, but not more often than every 3 months.
D.
Control Rod Drive Hydraulic 1.
Category B valves 32-98-001 through 029, control rod drive motor scram initiating valves cannot be exercised during power operation. Exercising these valves requires inserting the control rods, requiring plant shutdown. These valves will be exercised for operability each cold shutdown and refueling outage.
E.
Alternate Core Spray 1.
Category C valves 38-26-003 and 023, alternate core spray pumps discharge checks, cannot be full stroke exercised during power operation. The only full-flow / full stroke flow paths in this system are to the reactor or recirculation back to the river. The path to the reactor would introduce river water to the reactor vessel, resulting possible stress corrosion and in an out of specification primary water chemistry that would require a plant shutdown.
In addition, recirculation back to the river requires isolating the Alternate Core Spray System which, in turn, places the Alternate Core Spray System inoperative. These valves will be part stroked during power operation through the pump recirculation line and full stroked each cold shutdown and refueling outage, but not more often than very 3 months.
2.
Category B valves 38-30-001 and 002, redundant parallel alterate core spray isolations, cannot be exercised during pcwer operation. Exercising these valves during power 25
operation would introduce river water into the alternate-tore spray piping and possible stress corrosion. The flushing of this piping requires isolating the Alternate Core Spra: S stem from the reactor, thus placing the system i nop e rat i'. a.
These valves will be exercised for operability each cold shutdown and refueling outage, but not more often than every 3 months.
F.
Manual Depressurization 1.
Category B valves 62-25-013 and 014, shutdown condenser vents to containment, cannot be exercised during power operation. Exercising either of tnese valves during plant operations could cause plant depressurization into containment if any of the following conditions actuate the Shutdown Condenser System:
1.
MSIV closure 2.
Turbine Building steam isolation valve closure 3.
1325 psi reactor pressure These valves will be exercised for operability each cold shutdown, but not more often than every 3 months.
G.
Containment Isolation 1.
Category A valve 64-30-001, main steam inside containment isolation, cannot be exercised during power operation.
Movement of this valve from full open will initiate a full scram. This valve will be exercised each cold shutdown.
2.
Category A valve 64-25-001, main steam isolation bypass, cannot be exercised during power operation. To exercise this valve during plant operations would require inserting a 26 1
-. ~..
1 r
)
Y signal which would also actuate the Main Steam Isolation Valve, resulting in a scram. The valve will be exercised for operability each cold shutdtwn, i
1 3.
Category A ' valve 73-25-021, heating steam condensate return containment isolation,.cannot be exercised during-power l
i operation. To exercise this valve during plant operations would require inserting a high Containment Building pressure signal which would cause other safety system actuations and place the plant in an shutdown condition. The valve will te exercised for operability each cold shutdown.
t V
4.
Category A valve 55-25-003, containment vessel to off gas containment'isclation, cannot be exercised during power operation. To exercise this valve during plant operations would require inserting a high Containment Building pressure signal which would cause other safety system actuations and
~
place the-plant in a shutdown condition. This valve will be exercised for operability each cold shutdown.
~
I j
5.
Category A valve 56-25-001 startup water removal control j,
containment isolation need not be exercised during power r
operation. Thi.s is a passively shut valve (its safety.
related position) not required to change position to perform its safety function. This valve will be exercised for operability each cold shutdown.
6.
Category A valve 62-25-017, condensate to shutdown condenser containment isolation, cannot be exercised during-power operation. Exercising this valve-open would require placing the shutdown condenser in operation resulting in a rapid i
plant cooldown and'a plant shutdown. This' valve will be exercised during. cold shutdown.
27 i
VI.
Attachment III The P& ids listed below were used during the course of this review.
System P&lD Rev.
Shutdown Condenser 41-300-084 4
Core Spray 41-300-080 2
Seal Injection (CRD) 41-400-195 Main Steam M-12 P
Reactor Service Water 41-503385 L
High Pressure Service Water M-21 U
Seal Injection (RCP) 41-300-102 Purification 41-300-081 3
Component Cooling 41-400-416 2
Feed and Condensate M-13 T
Feed Water C/LR-53 1
Hydraulic Valve Accumulator 41-300-087 4
Air Ejector 0FF Gas 41-300-189 6
Low Pressure Service Water M-17 T
Gland Seal Steam C/LR-57 Shield Cooling 41-300-082 Demineralized Water C/LR-74 Instrumentation C/LR-79 Fuel Storage Well 41-300-079 3
Decay Heat Removal 41-300-083 2
Containment Vessel Penetrations 41-300-088-1 5
41-300-088-2 2
O 28
Vll. Attachment IV i
A.
The following valves are never full stroke exercised.
1.
Item B.1.a valve 53-26-004 2.
Item C.1.a valve 60-26-001 3.
Item 0.1.a valves 38-26-001 and 002 I
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l i
i
=
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4
l VIII. Attachment V t
The following items were discussed with the licensee on 20 October 1980, and the licensee agreed to make these revisions to the IST program submitted on 14 July 1980.
1.
A statement will be included in the introduction to explain that leak testing is done in accordance with the requirements of Appendix J in lieu of Section XI.
2.
The relief request for 62-25-001 and 011; manual depressurization valves, will be deleted.
3.
A relief request will be added to the IST program for passive valve 56-25-001, startup water removal control valve isolation.
4.
A relief request will be added to the IST program for valve 62-25-017, condensate to shutdown condenser isolation, to reflect the contents of Item G.6 of Attachment II of this report.
9 30