ML19351E934
| ML19351E934 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| 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-5245, NUDOCS 8012190547 | |
| Download: ML19351E934 (52) | |
Text
___
n E G c G,u,,..-
s onu tasu w fHev 1I Mp INTERIM REPORT Accession No.
Report No. _E66-EA-5245 Ccntract Program or Project
Title:
Systems Engineering Support Subject of this Document:
Safety Evaluation of the Inservice Testing Program for Pumps and Valves at the Rancho Seco Nuclear Generating Station (Docket No. 50-312) for the Period 10-18-79 through 6-18-81 Type of Document:
Safety Evaluation Report Author (s):
H. C. Rockhold J. M. Fehringer Date of Document:
November 1980 Risponsible NRC Individual and NRC Office or Division:
'lic!n" Nerses, NRC-DE This document was prepared primarily for preliminary orinternal use. It has not received full review and approval. Since there may be substantive changes, this document should not be considered final.
l EG&G Idaho, Inc.
Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
gqf Under DOE Contract No. DE-AC07-76tD01570 NRC eiN No.
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CONTENTS 1.
Introduction....................................................
1 II.
Pump Testing Program............................................
3 III.
Valve Testing Program...........................................
7 IV.
Attachment I....................................................
39 t
V.
Attachment II...................................................
40 VI.
Attachment III..............................,,,,,,,,,,,,,,,,,,,,
4 VII. Attachment IV...................................................
48 i
VIII. Attachment V....................................................
49 1
8 4
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1 0
I.
I,ntroduction
_ Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Sacramento Municipal i
Utility District (SMUD) for its Rancho Seco nuclear generating 1
station. The program applies to Rancho Seco,for the period October 18, 1979 through June 18, 1981. The working session with SMUD and Rancho Seco representatives was conducted on October 3,1979 and 4
October 4, 1979. The licensee resubmittal was issued on December 18,
- 1979 and was reviewed by EG&G Idaho Inc., to verify compliance of proposed tests of safety related class 1, 2, and 3 pumps and. valves t
with requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition, through the Summer of 1975 Addenda. SMUD has also requested relief from the ASME Code from testing specified
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pumps and valves because of practical reasons. These requests have been evaluated individually to. determine whether they have significant
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risk implications and whether the tests, as required, are indeed impractical.
4 i
The evaluation of the pump testing program and associated relief requests is contained in Section. II; the evalution of the valve 4
testing program and associated relief requests is contained in l
Section III. All evaluations for Sections II and III are the recommendations of EG&G Idaho, Inc.
Appendix J exemption requests for Category A valves currently being reviewed by the NRC are contained in Attachment I.
Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not exercised every 3 months are contained in Attachment II.
i 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 or that have a testing interval greater than each refueling outage and relief requests with insufficient technical basis where relief is not recommended are summarized in Attachment IV.
Items discussed via telephone conversations with Jack Uhl and Bill Garrett of Rancho Seco which may appear as differences between this report and the Rancho Seco IST Program are discussed in Attachment V.
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II. Pump Testing Program The IST program submitted by SMUD was examined to verify that all 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 SMUD basis for requesting specific relief and the EG&G evaluation of tnat request is summarized (A through C) below and grouped according to the system in which the pumps reside.
A.
All Pumps 1.
Relief Request Specific relief is requested from the requirements of IWR-4310 for the method of measurement of pump ' earing a
temperatures.
Code Requirement The temperature of all centrifugal pump bearings and main j
shaft bearing of reciprocating pumps shall be measured at points selected to be responsive to changes in the temperature of the bearing. Oil temperature, prior to the oil entering a cooler, shall be considered the bearing temperature.
Licensee's Basis for Requesting Relief
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No installed instrumentation exists for measurement of bearing metal or lubricant temperature for the following pumps.
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P-272-Spent Fuel Cooling P-291 A&B Reactor Building Spray P-318 Auxiliary Feedwater (Dual Drive)
P-319 Auxiliary Feedwater (Motor Drive)
P-472 A&B Nuclear Service Raw Water P-482 A&B Nuclear Service Cooling Water-P-705 A&B Boric' Acid 1
As an alternate, these pump bearing temperatures will be measured with a contact pyrometer.
Evaluation i
We feel the method of measurement of pump bearing temperature specified by the licensee meets the intent of-the code and provides the required information for evaluation of possible pump degradation. Therefore, we.
recommend relief be granted from the code specified method of measurement of bearing temperatures since the use of a contact pyrometer should convey the same information.
2.
Relief Request Specific relief is requested from the code specified frequency of pump performance testing.
Code Requirement An. inservice test shall be run on each pump,-nominally each month during normal plant operation.
It is recomended that this test frequency be maintained'during shutdown periods where this can reasonably be accomplished, although this is not mandatory.
If.it is not tested during plant shutdcwn,
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the pu_mp shall be' tested within one week after plant is.
returned to normal operation.
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Pumps that are operated more. frequently than every month need not be run or stopped for a special test, provided the plant log shows each such pump was operated at least once every month at the reference conditions and the quantities specified. were measured, obser ved, recorded, and analyzed.
Licensee'sBasisforRequestingReiief All of the pumps tested on the sheet entitled "ASME Code Pump Testing Requirements" are currently tested on a quarterly basis with the exception of the Spent Fuel Cooling Pump, P-272, which runs continuously and the-Boric Acid Addition Pumps, P-705A and P-705B, which are run on a frequency.of less than one month between runs. Test data'to' date indicate.that-testing these pumps on a quarterly basis is more than adequate for evaluating any degration which may occur. As an alternate the pump performance tests will be performed on a quarterly basis.
Evaluation We feel the licensee has not adequately demonstrated sufficient basis for going from the code specified frequency of monthly for pump testing. The licensee has stated they feel the quarterly testing frequency is more than adequate but has ' failed to provide the basis for. that determination.
Therefore, we feel relief should not be. granted unless the licensee provides that conclusive evidence..
B.
Nuclear Service Raw Water Pumps 1.
Relief Request Specific relief is requested from the code specified method of measurement'of pump flow rate for the Nuclear Service Raw Water pumps.
5
Code Requirement Section XI specifies that instrumentation utilized for measurement of pump flow rate have nominal maximum instrument errors of +2% of full scale, thus implying the method of measurement of flow rate be via a flowmeter.
Licensee's Basis for Requesting Relief No instrumentation is installed for measurement of flow rate for the Nuclear Service Raw Water Pumps. However, curves generated during the Startup Testing Program which show flow rate versus spray header pressure are available. As an alternate test flow rate will be obtained utilizing spray header pressure and the " flow rate vs. spray header pressure" curves. These curves show spray header flow rate (i.e., pump flow) vs. spray header pressure (which is measured during SP 203.07) and were empirically determined during the Rancho Seco Startup Testing Program.
Evaluation We feel the licensee has demonstrated the alternate method for measuring pump flow provides the information necessary for pump performance evaluation. Therefore, we feel relief should be granted from the code specified method of pump flow measurement since the licensee's proposed alternate test should convey the same information.
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III. Valve Testing Program Evaluation The IST program submitted by SMUD was examined to verify that all Class 1, 2, and 3 safety related valves were included in the program and that those valves are subjected to the periodic tests required by the ASME code, Section X1, and the NRC positions and guidelines. Our review found thdt 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 co'de 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 perform a pressure isolation function and a procedure for the licensee's use to incorporate these valves into the IST program. Each SMUD basis for requesting specific relief from testing valves and the EG&G evaluation of that_ request is summarized (B through L) below and grouped according to each specific system.
A.
General Considerations 1.
Testing of Valves Which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure-boundary have design pressures below the reactor coolant system operating pressure. Redundant isolation valves within the Class 1 boundary forming the interface between these high and low pressure systems isolate the low pressure systems from pressures which exceed their design limit.
In this role, the valves perform a pressure
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isolation function.
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L
The PGC considers the redondant 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, the fRC 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 fGC and EGLG Idaho, Inc.
believe that the following valves should be categorized 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:
RCS001 DHS015 SIM050 SIM041 RCS002 DHS016 SIM049 SIM040 CFS001 HV20001 SIM048 CF5002 HV20002 SIM047 The faC 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 l
licensee will provide to the PRC for evaluation the details of the testing method which clearly demonstrate the condition of each valve.
l l
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8
d 2.
ASME Code Section XI Requirements Subsection IWV-3410-(a) of the Section XI Code (which discusses full stroke and partial stroke) requires that Code t
Category A and B valves be exercised once every 3 months, j -
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 testing for Code Category E valves. Operational checks, with appropriate record entries, shall record the position of these valves before operations are performed and after operations are completed and shall verify that each valve is locked, or sealed. The limiting value of full stroke time
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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 i
b.
It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator l
power.
3.
Stroke Testing of Check Valves i
The NRC stated its position to the licensee that check valves whose safety function is.to open~are expected to be-f full stroked.
If only limited operation is possible (and it T
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has been demonstrated by the licensee and agreed to by the NRC) the check valves shell be partial-stroked.
Since disc position is not always observable, the NRC staff stated that verification of the plant's ssfety analysis design flow rate through the check valve would be an adequate demonstration of the full-stroke requirement. Any flow rate less than
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design will be considered part-stroke exercising unless it can be shown that the check valve's disc position at the lower flow rate would be equivalent to or greater than the design flow rate through the valw. The licensee agreed to conduct flow test to satisfy the above position.
4 Test Frequency of Check Valves Tested at Cold Shutdowns The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Category A and B valves and once every nine months for Category C valves.
It is our 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 need not be performed more of ten than once every three (3) months for Category A, B and C valves."
5.
Licensee Request for Relief to Test Valves at Cold Shutdown The Code permits valves to be tested at cold shutdown, and i
the Code conditions under which this is permitted is noted i
in Appendix A.
These valves are specifically identified by the licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it will not be necessary to grant relief; however, during our review of the 10
licensee's IST program, we have verified that it was not practical to exercise these valves during power operation and that we agree with the licensee's basis.
It should be noted that the NRC differentiates for valve testing purposes between the cold shutdown mode and the refueling mode. That is, for testing purposes the refueling mode is not considered as a cold shutdown.
6.
Changes to the Technical Specification In a November 1976 letter to the licensee, the NRC provided an attachment entitled, "NRC Guidelines for Excluding Exercising (Cycling) Tests of Certa'... Valves During Plant Operation." The attachment stated tha one train of a redundant system such as in the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not be cycled 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 limiting conditions for operation-to exist at any one time and if the system is not restored to meet the requirements within the time period specified in a plant's Technical Specifications (T.S.), the reactor is required to be put in some other mode. Furthermore, prior to initiating repairs all valves and interlocks in the system that provide a duplicate function are required to be tested to demonstrate operability imediately and periodically thereafter during power operation. For such i
plants this situation could be contrary to the NRC guideline as-stated in the document mentioned above.
It'should be noted that' reduction in redundancy is not a basis for a T.S.
change nor is it by itself a basis for relief from exercising in accordance with Section XI.
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The licensee has agreed to review the plant's T.S. and to
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consider the need to propose T.S. changes which would have f
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
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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 j
demonstrates that the valve's failure would cause a loss of j
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.
I' 7.
Safety Related Valves N
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 l
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
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include some non-code Class valves.
l It should be noted that the licensee may have included non-safety related valves in their Inservice Test Program as a decision on the licensee's part to expand the scope of their program.
8.
Valve Testing at Cold Shutdown Inservice valve testing at cold shutdowr. is acceptable when the following conditions are met:
It is understood that the licensee is to commence testing as soon as.the cold shutdown i
12
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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 /> after shutdown and continue until complete or plant is ready to return to power. Completion of all valve testing is not a prerequisite to return to power. Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to meet the Code specified testing frequency.
For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
9.
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 l
applicable leak test procedures and requirements for CIVs are determined by 10 CFR 50 Appendix J.
Relief from i
j 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 g of IWV-3420 until relief is requested from these paragraphs.
It should be noted that these paragraphs are only_ applicable where a i
i 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 or the common defense and security of the public.
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- 10. 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 amended, they will amend their IST program accordingly.
B.
Category C Valves a.
Relief Request Specific relief is requested from the quarterly and cold shutdown exercising requirements of Section XI for the reactor internals vent check valves.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief l
These valves are located on the Core Support Assembly of the Reactor Internals and, therefore, cannot be stroked quarterly or at cold shutdown. As an alternate these valves will be stroked during refueling outages by lifting the disc.
14 L
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for the reactor internals vent check valves. These che,ck valves are physically located inside the reactor vessel on the core support assembly and utilizing flow to exercise these valves would require reverse flow in the RCS which cannot be accomplished during power operation or cold shutdown.
We feel the licensee's proposed alternate test of full stroke exercising these valves manually during refueling outages adequately demonstrates proper valve operability.
C.
Make Up/High Pressure Injection System 1.
Category C Valves a.
Relief Request Specific relief is requested from the exercising requirements of Section XI for the following valves.
HV23801 RCS B Loop HPI SIM049 RCS B Lcop HPI SIM050 RCS B Loop HPI SIM047 RCS B Loop HPI SIM041 RCS A Loop HPI SIM037 RCS A Leop HPI SIM040 RCS A Loop HPI SIM036 RCS A Loop HPI ll*
Code Requirement Refer to valve testing paragraph A.2.
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Licensee's Basis for Requesting Relief SIM036 and SIM037 are partial stroke exercised (closed-then open) but no verification is made because they are inaccessible during power operation.
- SIM036, SIM037, SIM049, SIM050, SIM047, SIM041, SIM040, and HV23801 cannot be full stroke exercised quarterly because the only available flow path is connected to the RCS. Design flow of 500 gpa cannot be achieved by the centrifugal type Make Up/High Pressure Injection Pumps when pumping into the RCS during power operation. These valves cannot be partial stroked during power operation because thermal shocking of the injection nozzles would result. These valves cannot be full stroke exercised during cold shutdown because power to the Make Up/High Pressure Injection Pumps and valves must be racked out to provide low temperature overpressure protection. As an alternate, these valves will be full stroke tested during each refueling outage during the SFAS Digital Channel tests.
Evaluation We agree with the licensee's basis and therefore feel relief should be grar.ted from the exercising requirements of Section XI for these valves.
SIP 436 and SIM037 are verified open (partial stroke) during power operation since these valves are in the normal charging flowpath. However, the remainder of these valves cannot be partial stroke exercised during power operation since unnecessary thermal shocking of the injection nozzles would result. Additionally, the licensee has demonstrated that full stroke exercising of these valves during power operation cannet be accomplished since the Make Up/High Pressure Injection pumps cannot develop full design accident flow when 16
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i pumping into the RCS during power operation. During j
cold shutdowns the Make Up/High Pressure Injection pumpt and valves must have their power racked out to j
prevent a low temperature overpressurization event from occurring. We feel the licensee's alternate test of full stroke exercising these valves during refueling outages is sufficient to demonstrate proper valve operability.
o.
Relief Request Specific relief is requested from the exercising requirements of Section XI for the following valves.
l SIM045
'B' HPI pump discharge check SIM058
'A' HPI pump discharge check SIM002 Make-up pump discharge check Code Requirement j
Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief These valves cannot be full stroke tested quarterly because during power operation the only available flow path to utilize for testing is connected to the RCS.
Design flow of 500 gpm cannot be. achieved by the centrifugal Make Up/High Pressure Injection Pumps when I
pumping into the RCS during power operation. These i
valves cannot be full stroke exercised during cold shutdown because power to the Make Up/High Pressure Injection Pumps and Valves must be racked out to provide low temperature overpressure protection. As an alternate test these valves will be partial stroke exercised quarterly and full stroke ~ exercised during refueling outages.
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Evaluation We agree with the licensee's basis and feel relief should be granted from the exercising requirements of Section XI for valves SIM045, SIM058 and SIM002. The licensee has shown that the only available flowpath for full stroke exercising these valves is into the RCS and
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the Make Up/High Pressure Injection pumps cannot develop full flow when the RCS is at operating pressure. During cold shutdown power to the Make Up/High Pressure Injection pumps must be racked out to prevent a low temperature overpressurization event from occurring. We feel the licensee's proposed alternate test of partial stroke exercising these valves quarterly and full stroke exercising during refueling outages is sufficient to demonstrate proper valve 3
operability.
1 c.
Relief Request 4
Specific relief is requested from the exercising requirements of Section XI for the following valves.
SIM052
'A' Loop BWST Outlet Check r
BWS044
'A' loop CBAST Outlet Check i
l BWS019
'B' Loop CBAST Outlet Check l
SIM043_
'B' Loop BWST Outlet Check I-Code Requirement i
Refer to valve testing paragraph A.2.
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Licensee's Basis for Requesting Relief These valves cannot be exercised quarterly because exercising these valves with the plant in operation t
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would cause highly concentrated boric acid to be
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injected into the RCS by the Make-Up Pump through the r
Pressurizer Level Control valve and the RCP seals.
This would cause unwanted changes in boric acid i'
concentration in the RCS and could result in unwarranted transients. These valves cannot be exercised during cold shutdo'wn because power to the Make Up/High Pressure Injection pumps and valves must remain racked out to provide low temperature overpressure protection. As an alternate these valves will be full stroke exercised during refueling outages.
Evaluation
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4 We agree with the licensee's basis and feel relief should be granted from the exercising requirements of Section XI for check valves SIM052, BWS044, BWS019 and SIM043. The licensee has demonstrated that full or l
partial stroke exercising these valves during power operation would result in' injection of higher concentration boric acid into the RCS resulting in i
power transients and potentially causing plant-l
- shutdown. During cold-shutdowns the Make Up/High 4
Pressure Injection pumps power must be racked out to prevent a low temperature overpressurization event from i.
occurring. We feel the. licensee's proposed alternate test of full stroke exercising these valves during refueling outages is sufficient to demonstrate proper i
2 valve operability.
v D.
. Decay Heat / Core Flood Systems 1.
Category A/E Valves 4
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Relief Request a
j Specific relief is requested from the exercising i
requirements of Section XI for the following valves.
CFS003 Core Flood Tank Sample R.B. Iso.
f CFS004 Core Flood Tank Drain R.B. Iso.
CFS005' N to 'A' Core Flood Tank R.B. Iso.
2 j
CF5006-N to 'B' Core Flood Tank R.B. Iso.
2 CFS009 Make Up to 'A' Core Flood Tank R.B. Iso.
4 CFS010 Make Up to 'B' Core FlocJ Tank R.B. Iso.
CFS011 BA Addition to 'A' Core Flood Tank R.B. Iso.
CFS012 BA Addition to 'B' Core Flood Tank R.B. Iso.
Code Requirement l
Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief l
These valves are manual, locked closed, passive j
containment isolation valves which are not required to l
be moved to perform their safety related functions.
Evaluation
?
We agree with the. licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for Category A/E valves i
CFS003,. C?S004, CFS005, CFS0%, CFS009, CFS010, CFS011 and CFS012. These valves are locked in their safety related position and are not required to change l
position 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 i
safety function which they perform. We conclude that the quarterly stroke and stroke. time measurements are meaningless for' passive valves.
20 i
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2.
Category C Valves a.
Relief Request Specific relief is requested from the exercising requirements of Section XI for the following valves.
BWS003
'A' Loop BWST Discharge Check BWS004
'B' Loop BWST Discharge Check DHS003
'A' Loop Decay Heat Pump Suction Check DHS004
'B' Loop Decay Heat Pump Suction Check Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief It is not possible to fully stroke these valves quarterly because of recirculation piping will not pass the required flow.
It is not possible to stroke these valves during cold shutdown because the BWST is isolated from the Decay Heat Pump suction with the RCS Decay Heat suction valves open for decay heat removal from the RCS.
In addition, stroking these valves during cold shutdown would cause unwanted boron concentration in the RCS. As an alternate these valves will be partial stroke exercised quarterly and full stroke exercised during refueling outages.
Evaluation We agree with the licensee's basis and therefore feel relief-should be granted from the requirements of Section XI for check. valves BWS003, BW5004, OHS 003 and DHS004. The licensee has-demonstrated that full stroke exercising these valves during power operation cannot i'
I.
be accomplished since the DHR/LPI pump recirculation line cannot pass enough flow for full stroke exercising. The only full flow flowpath for this system is into the RCS and the OHR/LPI pumps cannot develop enough head to discharge into the operating RCS. During cold shutdown the DHR/LPI pumps are utilized for the decay heat removal function and cannot take a suction from the BWST for exercising these valves. Therefore, we feel the licensee's proposed alternate test of partial stroke exercising these l
valves during power operation and full stroke exercising during refueling outages is sufficient to demonstrate proper valve operability, b.
Relief Request Specific relief is requested from the exercising requirements of Section XI for the following valves.
RCS001
'A' Loop DHS to RCS Inlet Check CFS001'
'A' Loop CFS to RCS Inlet Check RCS002
'B' Loop DHS to RCS Inlet Check CF5002
'B' Loop CFS to RCS Inlet Check Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief The function of these valves is to' provide protection to the Decay Heat'and Core Flood Systems from Reactor
- Coolant System pressure during power operation while allowing Low Pressure'and Core ~ Flood Injection.
Stroking these valves during power operation is impossible. Full stroke testing these valves can only 22'
be accomplished by rapid depressurization of the Reactor Coolant System. This could result in major equipment damage. As an alternate these valves will be partial stroke exercised during cold shutdowns and refueling outages. Verification of actual disc movement will be performed at refueling outages.
Evaluation The licensee has demonstrated that utilizing flow to full stroke exercise valves RCS001, RCS002, CFS001 and CFS002 is impractical in that it would require a rapid depressurization of the RCS that would simulate a large LOCA to create the flow required to full stroke exercise these valves. However, we feel the licensee has not fully investigated all alternate means of full stroke exercising these valves such as disassembly of the valve and manually exercising the disc. Therefore, we feel relief should not be granted unless the licensee can demonstrate that all alternate test methods are impractical.
E.
Containment Building Spray System 1.
Category A/C/E Valves a.
Relief Request Specific relief is requested from the exercising requirements of Section XI for valves CBS009 and CBS010, containment building spray header inlet stop check valves.
Code Requirement Refer to valve testing paragraph A.2.
23
r Licensee's Basis for Requesting Relief No means are available to isolate the Containment Building Spray headers from these valves. They cannot be stroked quarterly during power operation because the result would be a spray down of the containment building. Provision of header isolation cannot be accomplished during power operation because entry into inaccessible areas would be required. Provisions required to preclude spray down of the Containment Building are too involved to be performed during normal cold shutdowns. As an alternate these valves will be partial stroke exercised during refueling outages.
Evaluation The licensee has demonstrated that exercising valves CBS009 and CB5010 with flow would result in extensive equipment damage to electrical components, lagging, etc., and would require a large decontamination effort since the water utilized to stroke these valves would be contaminated water from the BWST. However, we feel the utility has not fully investigated all alternate means of full stroke exercising these valves such as disassembly of the valves and manually exercising the disc to verify freedom of movement. Therefore, we feel relief should not be granted from the exercising requirements of Section XI unless the licensee can demonstrate all alternate means are indeed impractical.
24 M
2 4
2.
Category C Valves i
i a.
Relief Request l
Specific relief is requested from the exercising requirements of Section XI for the following valves.
SFV29016
'B' Loop CBS N 0H Suction Check a
CBS028
'B' Loop CBS N 0H Suction from 'A' Loop a
CBS022
'B' Loop CBS N OH Suction Check SFV29015
'A' Loop CBS N OH Suction Check 1
a CBS021
'A' Loop CBS N,0H Suction Check CBS027
'A' Loop CBS N 0H Suction from 'B' Loop a
CBS035
'A' Loop DHS N 0H Suction Check a
CBS036
'B' Loop.DHS N,0H Suction Check
- l Code Requirement l
Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief Full stroking these valves would allow injection of.
N 0H solution into Decay Heat System piping and the a
Borated Water Storage Tank. As an alternate these
{
valves will be partial stroke. exercised during refueling outages except CBS035 and CBS036 for which no alternate testing is proposed.
t i
l Evaluation i
We agree with the licensee's b' asis for not exercising these valv'es during power operation since. utilizing j
flow to exercise these. valves would introduce highly.
corrosive N OH into the decay heat. system piping and a
into the Borated Water Storage Tank. However, we feel i
25 i
4 s
+,_
y p-.,,
,-w-,c,,
- _.,,,,,-en,....
~-nm
,,m.----..,,
,.,.,4--,+-.--
,.-m,,
m.y.,
_ - =.. - - -. -
i the licensee has not fully investigated all methods of exercising these valves, such as valve disassembly, and therefore we reconrnend relief not be granted from the exercising requirements of Section XI for these valves.
b.
Relief Request I
I Specific relief is requested from exercising requirements of Section XI for valves CBS504 and l
CBS505, spray additive tanks vacuum breakers.
Code Requirement i
Refer to valve testing paragraph A.2.
t Licensee's Basis for Requesting Relief
?
These check valves serve as vacuum breakers for protection of the N 0H storage tanks, and cannot be a
full stroke tested at any time without addition of i
N,0H to the Decay Heat System or BWST. As an alternate these valves will be partial stroke exercised during the draining of the Reactor Building Spray I
Additive Tanks during refueling outages.
i i
' Evaluation We do not agree with the licensee's basis for not exercising valves CBS504 and CBS505. We feel the licensee has not fully investigated alternate test I
methods, such as mechanical exercising or disassembly of the valves. Therefore, we recommend relief not.be
. granted from the exercising requirements of Section XI for these valves.
4 9
26
,.a
_ _...~._,
F.
Main Steam /Feedwater/ Auxiliary Feedwater Systems 1.
Category A, A/C, and A/E Valves a.
Relief Request Specific relief is requested from the exercising requirements of Section XI for the following valves.
MSS 066 Main Steam to Condenser MSS 012 Main Steam to Condenser MSS 067 Maisi Steam to Condenser MSS 065 Main Steam to Condenser MSS 064 Main Steam to Condenser MSS 063 Main Steam to Condenser MSS 011 Main Steam to Condenser MSS 062 Main Steam to Condenser MSS 060 Main Steam to Condenser Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Rea;usting Relief These valves are manual, closed, passive Containment isolation valves which are not required to be moved to perform their safety functions.
Evaluation We-agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for Categcry A valves MSS 066, MS5012, MSS 067, MSS 065, MSS 064, MSS 063, MSS 011, MSS 062 and MSS 060. These valves are normally in their 27 i
safety related positinn and are not required to change position to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
b.
Relief Request Specific relief is requested from the exercising requirements of Section XI for Category A/C valves PSV20533, PSV20534, and PSV20544 through PSV20559, main steam code safety valves.
Code Requirements Refer to valve testing Paragraph A.2.
Additionally, IWV-2110, footnote I states " Combination of categories, such as categories AC are to be used when more than one distinguishing category characteristic is applicable.
In such cases, all requirements of each_of the individual categories are applicable, although duplication or repetition of comon testing requirements is not necessary."
Licensee's Basis for Requesting Relief These valves are pressure relief valves which are located on the main steam Reactor Building penetrations. They are tested as Category C pressure relief devices. Additionally, they are leak tested during the Appendix J penetration leak test. Quarterly exercising'of these valves would contribute nothing to' verifing these valves perform their safety related -
functions.
28
Evaluation l
We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for valves PSV20533, PSV20534, and PSV20544 through,PSV20559. The safety related functions of these valves are to maintain a leak limiting barrier for containment isolation, verified by leak testing at refuleing outages, and providing over pressure protection of the OTSG's, verified by the periodic relief / safety valve testing.
We feel quarterly exercising these valves would not contribute to the assurance these valve are performing their safety related functions but would instead cause valve degradation and could require plant shutdown for repairs so the valves could perform their safety related functions.
j c.
Relief Request Specific relief is requested from the exercising i
requirements of Section XI for valves FWS101 and FW5102, OTSG Chemical Cleaning Penetration Isolation Valves.
I Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief FWS101 and FWS102 are manual, locked closed, passive Containment Building isolation valves which are not required to stroke to perform their safety function.
1 e
29.
t
Evaluation We agree with the licensee's basis and therefore feel relief should be granted f rom the exercising requirements of Section XI for Category A/E valves FWS101 and FWS102. These valves are locked in their safety related position and are not required to change position 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.
G.
Auxiliary Steam System 1.
Category A/C/E and A/E Valves a.
Relief Request Specific relief is requested from the exercising requirements of Section XI for valves ASC048 and ASC049, auxiliary steam reactor building penetration isol ati ons.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief ASC048 and ASC049 are passive, locked closed, Containment Building isolation valves and do not need to move to provide their safety function.
30
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for Category A/E valve ASC048 and Category A/C/E val,ve ASC049. These valves are locked in their safety related position and are not required to change position 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.
H.
Heating and Ventilat'on Systems 1.
Category A and A/E Valves a.
Relief Request Specific relief is requested from the exercising requirements of Section XI for valves HGS 013 and HGS 012, ILRT Test Cart R.B. Penetration Isolation.
l Code Requirement t
Refer to valve testing paragraph A.2.
l j
Licensee's Basis for Requesting Relief I
l HGS 013 and HGS 012 are manual, passive, locked closed l
Containment isolation valves which are not required to move to provide their safety function. These' valves provide _ access to the Containment Building for instrumentation during integrated leakage rate testing.
i 31 L
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for Category A/E valves HGS 013 and HGS 012. These valves are locked in their safety related position and are not required to change position to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is incnnsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves, b.
Relief Request Specific relief is requested from the exercising requirements of Section XI for valves HGS 005 and HGS 010, Hydrogen Purge Make Up Isolation.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief HGS 005 and HGS 010 are manual, passive, locked closed Containment isolation valves which are not required to be moved to provide their safety function.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for Category A valves HGS 005-and HGS 010. These are manual passive valves normally 32
_ _ _ -. = _. _ _ _.. _ - _
1 in their safety related position and are not required to change position to mitigate the consequences of an accident or safely shut down the plant. Therefore, the 4
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.
I.
Service Air System i
1.
Category A/E Valves a.
Relief Request Specific relief is requested from the exercising j
requirements of Section XI for valves SAS052 and SAS054, R.B. Service Air Penetration Isolation.
1 Code Requirement t
Refer to valve testing paragraph A.2.
i Licensee's Basis for Requesting Relief i
SAS052 and SAS054 are manual, passive, locked closed i
Containment isolation valves which are not required to l
move to provide their safety function.
4 Evaluation We agree with the licensee's basis.and therefore feel relief should be granted from the exercising requirements of Section XI for Category A/E valves SA5052 and SAS054. These valves are locked in their safety related position and are not required to change position to mitigate the consequences of an accident or i
33
1 5
r i
safely shut down the plant. Therefore, the operability t
of these valves is inconsequential with regard to the i
j safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are
~
meaningless for passive valves.
J.
Nitrogen Gas System 1.
Category A/C and A/E Valves i
a.
Relief Request i
Specific relief is requested from the exercising j
requirements of Section XI for valves NG5011, NGS017
)
and NGS018, R.B. Nitrogen Penetration Isolation valves.
Code Requirement i
l Refer-to valve testing paragraph A.2.
t Licensee's Basis for Requesting Relief l
NGS011, NGS018, and NGS017 are normally closed, passive Containment isolation valves which are not required to move to provide their safety function.
Evaluation i
We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI.for Category A/C valves NGS011 and NGS018 and Category A/E valve NGS017. These are passive valves normally in their safety related position and are not required to change position 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 -
34
.. -... ~....., _ _.
function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
K.
Demineralized Water System 1.
Category A/C and A/E Valves i
a.
Relief Request Specific relief is requested from the exercising requirements of Section XI for valves DMWO24 and DMWO25, R.B. Demineralized Water Penetration Isolation valves.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief DMW024 and DMW025 are normally closed, passive Containment isolation valves which are not required to move to provide their safety function.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for Category A/C valve DMW025 and Category A/E valve DMWO24. These are
_ passive valves normally in their safety related position and are not required to change position 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 35
function which they perform. We conclude that the quarterly stroke and stroke time measurements cre meaningless for passive valves.
L.
All Systems 1.
Category A and B Valves a.
Relief Request Specific relief is requested from the requirements of paragraph IWV-3420 of Section XI for all Category A valves listed in the IST program.
Code Requirement Refer to Valve Testing Paragraph A.2 and Section XI Paragraph IWV-3420.
Licensee's Basis for Requesting Relief Only valves which provide a Reactor Building isolation function have been categorized as A valves in this program.
These valves are listed as Category A valves because seat leakage is important to their safety function; however, these valves are adequately and more applicably tested under requirements of the Rancho Seco Technical Specification which are based upon Appendix J Requirements of 10 CFR 50.
As an alternate Appendix J type testing per SP205.01, Reactor Building Integrated Leakage Test and SP205.02, Local Component Leak Testing, as applicable will be performed.
36
4 i
Evaluation i
We agree with the licensee's basis and therefore feel i
relief should be granted from the leak testing l
requirements of Section XI for all Category A valves in the IST program that are tested per 10 CFR50 l
Appendix J.
We feel the Appendix J requirements meet the intent of Section XI and present piping configurations were installed to meet these requirements. Refer to Section A Paragraph 9 of this report for more information.
i b.
Relief Request 1
Specific relief is requested from the requirements of paragraph IWV-3410(g) for all Category A and B valves listed in the IST program.
i 1
Code Requirement l
If a valve f ails to exhibit the requirei change of valve stem or disc position by this testing, corrective action shall be initiated immediately.
If the condition is not, or cannot be corrected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,'the valve shall be declared inoperative.
When corrective action is required as a result of tests l
made during cold shutdown, the condition shall be corrected before startup. A retest showing acceptable l
operation shall be run following any required corrective action before the valve is returned to i
service.
Licensee's Basis for Requesting Relief Limiting Conditions for Operation in the Rancho Seco j
Technical Spectfications specify equipment which is-37 i
..,e
,,,_-_,...~,-,-y
,,.__.__...-,...-_..,-,-,u.,..,...,
,y.
,.... ~.
required to be in service during various operational levels.
These Technical Specifications have been analyzed with respect to plant safety and should govern in all situations.
As an alternate we will utilize Rancho Seco Technical Specifications to detecmine
~
operational restrictions.
i Evaluation IWV-3410(g) requires that a valve declared inoperative as a result of cold shutdown testing, be repaired prior to startup of the plant. We feel the plant technical specifications address this condition and have allowed specific limiting conditions for operation and permit plant operation with sections of safety systems out of service for specific time periods.
Therefore we feel relief should be granted from the requirements of Paragraph IWV-3410(g) of Section XI.
1 I
I i
38
IV. Attachment I During the course of our review of the Rancho Seco IST program we found no valves that need further review by the NRC Appendix J review committee.
W l
l i
l t
I
(
39
V.
Attachment II i
The f ollowing are Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not full stroke
~
exercised every three months during plant operation. These valves are specifically identified by the owner and are full stroke exercised during cold shutdowns and refueling outages.
EG&G has reviewed all valves in this attachment and agrees with the licensee that testing these valves during power operation is not possible due to the valve j
type and location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.
A.
Make Up/High Pressure Injection System i
1.
Category A valves SFV22023 and SFV22009 and Category B valve SFV22025, RCS letdown isolation valves, cannot be exercised 4
during power operation since f ailure to reopen af ter testing 1
would result in a loss of pressurizer level control'and could require plant shutdown.
These valves will be full i
stroke exercised during cold shutdowns.
2.
Category A valve SFV23616, Reactor Coolant Pump (RCP) seal l
injection isolation, cannot be exercised during power operation since closure of this valve would isolate seal water to all RCP seals which could require plant shutdown for repairs. This valve will be full stroke exercised
(
during cold shutdowns.
3.
Category A/C check valves SIM019, SIM020, SIM021 and SIM022, RCP seal water injection checks, cannot be exercised during power operation since closure of these valves would isolate I
seal water to the RCP_ seals resulting in seal damage which could require plant shutdown for repairs. These valves wil.l' be full stroke exercised during cold shutdowns.
i 40 -
4.
Category A valves SFV24004 and SFV24013, RCP Seal Return Isolation valves, cannot be exercised during power operation since closure of these valves would isolate RCP seal return flow which may cause an imbalance of seal stage pressures and subsequently loss of stage flow. This would result in degradation of sealing capability and could cause seal f ailure which would require plant shutdown for repair.
^
These-valves will be full stroke exercised during cold shutdowns.
5.
Category B valve SFV23508 Make Up tank isolation and Category C check valve PLS045, Make Up tank outlet check cannot be exercised during power operation since closure of-these valves would cause a loss of suction to the Make-Up Pump and therefore result in loss of RCP seal water flow and normal RCS Make Up flow. Loss of seal water flow would result in seal damage and require plant shutdown for repai rs. Loss of normal RCS Make Up flow would result in loss of pressurizer level control and would require plant s hutdown. These valves will be full stroke exercised during cold shutdowns.
B.
Decay Heat / Core Flood System 1.
Category C valve DHS059, Decay Heat System to Pressurizer Spray check valve, cannot be exercised during power operation.
Its function is to protect the Decay Heat. System -
from Reactor Coolant System pressure during periods of normal operation while allowing use of the Decay Heat System to spray the Pressurizer during periods when the plant is shutdown. This valve will be full stroke exercised during cold shutdowns.
41
- - - ~ -.. -
2.
Category B valves HV20001 and HV20002, Decay Heat System (DHS) Suction from RCS, cannot be exercised during ' power operation. The function of these valves is to protect the Decay Heat System.from Reactor Coolant System pressure during power operation. To stroke these valves during power operation would reduce that protection and would require bypassing valve control interlocks which prevent the valves from opening if RCS pressure is greater than 255'psig.
These valves will be full stroke exercised during cold shutdowns.
3.
Category B valve HV26011, Decay Heat to Pressurizer Spray Isolation,'cannot be exercised during power operation since opening this valve could subject the low pressure Decay Heat Removal System to the high Reactor Coolant System pressure.
This valve will be full stroke exercised during cold shutdowns.
4.
Category B valve HV20003, Decay Heat Suction Isolation from RCS for Mode 2. cooling, cannot be exercised quarterly because DHS461 would have to be closed to avoid introducing voids into the Decay Heat Pump suction and DHS461 is inaccessible during power operation.
Introduction of voids into Decay Heat Pump suction piping would cause water hamer and pump cavitation which could result.in significant pipe, 3
pipe support and pump damage.
This valve will be full stroke exercised during'ccid shutdowns.
5.
Category A valves' HV26105 and HV26106, Decay Heat Removal System Suction from Reactor Building Isolation Valves, cannot be exercised during-power operation since f ailure 'in l
the open position would cause-a loss of containment integrity.. These valves will be individually full stroke-l exercised during cold shutdowns while the redundantLleg is-l providing ' decay heat removal.
1 I
l' 42
6.
Category A/C/E valves DH5015 and DH5016, DHS to RCS stop check valves, cannot be exercised during power operation since the DHS pumps cannot develop enough discharge head to pump into the RCS during power operation. These valves will be full stroke exercised during cold shutdowns.
C.
Main Steam /Feedwater/ Auxiliary Feedwater Systems 1.
Category A valves TV-1, 2, 3, and 4, Turbine Throttle Stop Valves, cannot be "f ailed" closed and stroke timed during power operation since the only method of accomplishing this would be by tripping the Main Turbine Auto Stop Control Oil which would trip the main turbine. As an alternate these valves will be individually stroked shut slowly quarterly to avoid plant transients and will be full stroke exercised and timed by tripping during cold shutdowns.
2.
Category C valves FWS047 and FW5048, Auxiliary Feedwater Pumps discharge checks and FWS061 and FWS062, Auxiliary Feedwater OTSG Inlet check valves cannot be exercised during power operation since establishing flow through these valves would inject cold water into the OTSG's causing thermal shocking of the OTSG's. These valves will be full stroke exercised during cold shutdowns.
3.
Category C valves FWS013 and FWS014, Main Feedwater to OTSG's Inlet Checks, cannot be exercised during power operation since shutting these valves during power operation would isolate'feedwater to the respective OTSG which could result in a reactor trip. These valves will be full stroke exercised shut during cold shutdowns.
4.
Category A valves, FV20575, FV20576, FV20529 and FV20530, Main Feedwater Startup and Control valves, cannot be exercised during power operation since' stroking these valves i
f 43
could secure feeceater to the OTSG and cause a reacto-trip.
These valves will be full stroke exercised curing cold shutdtwn.
5.
Category A Valves hY20593 and HY20597, main steam to
~
reheaters, cannot be exercised during po er operation since shutting and re-opening the these valves would cause severe thermal transients on the tubes and tube sheets cf the reheaters and could cause cocponent f ailure and require plant shutccan for repair. These valves will be full strole exercised during cold shutscwns.
6.
Category A valves PY20561, PY20563, PV20563, and PV20566, main steam turbine bypass valves, cannot be exercised during power operaticn since isolation of these valves would subject personnel to possible steam leaks.
Exercising these valves regularly would cause rapid degradation of the valves since greater than 900 psig differential pressure normally exists across the valve seat and disc and regular operation would cause wire crawing the disc and seat causing them to leak excessively and could require plant shutdown for repairs.
These valves will be full strcke exercised during colo shutdowns.
7.
Categcry A valves PV20562 A, B, and C and PV20571 A, B, and C, main steam atmospheric dump valves, cannot be exercised during paaer operation since isolation of these valves would subject personnel to possible steam leaks.
Exercising these valves regularly would cause rapid degradation of the valves since greater than 900 psig differential pressure normally exists across the valve seat and disc and regular operation would cause wire drawing the disc and seat causing them to leak excessively and could require plant shutdown for t
rep ai rs.
These valves will be full stroke exercised during cold shutdowns.
i 44 l
l
~
D.
Component Cooling Water i
1 1.
-The following Category A.and A/C valves cannot be exercised I
during power operation.
SFV 46014 Component Cooling Water Supply Containment Building Isolation ~(Outside)
SFV 036 Component Cooling Water Supply Containment j
Building Isolation (Inside) i SFV 46203 Component Cooling Water Return Containment-Building Isolation (Inside)
SFV 46204 Component Cooling Water Return Containment Building Isolation (Outside)
SFV 46906 Control Rod Drive Cooling Water Supply:
j Containment Building Isolation (Outside)
CCW 194 Control Rod Drive Cooling Water Supply f
Containment Building Isolation (Inside)
SFV 46907 Control Rod Drive Cooling Water Return Containment Building Isolation Valve (Inside) s SFV 46908-Control Rod Drive Cooling Water Return Containment Building Isolation Valve (Outside)
Exercising these valves during power operation would isolate' cooling water to the cooled' component causing component-failure and possibly causing a reactor trip.or require' plant J
' shutdown _ for - repair. ' These valves will be full-stroke exercised during_ cold shutdowns.
4 45;
- s. -
,n,.,
v,..+,
n
-,,, -,-, n
,-,,,,,n,,
,,,,,., ~
n
--,a,-
c.,,
E.
Heating and Ventilation System 1.
Category A valves SFV53612 and SFV53613, Reactor Building H2 Purge Valves, cannot be exercised during power operation since f ailure to reclose would result in loss of containment integrity.
These valves will be full stroke exercised during cold shutdowns.
4 t
i i
I l
I 46
1/ I. Attachment III The P& ids listed below were used during the course of this review.
System P&ID Rev.
Reactor Coolant System 520 16 Make-up and Purification 521 15 Decay Heat Removal 522 18 Spent Fuel Cooling 523-9
' Reactor Building Spray 524 8
H.P. and Auxiliary Turbines 530 17 Steam Generator
'532 14; High Pressure Feedwater Heater 533 12 Condenser 536 18 Auxiliary Steam 537 18 Component Cooling Water 543 11:6 Nuclear Service Raw Water 544 11
' Nuclear Service Cooling Water 54 5 -
9 R.B. Heating, Ventilating and Cooling 551 12 Coolant Radwaste 560 17 Miscellaneous Liquid Radwaste 561 21
~ Reactor Coolant Chemical Add and Sampling 570 14
. Turbine Plant Sampling 573 13 Plant Air
-590 17 Auxiliary Gas-591 18 Misc. Water Systems 593-24 i
s s
I 47-l' i
VII. Attachnent IV A.
The following relief requests include v&lves that are never full stroke exercised or have a testing frequency greater than each refueling outage.
1.
D.2.b 2.
E.1.a 3.
E.2.a 4.
E.2.b l
B.
The following-relief ' requests have insufficient technical; basis provided and relief is not recommended.
1.
Pump Testing Program i
I a.
A.2 l
1 2.
' Valve Testing Program a.
D'.2.b b.
E.1.a c.
E.2.a
.d.
E.2.b 48
I I
l VIII. Attachment V i
i 4
The following are items discussed,with Jack Uhl and Bill Garrett of Rancho Seco on September 30, 1980 and October 28, 1980 which 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 these changes.
l 1
i A.
Relief request PV-25 will be deleted from the IST program. The licensee has determined their instrumentation utilized for punp
(
testing meets the requirements of Section XI.
r e
B.
Relief request PV-9 will be modified to reflect a cold shutdown full stroke exercise of valves DH5015 and DH5016.
It has been determined that these valves can be full stroke exercised during.
cold shutdown with the Decay Heat Removal Flow.
C.
Relief request PV-43 and valve BWSO45 will.be' deleted from the IST program. This valve has been determined to be non-safety i
rel ated.
D.
Relief request PV-45 will be rewritten to reflect the contents of Paragraph C.5 of Attachment II of this report. This will be clarification of wording rather than a change of basis.
E.
Relief request PV-46 will be rewritten to reflect the contents of Paragraphs C.6 and C.7 of Attachment II of this report. This will be clarification of wording rather than a change of basis.
e 9
i I
I i
49 l
- -,