ML20003D853

Safety Evaluation of Inservice Testing Program, Interim Rept

ML20003D853
Person / Time
Site:	Quad Cities
Issue date:	03/31/1981
From:	Fehringer J, Rockhold H EG&G IDAHO, INC., EG&G, INC.
To:
References
CON-FIN-A-6258 EGG-EA-5347, NUDOCS 8104010193
Download: ML20003D853 (40)

Text

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=- INTERIM REPORT Accession No.

Report No. EGG-EA-5347 Contract Program or Project

Title:

Systems Engineering Support Subject of this Document:

Safety Evaluation of the Inservice Testing Program for Pumps and Valves at the Quad Cities Station Units 1 and 2 (Docket Nos. 50-254/265) for the Period 10-18-79 through 6-17-81 for Unit 1 and 11-10-79 through 7-9-81 for Unit 2 Type of Document:

Safety Evaluation Report Author (s).

J. M. Fehringer H. C. Rockhold g g gg{ gg}gjggl

'""*"l81 c 1 Assistance Repor;e R:sponsitsle NRC Individual and NRC Of0 4 or Division:

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

EG&G Idaho. Inc.

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

Under DOE Cord act No. DE-AC07 76lD01570 NRC- 1 N o. A6258 INTERIM REPORT y o gol O'O l

.I CONTENTS

1. INTRODUCTION .................................................... 1 II. P UMP T ES T I N G P R O GR AM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1. Al l S af e ty Re l a ted Pump s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

'2. S tandby Liquid Control Pumps 1102-1 A, 18, 2A, and 28 . . . . . . . 6

3. Diesel Generator Fuel Oil Transfer Pumps 1-5203, 2-5203, 1/2-5203 ........................................... 7 III.- VALVE TESTING PROGRAM EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

1. General Considerations ..................................... 8 1.1. Testing of Valves which Perform a Pressure Isolation Function ................................... 8 1.2 ASME Code S ec tion XI Requ i remen ts . . . . . . . . . . . . . . . . . . . . 9

67 ' l '. 3 7 S t rok e dle s t'i 1,n# C,d f/ Chec k Va l ve s . . . . . . . . . . . . . . . . . . . . . . . 9

,. . irl 1.4 S troke -jest'ing of Motor Ugerated Valves . . . . . . . . . . . . . . 9

• '<f i 1.5 Tes+ Frequency of Check Valves Tested at Cold Shutdowns ....................................... 10 1.6 Licensee Request for Relief to Test Valves at C o l d S h u t d own . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1.7 Changes to the Technical Specification . . . . . . . . . . . . . . . 10 1.8 Safety Related Valves . .............................. Il 1.9 Valve Testing at Cold Shutdown ....................... 11 1.10 Category A Valve Leak Check Requirements for Containment isolation Valves (CIV) ................... 11 1.11 Application of Appendix J Testing to -

t h e I S T P o g r am . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 i

2. General Relief Raquests .................................... 12 .

2.1 Category A, A/C, and A/E Valves ...................... 12 2.1.1 Relief Request ............................... 12 2.1.2 Relief Request ............................... 13 2.2 Power Operated Category A a.nd B Valves ............... 14 L

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c i: 2.2.1 Relief Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .14 2.2.2 Relief Request ............................... - 14 2.3 Category A, 6, and C Valves .......................... 15 2.3.1 Relief Request ............................... 15'

3. Control Rod.Orive .......................................... 16

- 3.1 Category B Valves .................................... 16 i

3.1.1 Relief Request ............................... .16 3.2 Category C Valves .................................... 17 3.2.1 Relief Request .................. ............ 17

4. Residual Heat Remova. ...................................... 18 4.1 Category B Valve .................................... 18 4.1.1 Relief RtgJest ............................... 18 4.2 Category C Valves .................................... 18 4.2.1 Relief Request ............................... 18

, 5. Standby Liquid Control ..................................... 19 5.1 Category C Valves .................................... 19 5.1.1 HRelief Request ............................... 19

6. Reactor Core Isolation Cooling ............................. 20 i

6.1 Category A/C Valves .................................. 20 6.1.1 Relief Request ............................... 20

7. CoreSpray................................................. 20 7.1 Category B Valves ....................s............... 20 e

7.1.1 Relief Request ............................... 20 4

1 7.2 Category C/E Valves .................................. 21 7.2.1 Relief Request ............................... 21 -

8. High Pressure Coolant Injection ............................ 22 ,

8.1 Category A/C Valves .................................. 22 8.1.1 Relief Request ............................... 22 iii i l

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8.2 Category B Valves .................................... 22

8. 2.1 - Relief Request ............................... 22 8.3 Category C Valves .................................... 23 8.3.1 Relief Request ............................... 23 8.3.2 Relief Request ............................... .24

9. M a i n S t e am . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 9.1 Category C/C Valves .................................. 24 9.1.1 Relief Request ............................... 24 9.2 Category C Valves .................................... 26 9.2.1 Relief Request ............................... 26

10. Feedwater .................................................. 27 10.1 Category A/C and C Valves ............................ 27 10.1.1 Relief Request ............................... 27

11. Neut ro n Mon i tor i ng Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 1.

11. 1 Category A/C Valves .................................. 28 11.1.1 Relief Request ........ ...................... 28 IV. APPENDIX A ...................................................... 29

1. Code Requirements--Valves .................................. 29

2. Code Requirements--Pumps ................................... 29 V. ATTACHMENT I .................................................... 30

1. Recirculation ............................................... 30 1.1 Category B Valves .................................... 30

2. Control Rod Drive .......................................... 30 t- 2.1 Category B Valves .................................... 30

3. Residual Heat Removal ...................................... 30 3.1 Category A Valves .................................... 30 3.2 Category A Valves .................................... 31 3.3 Catepary B Valves .................................... 31 iv l

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3.4 Category C Valves .................................... 31

4. C o re S p r ay . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 2 -

' 4.1 Category C. Valves _.................................... 32

5. P re s su re S u pp res s i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 5.1- Category A Valves .................................... 32 5.2 Category C-Valves .................................... 32

. 6. High Pressure Coolant Injection ............................ 32 6.1 Category A Valves .................................... 32 6.2- Category C Valves .................................... 33

7. M a i n S t e am . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 7.1 Category A Valves .................................... 33 VI. ATTACHMENT II ................................................... 34

- VII. ATTACHMENT III .................................................. 35 VIII. ATTACHMENT IV ................................................... 36

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v I. INTRODUCTION Contained herein is a safety evaluation of the pump and valve inser-vice testing (IST) program submitted by the Commonwealth Edison Com ' on 7-18-79 for its Quad Cities Station Units 1 and 2 nuclear plants.

program applies to Unit 1 for the period 10-18-79 through 6-17-6 .a co Unit 2 for the period 11-10-79 through 7-9-81. The working sess.on with Quad Cities and Commonwealth Edison Company representatives was conducted on 6-25-80 and 6-26-80. The licensee resubmittal was issued on 9-30-80 and was reviewed by EG&G Idaho Inc., to verify compliance of proposed tests of -

safety related Class 1, 2, and 3 pumps and valves with requirements of the ASME Boiler and Pressure Vessel Code,Section XI,1974 Edition, through the Summer of 1975 Addenda. Commonwealth Edison Company and Quad Cities has .

also requested relief from thc ASME Code from testing specified pumps and i valves because of practical reasons. These requests have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed impractical.

The evaluation of the pump testing 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.

A summary of the pump and valve testing requirements is contained in Appendix A.

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

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

Valves that have a proposed testing interval greater than each refueling outage are summarized in Attachment III.

Valves that should be reviewed by the NRC to determine if they should

be Categorized A, A/C, or A/E are summarized in Attachment IV.

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i II. Pump Testing Program The IST program submitted by Commonwealth Edison for its Quad Cities Station Units 1 and 2 was examined to verify that Class 1, 2, and 3 safety l_ related pumps were included in the program and that those pumps are subjec-ted 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 request M, the pump tests and fre-

• quency of testing comply with the code. Each Commonwealth Edison basis for requesting specific relief from testing pumps and the EG&G evaluation of that request is summarized (Sections 2 through 4) below and grouped accor-

. ding to the system in which the pumos reside:

1. All Safety Related Pumps Core Spray Pumps 1401-1 A,18, 2A and 28; Residual Heat Removal Pumps 1002-lA, 18, 1C, 2A, 28 and 2C; RHR Service Water Pumps 1-1001-65A, -658,

-65C, -650, 2-1001-65A, -658, -65C, and -65D; Standby Liquid , Control Pumps 110?-1A, -18, 1002-2A and -2B; High Pressure Coolant Injection Pumps 1-2302 and 2-2302; Diesel Generator Cooline ater Pumps 1-3903, 2-3903, and 1/2-3903; and Diesel Generator Fuel 011 Transfer Pumps 1-5203, 2-5203, and 1/2-5203 l.1 Relief Request The licensee has requested specific relief from measuring bearing temperature and taking vibration readings in accordance with the require-ments of Section XI and proposed to take vibration readings in velocity (in./sec).

1.1.1 Code Requirement. Refer to Appendix A. j l.1.2 Licensee's Basis for Requesting Relief. Pump vibration and bearing temperature are required to be measured to detect any changes in the mechanical characteristics of a pump to detect developing problems so i repairs can be initiated prior to a pump becoming inoperable (i.e. unable i to perform its function). The ASME Code minimum str dards require measure-4 ment of the vibration amplitude displacement in mils (thousands of an inch j every three months and bearing temperatures once per year.

Quad Cities Station proposes an alternate program which is believed to be more comprehensive than that required by 3ection XI. This program con-

! sists of performing the required vibration readings in velocity rather than mils displacement. This technique is an industry-accepted method which is much more meaningful and sensitive to small changes that are indicative of developing mechanical problems. These velocity measurements detect not

, only high amplitude vibrations that indicate a major mechanical problems but also the equally harmful low amplitude-high frequency vibrations dJe to misalighment, imbalance, or bearing wear that usually go undetected by simple displacement measurements.

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In addition, these readings go far beyond the capabilities of a bearing temperature monitoring program, which requires a bearing to be seriously degraded prior to the detection of increased heat at the bearing housing.

The vibration velocity readings on a schedule of once every three months achieves a much higher probability of detecting developing problems than the once per year reading of bearing temperatures. Data gathering on bearing temperatures also is not without its cwn problems. The enforced thirty minute run time, (i.e., IWP-3500) (b)--three successive readings taken at ten minute intervals that, do not vary more than 3%), causes prob-lems with pumps having'no recirculation / test loop. The temperature of the -

pumped' fluid is also meaningful when attempting to trend any developing problems from year to year. It is easy to see that a program of bearing temperature trends and the evaluation of the results would in some cases be .

difficult to analyze. Improper interpretations of results could result in unnecessary pump maintenance. In addition, it is impractical to measure bearing temperatures on many of the pumps in the program. Some specific examples are as follows:

1. Core Spray l(2)A,B-1401--pu .p bearings are lubricated by pumped fluid. Temp are of the pumped fluid would seriously affect the accuracy of trends.

2. RHR 1(2)A,B,C,0-1002--same as above.

3. RHR Service Water 1(2)l001-65A,B,C,D--Bearings are contained in an oil-filled reservoir. The ambient temperature of the pump space is changeable thereby varying the start temperature of the data. Results would be difficult if not impossible to trend from test to test.

4. High Pressure Coolant Injection--This pump is driven by a steam-turbine which exhausts steam into the pressure suppression chamber. Extended run times to stabilize bearing temperatures would create problems in keeping suppression pool temperatures below the Technical Spec-ification limit of 950F.

5. Diesel Generator Cooling Water 1(2)(1/2)-3903--Same as RHR Service Water

6. Diesel Generator Fuel Oil Transfer 1(2)(1/2)-5203--These transfer pumps pump fuel oil from the fuel oil storage

• tank to the D/G fuel oil day tank. There is no recir-culation test loop for these pumps, thereby, limiting l

the run time necessary to gather bearing temperature data.

The foregoing reasons demonstrate that the proposed program of vibra-tion reasurements is a more practical method of testing which exceeds the requirements of the ASME Code.

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ALTERNATE TESTING: Pump vibration measurements will be taken in vibra-tion velocity (in./sec.). The evaluation of the reaoings will be per Table 1.

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1.1.3 Evaluation. We agree with the licensee's basis and tnerefore  !

feel that relief should be granted for all safety related pumps from the  !

requirements of Section XI to measure bearing temperature yearly and take vibration readings in mils displacement. The licensee has demonstrated that taking vibration readings in velocity (in/sec) is more restrictive

. than the requirements of Section XI-and will provide a better indication of pump degradation. We conclude that the proposed alternate testing methods more than meet the requirements of Section XI and should provide adequate

, information to determine pump degradation (the intent of Section XI).

1.2 Relief Request The licensee has requested specific relief from the requirements of Section XI to measure pump parameters monthly and proposed to run these j pumps monthly for bearing lubrication and to run pumps quarterly and l measure the required parameters.

j 1.2.1 ^ode Requirement. Refer to Appendix A.

1.2.2 Licensee's Basis for Requesting Relief. Relief is requested f rom the requirements of Subsection IWP-3400 to measure the basic pump parameters identified in Table IWP-3100-1 on a monthly basis. Changes in these hydraulic and mechanical parameters will not significantly change over the period of one month because the pumps are primarily run only for

, operability and remain in a standby mode of operation. Quarterly measure-ment of these parameters is more than adequate in determining pump degradation.

The original intent to require monthly testing was based on the

premise that damage can occur to bearings if a pump remains stagnant for i long periods of time. This concern can be mitigated by running pumps on a monthly basis to lubricate the main bearings.

, A change to the Code of a similar nature, recently passed the Sec-j tion XI Main Comittee, will be published in a forthcoming Addenda to

, Section XI. It is not felt that this relief request represents a relaxa-1 tion in safety requirements, only that it allows more practical implemen-tation of Section XI requirements. 4 All pumps will be exercised on a monthly basis to lubricate the 4

bearings. Pump parameters will be measured quarterly.

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• 1.2.3 Evaluation. We agree with the licensee's basis and therefore

feel that relief should be granted from the Secticn XI requirement to measure pump parameters monthly. The licensee has demonstrated that their

proposed testing frequency meets the intent of the Section XI require- q ments. We conclude that running pumps monthly to lubricate bearings, and l running pumps quarterly to measure all required parameters should provide i j sufficient data to determine any pump degradation. ,

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i l' TABLE 1. . ALLOWABLE RANGES OF IEST: QUANTITIES l

~ Alert Range Required Action ' flange t Acceptable Low Low

, Quantity Range Values' High Values Values High Values 4 '

v wnen 0 1vr1 0.15 in./s 0 to 0.3 in./s 0.3 to 0.45 in./s v > 0.45 in./s None None

{ v when 0.15 in./s < vr < 0.3 in./s 0 to 0.45 in./s None 0.45 to 0.75 in./s None v > 0.75 in./s i

v when 0.3 in./s < vr < 0.6 in./s 0 to 0.9 in./s None 0.9 to 1.5 in./s None v > 1.5~in./s '

l-4 v when 0.6 in./s < vr < 1.0 in./s 0 to 1.1 in./s None 1.1 to 1.5 in./s None v > 1.5 in./s i

f, where:

v = velocity measured in inches /second, peak.

! vr = reference velocity measurement (initial measarement after installation or rework.  !

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l.3 Relief Request The licensee has requested specific relief from the requirements of Section XI, (corrective action) and proposed to use the plants " Limiting Conditions for Operation" to determine required action ranges for pumps.

1.3.1 Code Requirement. Refer to Appendix A, IWP-3220(c), and Table IWP-3100-2.

. 1.3.2 Licensee's Basis for Requesting Relief. When measured pump parameters f all into the " Required Action Range",- pump operability and corrective action will be based on the limits specifieo in the Limiting

, Conditions for Operation of the plant Technical Specifications. A pump may remain operable if it meets all Technical Spec. cation requirements and an analysis indicates that, even though a pump paran,-Cer is in the " Required Action Range", the pump can still fulfill its intended functions. ,

Relief is requested from the requirements of IWP-3220(c) regarding corrective action when pump parameters are found to be within the " Required Action Range" of Table IWP-3100-2. Some means should be allowed for con-ducting an analysis to demonstrate that the condition of a pump does nct impair pump operability and that the pump caq still perform its intended function. Later editions of the Code do address this concern by allowing such an analysis to serve as the corrective action.

1.3.3 Evaluation. We agree with the licensee's basis and therefore

feel that relief should be granted from the Section XI " corrective action 4

requirements" for all safety related pumps. The licensee has demonstrated i that using pitnt " Limiting Conditions for Operation" for " Required Action Ranges" should ensure pump availability. We conclude that aproved Techni-

! cal Specifications for " Limiting Conditions of Operation" for pump testing

" Required Action Ranges" meets the intent.of the Section XI requirements.

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2. Standby Liquid Control Pumps 1102-1A, 18, 2A, and 28 2.1 Relief Request The licensee has requested specific relief from measuring pump inlet 4

pressure in accordance with the requirements of Section XI.

2.1.1 Code Requirement. Refer to Appendix A.

2.1.2 Licensee's Basis for Requesting Relief. It is impractical to measure standby liquid control pump inlet pressure in accordance with Sec-

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4 tion XI requirements. During pump testing, the pump suction is from a test tank rather than the main standby liquid control tank. No instrumentation

is provided for measuring inlet pressure, and therefore, the only means available is to correlate tank level to inlet pressure. Since these pumps are positive displacement designs, the measurement of inlet pressure is not critical in judging pump performance. Measuring the discharge pressure and the flow rate is' adequate to detect changes in the hydraulic characteris-tics of the pumps. i i

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2.1.3 Evaluation. We agree with the licensee's basis and therefore feel-that relief should be granted from the Section XI requirement to measure inlet pressure for these pumps. The licensee has demonstrated that i calculating inlet pressure for a positive displacement pump will not pro-vide any meaningful data to analyze for pump degradation. -We conclude that measuring discharge pressure and flowrate should provide adequate informa-tion to determine any hydraulic degradation of these pumps.

3. Diesel Generator Fuel Oil Transfer Pumps 1-5203, 2-5203, 1/2-5203 3.1 Relief Request The licensee has requested specific relief from measuring pump inlet -

pressure in accordance with the requirements of Section XI.

3.1.1 Code Requirement. Refer to Appendix A.

3.1.2 Licensee's Basis for Requesting Relief. Relief is requested from the requirement of measuring pump inlet pressure curing pump tests.

4 This pump is utilized in-transfering fuel oil from the diesel generator fuel oil storage tank to the diesel fuel oil day tank. The configuration of the piping is-such that the pump is located above the storage tank. The pump is a positive displacement gear type pump not requiring a positive suction head for proper operation. Since this pump is a positive displace-ment type, the discharge pressure is independent of the suction pressure and, therefore, inlet pressure data is not important in evaluating pump i

performance.

i 3.1.3 Evaluation. We agree with the licensee's basis and therefore feel that rellet should be granted from the Section XI requirement to measure inlet pressure for these pumps. The licensee has demonstrated that measuring inlet pressure for these positive displacement gear type pumps would not provide any meaningful data that could be used to determine any pump degradation. We conclude that measuring pump discharge pressure and

. flowrate should provide adequate information to determine if these pumps are performing their design function or if any hyoraulic degradation of these pump; has occurred.

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III. VALVE TESTING PROGRAM EVALUATION The IST prcgram submitted by Commonwealth Edison Company and Quad Cities was examined to verify that Class 1, 2, and 3 safety related valves were included in the program and that those valves are suojected to the periodic tests required by the ASME Code,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 iden-tified 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 1. Also, included in the General Section 1 is the NRC rasition and valve listings

. for the leak testing of valves that perform i pressure isolation function and a procedure for the licensee's use to i1 corporate these valves into the IST program. Each Commonwealth Edison Company and Quad Cities basis for requesting specific relief from testing valves and the EG&G evaluation of that request is summarized (Sections 2 througF 11) below and grouped according to each specific system.

1. General Consiaerations 1.1. Testing of Valves which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure boun-dary have design pressures below the reactor coolant system operating pres-sure. Redundant isolation valves within the Class 1 bounoary forming the intc face between these high and low pressure systems prevent the low pres-sure systems from being subjected to pressures which exceed their design limit. In this role, the valves perform a pressure isolation function.

The NRC considers the redundant isolation provided by these valves to be '

important. The NRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For these reasons, the NRC and EG&G believe that some method, such as pressure monitoring, leak testing, radiography or ultrasonic testing, should be used to assure the condition of each valve is satisfac-tory 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 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:

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1(2)-1402-9A and -9B 3 1(2)-1402-25A and -25B 1(2)-1001 47 and -50 1(2)-1001-68A and -688 1(2)-1001-29A and -298 8

The NRC and EG&G Idaho, Inc., nave 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 demonstrates the condition of each valve.

1.2 ASME Code Section XI Requirements ,

Subsection IWV-3410(a) of the Section XI Code (which discusses full stroke and partial stroke) requires that 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 testing for Code Category E valves. Operational checks, with appropriate record entries, shall record the position of these valves before operations are performed and after operations are completed and shall verify that each valve is locked, or sealed. The limiting value of full stroke time for each power operated valve shall be identified by the owner and tested in accordance with IWV-3410(c). In the above exceptions, the code permits the valves to be tested at cold shutdown where:

1. It is not practical to exercise the valves to the posi-tion required to fulfill their function or to the par-tial position during power operation.

2. It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.

1.3 Stroke Testing of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full stroked. If only lim-ited operation is possible (and it has been demonstrated by the licensee and agreed to by the NRC) the check valve shall be partial stroked. Since disk position is not always observable, the NRC staff stated that verifica-tion of the plant's safety analysis design flow rate through the check valve would be an adequate demonstration of the full stroke requirement.

Any flow rate less than design will be considered part stroke exercising unless it can be shown that the check valve's disk position at the lower -

flow rate would be equivalent to or greater than the design flow rate through the valve. The licensee agreed to conduct flow testing to satisfy the above position. e 1.4 Stroke Testing of Motor Operated Valves The licensee has requested relief from the part-stroke requirement of Section XI for all power operated valves except those identified in Attach-ment I.7.1. The licensee has stated tnat none of the Category A or B power operated valves identified, except those noted above, can be part stroked l 9 1

because of the design logic of the operating circuits. These circuits are such that when an open or close signal is received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other direction. We find that the above relief request from part stroking is warranted and should be granted because the required function of the valves involves only full open or full closed positions.

1.5 Test Frequency of Check Valves Tested at Cold Shutdowns The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Cate-gory A and B valves and once every nine months for Category C valves. It S 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 need not be performed more often than once every three (3) months for Category A, B and C valves."

1.6 Licensee Request for Relief to Test Valves at Colo Shutdown The Code permits valves to be tested at cold shutdown, and the Code i conditions under which this is permitted are noted in Appendix A. These

! valves are specifically identified by the licensee and are full stroked j exercised during cold shutdowns; therefore, the licensee is meeting the j requirments of the ASME Code. Since the licensee is meeting the require-1 ments of the ASME Code, it will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it was not practical to exercise these valves during power operation and that we agree with the licensee's basis. It should be noted that the NRC dif-ferentiates, for valve testing purposes, between the cold shutdown mode and i the refueling mode. That is, for testing purposes the refueling mode is i not considered as a cold shutdown.

i 1.7 Changes to the Technical Specification In a November 1976 letter to the licensee, the NRC provided an attach-ment entitled, "NRC Guidelines for Excluding Exercising (Cycling) Tests of

Certain Valves During Plant Operation." The attachment stated that when

. one train of a redundant system such as the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not

be cycled if their failure in a non-safe position would cause a loss of i total system function. For example, during power operation in some plants, there are stated minimum requirements for systems which allow certain lim-iting 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 1* 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 periodi-i cally thereafter during power operation. For some plants this situation could be contrary to the F C guideline as stated in the document mentioned

, above. It should be noteo that a reduction in redundancy is not a basis for a T.S. change not is it by itself a basis for relief from exercising in i

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A 4 accordance with Section ya. The licensee has agreed to review the plant's T.S. and to consider the need to propose T.S. changes which would have the effect of precluding such testing. After making this. review, if the licen-see determines that the T.S. should be changed because the guidelines are 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 f ailure 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.

l.8 Safety Related Valves *

This review was limited to safety-related velves. Safety-related valves are defined as those valves that are needed to mitigate the conse-quences of an accident and/or to shutdown the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2 and 3 valves and could include some non-code class valves. It should be noted that the licensee may have included non-safety related valves in their Inservice Test Program as a decision on the licensee's part to expand the scope of their program.

1.9 Valve Testing at Cold Shutdown Inservice valve testing at cold shutdown is acceptable when the fol-lowing conditions are met: It is understood that the licensee is to com-mence testing as soon as the cold shutdown condition is achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown and continue until complete or the 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, excep-tions 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.

1.10 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 applic- .

l able leak test procedures and requirements for CIVs are determined by 10_CFR 50 Appendix J. Relief from paragraph IWV-3420 (a-e) for CIVs pre-sents no safety problem since the intent of IWV-3420 (a-e) is met by Appen- c dix J requirements.

l The licensee shall comply with Sections f anu g of IWV-3420 until relief is requested from these paragraphs. It should be noted that these paragraphs are only applicable where a Type C Appendix J leak test is per-formed. Based on the considerations discussed above the NRC concludes that the alternate testing proposed above will give the reasonable assurance of L

! 11

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.

1.11 Application of Appendix J Testing to the IST Program The Appendix J review for this plant is a completely separate review from the IST program review. However, the determinations made by that review are directly applicable to the IST program. The NRC review has determined that the current IST program as submitted by the licensee cor-rectly reflects their 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.

2. General Relief Requests 2.1 Category A, A/C, and A/E Valves 2.1.1 Relief Request. The licensee has requested specific relief from leak testing all Category A valvas in accordance with the requirements of Section XI and proposed to leak test these valves in accordance with the requirements of Appendix J.

2.1.1.1 Code Requirement. IWV-3420 Valve Leak Rate Test. Cate-gory A valves shall be leak-tested. Tests shall be' conducted at the same j (or greater) frequency as scheduled refueling outages, but not less than once every two years. Valve seat leakage tests shall be made with the pressure differential in the same direction as will be applied when the valve is performing its function with the following exceptions:

Any gicbe type valve may be tested with pressure under

~

1.

seat.

2. Butterfly valves may be tested in either direction, provided their seat construction is designed for sealing against pressure on either side.

4

3. Gate valves with two-piece disks may be tested by pres-surizing them between the seats.

i 4. All valves (except check valves) may be tested ir, either direction if the function differential pressure

. is 15 psi or less.

5. The use of leakage tests involving pressure differen-c*

tials lower than function pressure differentials are

, permitted in those types of valves in which service i

pressure will tend to diminish the overall leakge chan-i nel opening, as by pressing the disk into or onto the l seat with greater force. Gate valves, check valves, j and globe type valves having function pressure differ-

. ential applied over the seat are examples of valve applications satisying this requirement. When leakage

! 12

tests are made in such cases using pressure lower than function maximum pressure differential, tne observed leakage shall be ad.iosted to function maximum pressure differential value oy calculation appropriate to the e test media and the ratio between test and function pressure differential assuming leakage to be directly proportional to the pressure. differential to the one-half power.

6. Any valves not qualifying for reduced pressure testing as defined in 3420(c) (5) shall be leak-tested at full maximum function pressure differential, with adjustment

by calculation if needed to compensate for a difference *

between service and test media.

2.1.1.2 Licensee's Basis for Requesting Relief. Primary con-tainment isolation' valves whose functional differential pressure does not exceed the primary containment accident pressure will be seat leak tested in accordance with the Appendix J requirements of 10 CFR 50. At this func-tional differential pressure Section XI testing requirements are essenti-ally equivalent to those of Appendix J. No additional information con-ce nir.g valve leakage would be gained by performing separate tests to both

• ction XI_and Appendix J.

Valves will be seat leak tested in accordance with 10 CFR 50 Appendix J.

2.1.1.3 Evaluation. We agree with the licensee's basis and

therefore feel that relief should be granted for all Containment Isolation Valves (CIV's) from tee leak testing requirements of Section XI, IWV-3420(a-g). We conclude that, since the leak rate test requirements of

IW/-3420 (a-g) have been superseded by the Appendix J requirements ana that i the applicable leak test procedures and requirements for CIV's are now deter

ned by 10 CFR 50 Appendix J, the intent of IWV-3420(a-g) is met by the Appendix J requirements.

2.1.2 Relief Request. The licensee has requested specific relief from exercisinc all Category A/C excess flow check valves in accordance with the requirements of Section XI and proposed to verify valve' closure (their safety related position) following each refueling outage.

2.1.2.1 Code Requirement. Refer to Appendix A.

4 2.1.2.2 Licensee's Basis for Requesting Relief. These valves i are currently testec per Technical Specification requirements which con-sists of a leakage test conducted during primary system pressure tests at o the completion of each refseling outage. The testing involves uncoupling l the instrument lines and verifying that each valve strokes to the closed i

position. The operator also observes that the valve limits flow to an i acceptable level. This method and frequency of testing has been justified l in t le plant FSAR and has proven to be an adequate verification of valve j performance.

13

2.1.2.3 -Evaluation. We agree with the licensee's basis and therefore feel that relief should be granted for all excess flow check l valves from the exercising and leak testing requirements of Section XI.

The licensee has demonstrated that, due to plant design and operating limitations, valve closure (their safety related position) can only be verified during pressure testing per Technical Specifications following each refueling outage. We conclude that the proposed alternate testing method and frequency meets the intent of Section XI and should verify proper valve operability.

O 2.2 Power Operated Category A and B Valves

• 2.2.1 Relief Request. The licensee has requested specific relief from the stroke timing accuracy requirements of Section XI for all Cate-gory A and 8 powered operated valves with stroke times less than 10 seconds. ,

2.2.1.1 Code Requirement. Refer to Appendix A.

2.2.1.2 Licensee's Basis for Requesting Relief. The code requires that stroke timing accuracy be either to the nearest second or 10 percent of tL. maximum stroke time, whichever is less. Quad Cities Station feels that this requirement is impractical for valves with stroke times less than 10 seconds. For these valves, the accuracy of the measured stroke time is less than one second which is inconsistent with the method used for timing (i.e., hand held stopwatch) and difficult to certify.

<ince the purpose for the test is to detect deterioration of valve func-tion, establishing a lower limit of one second for valve timing accuracy will have no effect on the ability to detect changes in valve performance.

Recent changes in Section XI of the ASME Code have reflected this position.

As revised in later editions of the Code, the stroke time of all power operated valves will be measured to the nearest second, for stroke times 10 seconds or less, or 10 percent of the specified limiting stroke time for full-stroke times longer than 10 seconds.

2.2.1.3 Evaluation. We agree with the licensee's basis and therefore feel relief should be granted for all power operated Category A and B valves (with stroke times less than 10 seconds) from the timing requirements of Section XI. The licensee has demonstrated that using the present available methods of measuring stroke times that accuracy is lim-ited and meaningful data on valve stroke time degradation cannot be obtained. We conclude that measuring stroke time to the nearest second

, meets the intent of Section XI and should provide meatlingful data to use in determining any valve degradation.

, 2.2.2 Relief Request. The lice.'see has requested specific relief from stn ke timing Category A and B power operated valves in accordance i with the requirements of Section XI.

2.2.2.1 Code Requirement. Refer to Appendix A.

2.2.2.2 Licensee's Basis for Requesting Relief. Paragraph IWV-3410(c) (3) requires that valve stroke times be evaluated against the i,

14

d previous stroke time to determine if corrective action is required. To establish consistency in evaluating stroke times and make program implemen-tation more practical, Quad Cities Station proposed to establish a refer-ence stroke time for each valve which will be usea fur evaluating perform-ance. This reference value will be determineo by averaging stroke times.

l This actually results in a tighter band of acceptable stroke times, out is much easier to administer. The limiting value of full stroke time for each valve will remain as listed in the IST Program tables.

e In addition, it is impractical to apply the requirements of IWV-3410(c)

(3) to valves with very short stroke times (i.e., 5. seconds) particularly solenoid valves which typically have full stroke times under one second.

For these short stroke time valves, variances of 50 percent or more can

• occur in the measured times for reasons that are in no way related to valve-performance, for example, operator reaction times. In these specific cases, verifying that the valve stroke times do not exceed 5 seconds would be sufficient to evaluate valve performance.

Based on this relief request paragraph IWV-3410(c) (3) would, in effect, read as follows:

If an increase in stroke time of 25% or more from the estab-lishmed reference value for valves with stroke times greater than ten seconds or 50% or more for valves with stroke times between 5 and 10 seconds or 5 seconds or more for valves with stroke times less than or equal to 5 seconds is observed, test frequency.....

2.2.2.3 Evaluation. We agree with the licensee's basis and therefore feel that relief should be granted for all Category A and B power 4

operated valves from the stroke timing requirements of Section XI. The -

licensee has demonstrated that the proposed valve timing requirements for

, valves with stroke times greater than 5 seconds meets the intent of the requirements of Section XI. Also, for valves with established stroke times of less than 5 seconds, a maximum limit should provide the required data to determine valve degradation. We conclude that the proposed alternate stroke timing requirements for these valves will provide the required meaningful data to determine any valve degradation (the intent of Section XI).

2.3 Category A, B, and C Valves 2.3.1 Relief Request. The licensee has requested specific relief from declaring Category A, C, and C valves inoperable and repairing these s valves in accordance with the requirements of Section XI and proposed to use plant Technical Specifications to determine " Limiting Conditions of Operation". 6-2.3.1.1 Code Requirement. If a valve fails to exhibit the required 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 incperative.

When corrective action is required as a result of tests made JJring cold shutdown, the condition shall be corrected before startup. A retest ,

15

O showing acceptable operation shall be run following any required corrective action before the valve is returned to service.

2.3.1.2 Licensee's Basis for Requesting Relief. Specific relief L is requested from requirements of paragraphs IWV-3410(g) and IWV-3520(c) of i

Section XI of the 1974 Edition of the ASME Boiler and Pressure Vessel Code including the Addenda through Summer 1975. These paragraphs state the corrective action; to be taken when valves fail to exhibit a required change of disk position. These actions include. requirements to take corrective action prior to plant startup should a failure occur during cold shutdown testing. Also stated are requirements to declare valves inoperable if corrective action is unsuccessful within a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.

These paragraphs do not take into account the plant Technical Specifi-cation requirements for limiting conditions for operation whicn state the minimum conditions necessary for safe operation of the plant. The failure of a particular valve may not necessarily require a plant shutdown or pre-vent a startup. In addition, valves not capable of performing their safety-related function are declared inoperable as soon as that condition has been verified, not after a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period has elapsed.

For these reasons, Quad Cities Station will evaluate the condition of

, each valve with respect to its safety related function and take the appro-i priate corrective action as stated in the Technical Specification--Limiting

]

Condition for Operation.

2.3.1.3 Evaluation. We agree with the licensee's basis and therefore feel that relief should be granted for Category A, B, and C valves from the Section XI requirement to declare valves inoperative and the repair i requirements that determine when the plant can be started up and power

, operation resumed. We conclude that plant technical specifications ade-quately address these specific conditions and should be allowed to govern j the limiting conditions of operation and permit plant operation with por-i tions of their safety systems out of service for specific periods of time.

4

3. Control Rod Drive

. 3.1 Category B Valves 3.1.1 Relief Request. The licensee has requested specific relief from exercising Category B valves 1(2)-0305-126 and 127 (177 of each),

individual rod scram valves, in accordance with the requirements of Sec-i tion XI and proposed to test these valves in accordance with plant Techni-l;. cal Specifications.

, 3.1.1.1 Code Requirement. Refer to Appendix A.

j 3.1.1.2 Licensee's Basis for Requesting Relief. There are 177 of each of the valves listed, i.e., one for each of the 177 control rod

drives. The proper operation of each of these valves is demonstrated during scram testing when each drive's scram insertion time is measured. The Technical Specifications limit individual scram insertion times to specific values. This insures that the above mentioned valves are functioning properly.

i i

16

Individual scram insertion tests will be performed per the Technical Specifications frequency. The frequency is: 1) 100% of control rod drives af ter each refueling with reactor power equal to or less than 30%, and

2) 50% of the CRD's every 16 to 32 weeks with 100% completed every year.

3.1.1.3 Evaluation. We agree with the licensee's basis and ,

therefore feel that relief should be granted for Category B valves 1(2)-0305-126 and 127 (177 of each) from the exercising requi rements of Section XI. The licensee's has demonstrated that a reactor pu er reduc- m tion is required to conduct this testing and that a frequency more restric-tive than the one proposed would result in unnec'essary power and operating restrictions. We conclude that the proposed alternate testing method and e frequency should ensure these valves will properly perform their safety function.

3.2 _ Category C Valves 3.2.1 Relief Request. The licensee has requested specific relief from exercising Category C valves 1(2)-0305-114 (177 of each), scram flow check valves, in accordance with the requirements of Section XI and pro-posed to test these valves in accordance with plant Technical Specifications.

3.2.1.1 Code Requirement. Refer to Appendix A.

3.2.1.2 Licensee's Basis for Requesting Relief. There are 177 of each of the valves listed (i.e., one for each of the 177 control rod drives). The proper operation of each of these valves is demonstrated during scram testing when each drive's scram insertion time is measured.

i The Technical Specifications limit individual scram insertion times to specific values. This ensures that the above mentioned valves are functioning properly.

Individual scram insertion tests will be performed per the Technical Specifications frequency. The frequency is: 1) 100% of control rod drives j after each refueling with reactor power equal to or less than 30%, and

2) 50% of the CRD's every 16 to 32 weeks with 100% ccmpleted every year.

3.2.1.3 Evaluation. We agree with the licensee's basis and therefore feel that relief should be granted for Category C valves 1(2)-0305-114 (177 of each) from the exercising requirements of Section XI. The licensee has demonstrated that a reactor power reduction is required to conduct this testing and that a frequency more restrictive ,'

than the one proposed would result in unnecessary power and operating restrictions. We conclude that the proposed alternate testing method and frequency should ensure these valves will properly perform their safety function.

17

4. Residual Heat Removal

! 4.1 Category B Valves 4.1.1 Relief Request. The licensee has requested specific relief from timing Category B valves 1(2)-1001-18A and 188, RHR pump minimum flow recirculation isolations in accordance with tne requirements of Section XI.

j 4.1.1.1 Code Requirement. Refer to Appendix A.

4. l'.1. 2 Licensee's Basis for Requesting Relief. Relief is requested from measuring the stroke time of these valves. Since the valves O close automatically when adequate pump flow is reached, it is difficult to accurately measure the stroke time. An equally meaningful test would be to verify that the valves do close automatically as the pump flow increases.

An operator will verify that these valves automatically close as pump flow increases during quarterly pump operability testing.

4.1.1.3 Evaluation. We agree with the licensee's basis and therefore feel that relief should be granted for Category B valves 1(2)-1001-18A and 188 from the stroke timing requirements of Sec-tion XI. The licensee has demonstrated that obtaining meaningful data to i determine valve degradation on valves with variable stroke times is not possible. In addition, if these valves failed in the full open position design pump flow can still be achieved. We conclude that the proposed alternate test method to obse/ve these valves do close on an increase in pump flow should demonstrate proper valve operability.

4.2 Category C Valves 4.2.1 Relief Request. The licensee has requested specific relief

~

from exercising Category C valves 1-1001-142A through 1420, residual heat removal pump minimum flow checks, in accordance with the requirements of Section XI and proposed to make plant modifications to install flow devices ,

in thec: lines for valve full stroke exercising verification.

4.2.1.1 Code Requirement. Refer to Appendix A.

4.2.1.2 Licensee's Basis for Requesting Relief. There are no provisions in the current system design for exercising or determining the position of these valves. Based on the record of satisfactory pump per-formance and lack of pump overheating problems, it is evident that these

, valves have performed in an acceptable manner. However, due to the inabil-ity tc demonstrate that the valves stroke open, Quad Cities Station has initiated system modifications to install flow instrumentation in the mini-

mum flow lines to indicate that the valves are, in fact, opening and pas-sing adequate flow for pump cooling purposes. The modifications must be made during a refueling outages because the system will be out of service during the installation. The modifications will be implemented at the earliest possible date which is contingent on the availability of materi-

'a's. Relief is therefore requested from the requirement to demonstrate that the subject valves stroke open until system modifications provide the necessary instrumentation. ,

i 18 l - __ . _ . --- . ,, . . . . ,

No specific alternate te;t is applicable during this intcrim period.

4.2.'.3 Evaluation. We agree with the licensee's basis and therefore feel that temporary relief should be granted for Category C valves 1-1001-142A through D from the exercising requirements of Section XI. The '

licensee has demonstrated that with the present plant design a method to verify these valves open fully (their safety related position) does not exist. We conclude that the proposed plant modifications to install flow devices will provide a meals to verify proper valve operability.

5. Standby Liquid Control =

5.1 Category C Valves 5.1.1 Relief Request. The licensee has requested specific relief

, from exercising category G valves 1(2)-1101-15 and 16, standby liquid con-4 trol injection checks, in accordance with the requirements of S,ection XI and proposed to partial stroke exercise these valves during cold shutdown

and full stroke exercise these valves during refueling outages.

5.1si.! Code Requirement. Refer to Appendix A.

5.1.1.2 Licensee's Basis for Requesting Relief. Exercising

, these valves by system initiation is not feasible during operation due to 4

the requirements to maintain (a) baron to reactor water separation, and (b) system operability per Technical Specifications.

Since the valve operability test, in this case, must be performed with the system out of service by injecting clean demineralized water from,some external source, it is more practical in terms of system availability to perform this test during cold shutdown. Currently it is not possible to achieve full flow through the valves using the method described above; only 26 gpm of the required 39 can be injected. The station is confident that during refueling outages a method can be devised to obtain full flow through these valves. If necessary, although not desired, the system pumps could

, be used to provide this flow, but this would require extensive cleaning of

, the system to remove residual boron.

These valves will be part stroke exercised during cold shutdown and

full stroke exercised at each refueling outage.

J 5.1.1.3 Evaluation. We agree with the licensee's basis and l therefore feel that relief should be granted for Category C valves 1(2)-1101-15 and 16 from the exercising requirements of Section XI. The licensee has demonstrated that exercising these valves with demineralized water during power operation would require removing the system from service .

thus making the system inoperable. Also, injecting baron during power operation could cause reactivity excursions, a reactor shutdown, and an extensive recirculation system clean-up to return plant chemistry to oper-

, ating specifications. We conclude that due to plant design only partial stroke exercising of these valves during cold shutdown with deminera'ized l

-water is possible. Also, we feel that full stroke exercising these a;ves during refueling outages should demonstrate proper valve operability.

19 ,

6. Reactor Core Isolation Cooling 6.1 Category A/C Valves 6.1.1 Relief Request. The licensee has requested specific reliet from exercising Category A/C valves 1(2)-1301-40 and 41, primary contain-ment isolation checks, in accordance with tb? requirements of Section XI 4

and proposed to verify valve opening during the quarterly pump tests and valve closure (their other safety related position) during refueling outages. ,

6.1.1.1 Code Requirement. Refer to Appendix A.

, O 6.1.1.2 Licensee's Basis for Requesting Relief. It is impracti-

cal to demonstrate closure of these cneck valves curing normal operation or i

cold shutdown. To verify closure upon reversal of flow a pressure test must be performed. This requires that the systems be taken out-of-service.

I The safety significance of these components is minimal since leakage past these valves would be contained within the RCIC piping which returns to the 3

containment.

i

'These valves will be demonstrated to close upon reversal of flow during l each refueling outage per Appendix J test.

I 6.1.1.3 Evaluation. We agree with the licensee's basis, and therefore feel that reitet should be granted for Category A/C valves

1(2)-1301-40 and 41 from the exercising requirements of Section XI. The

. licensee has demonstrated that valve full stroke opening will be accom- ,

plished during the quarterly pump test but, due to plant design the only method available to verify valve closure (their other safety related posi-tion) is leak testing. These valves are 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  ;

l full stroke open exercising quarterly and verifying valve closure curing

the performance of leak rate testing at refueling outages should demon-strate proper valve operability.

7. Core Spray 7.1 Category 8 Valves 7.1.1 Relief Request. The licensee has requested specific relief from timing Category B valves 1(2)-1402-38A and 388 core spray pumps mini- '

mum flow recirculation isolation valves in accordance with the requirements =

of Section XI.

4 7.1.1.1 Code Requirement. Refer to Appendix A.

7.1.1.2 Licensee's Basis for Requesting Relief. Relief is i requested from measuring the stroke time of these valves. Since the valves  ;

close automatically when adequate pump flow is reached, it is difficult to

, accurately measure the stroke time. An equally meaningful test would be to just verify that the valves do close automatically as the pump flow increases.

l  ;

20 l .

, An operator will verify that these valves automatically close as pump flow increases during quarterly pump operability testing.

7.1.1,3 Evaluation. We agree with the licensee's basis, and therefore feel that relief should be granted for Category 8 valves

, 1(2)-1402-38A and 388 from the stroke timing requirements of Section XI.

1 The licensee has demonstrated that obtaining meaningful data to determine valve degradation on valves with variable strcke times is not possible. In

addition, if these valves faileo in the full open position design pump flow can still be achieved. We conclude that the proposed alternate test method -

to observe that these valves do close on an increase in pump flow should demon- strate proper valve operability.

9 7.2 Category C/E Valves s

7.2.1 Relief Request. The licensee has requested specific relief i from exercising Category C/E valves 1(2)-1402-13A and 138, core spray pumps l minimum flow recirculation checks, in accordance with the requirements of 1

Section XI and proposed to make plant modifications to install flow devices in these lines for valve full stroke exercising verification.

] 7.2.1.1 Code Requirement. Refer to Appendix A.

7.2.1.2 Licensee's Basis for Requesting Relief. There are no

provisions in the current system design for exercising or determining the

position of these valves. Based on the record of satisfactory pump perfor-mance and lack of pump overheating problems, it is evident that these valves have performed in an acceptable manner. However, due to the inability to demonstrate that the valves stroke open, Quad Cities Station has initiated 1

system modifications to install flow instrumentation in the minimum flow lines-to indicate that the valves are, in fact, opening and passing adequte flow for pump cooling purposes. The modifications must be made during a 4 refueling outage because the system will be out of service during the

installation. The modifications will be implemented at the earliest pos-

! sible date which is contingent on the availability of materials. Relief is

therefore requested from the r!quirement to demonstrate that the subject

! valves stroke open until system modifications provide the necessary instrumentation.

No specific alternate test is applicable during this interim period.

7.2.1.3 Evaluation. We agree with the licensee's basis and therefore feel that temporary relief should be granted for Category C/E ,

valves 1-1402-13A and 138 from the exercising requirements of Section XI.

l The licensee has demonstrated that with the present plant design a method to verify these valves open fully (their safety related position) does not .

exist. We conclude that the proposed plant modifications to install flow

devices will provide a means to verify proper valve operability.

{

21

l l

8. High Pressure Coolant Injection 8.1 Category A/C Valves

8.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 1(2)-2301-34 and 45, primary contain-  ;

ment isolations, in accordance with the requirements of Section XI and proposed to exercise these valves open during pump testing and to verify valve closure (their other safety related position) during refueling outages.

8.1.1.1 Code Requirement. Refer to Appendix A.

8.1.1.2 Licensee's Basis for Requesting Relief. It is impracti-cal to demonstrate closure of these check valves during normal operation or cold shutdown. To verify closure upon reversal of flow a pressure test must be performed. This requires that the systems be taken out-of-service.

The safety significance of these components is minimal since leakage past ,

these valves would be contained within the HPCI piping which returns to the containment.

4 These valves will be demonstrated to close upon reversal of flow during each refueling outage per Appendix J test.

8.1.1.3 Evaluation. We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C valves '

1(2)-1301-34 and 45 from the exercising requirements of Section XI. The

licensee has demonstrated that valve full stroke opening will be accom-l plished during the quarterly pump test but, due to plant design the only 4

method available to verify valve closure (their other safety related posi-tion) is leak testing. These valves are not equipped with valve position indicators and some of the required test connections are located inside the i containment. We conclude that the proposed alternate testing frequency of full stroke open exercising quarterly and verifying valve closure during

the performance of le&k rate testing at refueling outages should demon-strate proper valve operability.

8.2 Category B Valves 8.2.1 Relief Request. The licensee has requested specific relief

from timing Category B valves 1(2)-2301-14, HPCI pump minimum flow recircu-lation isolations, in accordance with the requirements of Section XI.

8.2.1.1 Code Requirement. Refer to Appendix A.

i , 8.2.1.2 Licensee's Basis for Requesting Relief. Relief is requested from measuring the stroke time of these valves. Since the valves i

close automatically when adequate pump flow is reached, it is difficult to accurately measure the stroke time. An equally meaningful test would be to just verify that the valves do close automatically as the pump flow increases.

An operator will verify tnat these valves automatically close as pump flow increases during quarterly pump operability testing. ,

22 ,

1 8.2.1.3 Evaluation. We agree with the licensee's basis, and therefore feel that relief should be granted for Category B valves 1(2)-2301-14 from the stroke timing requirements of Section XI. The licen-see has demonstrated that obtaining meaningful data to determine valve degradation on valves with variable stroke times is not possible. In addi-tion, if these valves failed in the full open position design pump flow can still be achieved. We conclude that the proposed alternate test method to observe these valves do close on an increase in pump flow should demon-strate proper valve operability.

8.3 Category C Valves 8.3.1 Relief Request. The licensee has requested specific relief from exercising Category C valves 1(2)-2301-39 (for function see relief request basis) in accordance with the requirements of Section XI and pro-posed to disassemble these valves every third refueling outage to verify that the disc swings freely to the open position.

8.3.1.1 Code Requirement. Refer to Appendix A.

8.3.1.2 Licensee's Basis for Requesting Relief. These valves are designed to prevent backflow into the suppression pool in the event of a pump suction shif t from the contaminated condensate storage tank (CCST) to the suppression pool. The safety related stroke direction of this valve is in the open direction to provide suction flow to the HPCI pump. There is no acceptable method for verifying this valve's ability to swing to its full open position. The system test circuit utilizes the CCST as the pump suction rather than the suppression pool. The suppression pool is not used as the pump suction for testing because of the desire to keep the system free of the dirt and contamination typically found in torus water.

In lieu of the Code required full stroke test, C'ommonwealth Edison proposes to demonstrate valve operability by disassembling the valve and verifying that the disc swings freely to the full open position. Since this valve is not normally used, there will be no expected wear-induced degradation of the valve internals. Therefore disassembly and inspection of these valves once every third refueling outage is felt adequate to ensure valve operational readiness.

It should also be mentioned that an evaluation is being conducted to determine if these valves can be removed from the system. If this proves to be feasible, the valve internals will be removed and this relief request would no longer be required.

Each valve will be disassembled every third refueling outage to verify that the disc swings freely to the full open position.

• 8.3.1.3 Evaluation. We agree with the licensee's basis and therefore feel relief should be granted for Category C valves 1(2)-2301-39 from the power operation and cold shutdown exercising requirements of Sec-tion XI. The licensee has demonstrated that the system test circuits only permit HPCI pump suction from the CCST which will not exercise these valves.

Also, if a suction were taken from the suppression pool the HPCI system 23

would be contaminated which would require removing the system from service to flush and cleanup the sytel. However, we' conclude that a method to full stroke exercise these valves Jn a refueling outage basis is available (i.e.,

taking a suction from the suppression pool when system availability is not required and cleanup flush time will not limit plant operation, or manual disassembly and exercising each refueling outage).

8.3.2 Relief Request. The licensee has requested specific relief from exercising Category C valves 1(2)-2301-40, HPCI pump minimum flow O recirculation checks, in accordance with the requirements of Section XI and

proposed to make plant modifications to install flow devices in these lines i for valve full stroke exercising verification.

8.3.2.1 Code Requirement. Refer to Appendix A.

8.3.2.2 Licensee's Basis for Requesting Relief. There are no provisions in the current system design for exercising or determining the position of these valves. Based on the record of satisfactory pump perfor-mance and lack of pump overheating problems, it is evident that these valves have performed in an acceptable manner. However, due to the inabil-ity to demonstrate that the valves stroke open, Quad Cities Station has 1

initiated system modifications to install flow instrumentation in the mini-i' mum flow lines to indicate that the valves are, in fact, opening and pas-sing adequte flow for pump cooling purposes. The modifications must be made during a refueling outage because the system will be out of service during the installation. The modifications will be implemented at the earliest possible date which is contingent on the availability of materials.

Relief is therefore requested from the requirement to demonstrate that the subject valves stroke open until system modifications provide the necessary instrumentation.

No specific alternate test is applicable ouring this interim period.

8.3.2.3 Evaluation. We agree with the licensee's basis and therefore feel that temporary relief should be granted for Category C valves 1(2)-2301-40 from the exercising requirements of Section XI. The licensee has demonstrated that with the present plant design a method to verify these valves open fully (their safety related position) does not exist. We conclude that the proposed plant modifications to install flow devices will provide a means to verify proper valve operability.

l 9. Main Steam

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9.1 Category B/C Valves 9.1.1 Relief Request. The licensee has requasteo specific relief

• from exercising Category B/C valves 1(2)-203-3A through 3E, safety and L electromatic relief valves, in accordance with the requirements of Sec-tion XI and proposed to calibrate the pressure switches that actuate these

valves and exercise these valves on the frequency specified in the relief request basis.

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9.1.1.1 Code Requirement. Refer to Appendix A.

9.1.1.2 Licensee's Basis for Requesting Relief. Relief is '

requested from the Section XI required testing frequency of once every three months. These electromatic relief valves are not tested routinely during reactor operation Decause of the resultant primary system pressure transients. In addition, a failure of any valve to close would cause an uncontrolled, rapid depressurization of the primary system resulting in undesirable thermal gradients in the reactor vessel. cxcessive testing of 6 tnose valves is inadvisable because each relief valve discharge to the suppression pool detracts from the limited life of the containment.

These valves cannot be tested at cold shutdown or refueling since a

• system pressure of greater than 150 psig is needed to actuate the valves.

Surveillance testing of these valves is, therefore, completed at very low reactor power levels. Verification of relief valve actuation is accom-plished by first opening a turbine bypass valve, actuating the relief valve, and then observing a corresponding closure response of the turbine bypass valve.

The frequency of such testing requested herein is that submitted by Quad Cities Station in a proposed Technical Specification change required by the August 3, 1977 letter from Don K. Davis (NRC-DOR) to Commonwealth Edison Company. In this Technical Specification change, a program was committed to which specified a variable testing frequency related to demen-strated reliability and operability. The testing interval is based on the number of valve failures during the required test interval. The frequency ranges from a maximum of 18 months to a minimum of 31 days. This testing frequency is provided to ensure operability and demonstrate reliability of the valves. Since the frequency varies with observed valve failures, this proposed testing scheme should result in a uniform level of reliability.

The following schedule will be used to determine the required test interval.

Numoer of Relief Valves Founa Inoperable Next Required During Testing or Test Interval Test Interval 0 18 months 1 25%

1 184 days 1 25%

2 92 days 1 25%

>3 31 days 1 25%

s Additionally, stroke times for these valves will not be measured since I there is no position indication circuitry to show disc movement.

The electromatic relief valves and the relief function of the Target Rock valve are operated by actuation of a pilM solenoid valve which opens the main valve by applying system pressure to _ diaphragm. The pilot valve is actuated from an electric signal from either the control sv. itch, the l

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auto-depressurization logic, or a pressure switch that senses system pressure.

The requirement of-IWV-3510(b) to check relief and safety. valve set points in accordance with PTC-25.2-1966 is not applicable in this case.

Therefore, relief is requested from compliance with this requirement.

The pressure set point of these valves is set by calibrating the pres-i 'sure switch rather than testing the complete valve assembly. The combina-

! ~ tion of the pressure switch calibration and the exercising test for oper-ability (BT) satisfies the intent of paragraph IWV-3510.

' s The pressure switch for each of these valves will be calibrated to verify the correct set point and the exercise test (BT) will verify oper-

ability of the valve.

9.1.1.3 Evaluation. We agree with the licensee's basis and therefore feel that relief should be granted for Category B/C valves 1(2)-203-3A through 3E from the exercising and timing requirements of Sec-tion XI. The licensee has demonstrated that exercising these valves during power operation would result in primary system pressure transients that could cause a reactor trip due to plant depressuriza; ion if any valve failed in the open position. During cold shutdown, primary system pressure is not-available to actuate these valves. We conclude that exercising these valves more often than proposed by the licensee would re.sult in unnecessary thermal fatigue stresses to the containment. In addition, calibrating the pressure 1

setpoints for the solenoid actuating valves and exercising the relief valves i

per the proposed schedule meets the intent of Section XI and should demon-strate proper valve operability. Furthermore, tne measuring of stroke times for relief valves will not provide any meaningful data to determine valve degradation.

11 . 2 Category C Valves 9.2.1 Relief Request. The licensee has requested specific relief from exercising Category C relief valves 1(2)-203-4A through 4H, safety relief valves for the primary coolant pressure boundary in accordance with the requirements of Section XI and proposed to remove one-half of the' safety valves and replace these valves with valves that have been rebuilt and had i their set point verified each refueling outage.

l 9.2.1.1 Code Requirement. Refer to Appendix A.

9.2.1.2 Licensee's Basis for Requesting Relief. It is impracti-cal for Quad Cities Station to meet the requirements of IWV-3510, in that j, "as-found" set points for these safety relief valves cannot be determined.

The station has no on-site facility for testing safety valve set points.

i Currently, these valves are being removed from the system, cleaned and l rebuilt, and then shipped off-site for re-verification of valve set points.

Therefore, IWV-3510(c) cannot be applied because "as found" set points are not verified.

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The frequency of removal and maintenance of these valves, however, is on a greatly accelerated basis compared to the Section XI requirements.

The Technical Specification frequency for these valves has been to remove one-half (4) of the eight safety valves each refueling outage and replace them with valves that have been rebuilt 4.nd verified for proper set point.

This accelerated maintenance schedule provides adequate assurance that these valves will perform reliably.

One-half (4) of the total number of safety valves will be removed and '

replaced with valves that have been rebuilt and had their set points veri-fied each refueling outage.

9.2.1.3 Evaluation. We agree with the licensee's basis and therefore feel that relief should be granted for Category C relief valves 1(2)-203-4A through 4H from the "as found" set point verification required by Section XI. We conclude that since no means is available to test these valves on site that senaing valves off-site for relief function testing ano installing functionally tested valves with a more restrictive frequency then that required by Section XI more than meets the intent of Section XI and should demonstrate that these valves are available to perform their design safety function.

10. Feedwater

10. 1 Category A/C and C Valves 10.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 1(2)-220-58A and 58B and 1(2)-220-62A and 628, containment isolation feedwater checks, and Category C valves 1(2)-220-598, HPCI to feedwater reverse flow checks, in accordance with the requirements of Section XI and proposed to verify valve opening during pump testing and closure (their other safety related position) during refueling outages.

10.1.1.1 Code Requirement. Refer to Appendix A.

10.1.1.2 Licensee's Basis for Reauesting Relief. These check valves cannot be tested for ope.cability during reactor operation because the feedwater system is needed to maintair. primary coolant inventory. It is impractical to test thesa valves during cold shutdown because the reac-tor water cleanup and feedwater systems are generally required to De oper-able. In addition, to verify that these check valves stroke to the full -

l closed position, a leak rate test must be performed. Since leak rate testing is performed only during refueling outages, these valves will be demonstrcted to be in the full closed position at each refueling outage. s 10.1.1.3 Evaluation. We agree with the licensee's basis, and therefore feel that elief should be granted for Category A/C vc'"es i

1(2)-220-58A and 588 and 1(2)-220-62A and 628, and Category C valves i 1(2)-220-598 from the exercising requirements of Section XI. The licensee has demonstrated that valve full stroke opening will be accomplished during the quarterly pump test but, due to plant design the only method available 27

i to verify valve closure (their other safety related position) is during leak testing. These valves are not equipped with valve position indicators and some of the required test connections are located inside the contain-mant. We conclude that the proposed alternate testing frequency of full stroke open exercising quarterly and verifying valve closure the perform-ance of leak rate testing at refueling outages should demonstrate proper valve operability.

11. Neutron Monitoring System

11. 1 Category A/C Valves a 11.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C valves 1(2)-743, primary containment isola-tions for T.I.P. system nitrogen purge lines in accordance with the require-ments of Section XI and proposed to verify valve closure (their safety related position) during refueling outages.

11.1.1.1 Code Requirement. Refer to Appendix A.

11.1.1.2 Licensee's Basis for Requesting Relief. These check valves cannot be exercised for operability every three months because the T.I.P. system is' required te be purged constantly during operation. Since thera is no external means of position indication, the system must be taken out-of-service and a leak rate test performed to verify operability. Since leak rate testing is performed only during refueling outages, these valves will be demonstrated to De in the full closed position at each refueling outage.

11.1.1.3 Evaluation. We agree with the licensee's basis and therefore feel that relief shoulo be granted for Litegory A/C valves 1(2)-743 from the exercising requirements of Sect,in XI. The licensee has demonstrated that due to plant design the only me' nod available to verify valve closure (their safety related position) is leak rate testing. These valves are not equipped with valve position indicators and some of the required test connections are located inside the containment. We con-clude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should verify proper valve operability.

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

-IV. APPENDIX A '

i 1. Code Requirements--Valves n

4 Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code

.(which discusses full stroke and partial stroke requirements) requires that 4

Code Category A and B valves be exercised every three months, with excep-l tions as defined in IWV-3410gd)(1), (e), and (f). IWV-3520(a) (which dis-cusses full stroke and partial stroke requirements) requires that Code  ;'

Category C valves be exercised once every three months, with exceptions as defined in IWV-3520(b). In the above cases of exceptions, the Code permits the valves to be tested at cold shutdown where: ,

1. It is not practical to exercise the valves to the posi-tion required to fulfill their function or to the par-tial position during power operation l 2. It is not practical to observe the operation of the valves (with failsafe actuators) upon loss of actuator power.

Subsection IWV-3420(c) requires all Category A and B power-operated

, valves to be stroke time tested to the nearest second or 10% of the maximum

{ allowable owner-specified stroke time.

l 2. Code Requirements--Pumps

An inservice test shall be conducted on all safety-related pumps, nominally once each month during normal plant operation. Each inservice i 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.

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. V. ATTACHMENT I The following are Category A, B, and C valves that meet the require-ments of _the ASME Code Section XI and are not full stroke exercised every three months during plant operation. These valves are specifically identi-

.fied by the owner and are full stroke exercised during cold shutdowns and refueling outages. EG&G has reviewed all valves in this attachment and i agrees with the licensee that testing these valves during power operation j 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 i these valves should not be exercised during power operation. These valves

! are listed below and grouped according to the system in which they are y located.

1 j 1. Recirculation i

1.1 Category B Valves Category B valves 1(2)-202-5A and 58, recirculation loop .c:vaticas, cannot be full stroke or partial stroke tested during. normal operatien since isolation of a recirculation loop would cause a recirculation pump trip which would require a reactor trip. One loop operation is restricted by the Technical Spet.ifications.

1 These valves wi~il be full stroke exercised during cold shutdown.

j 2. Control Rod Drive 2.1 Category B Valves f Category.B valves 1(2)-0302-21A, 21B, and 22, scram discharge volume vents and drains, cannot be exercised during power operation. These valves are normally in the open position to allow water which enters tne scram discharge volume from normal CRD leakage to drain into the reactor building equipment drain tank. This assures that a sufficient volume is always available to accept scram discharge water following a scram. The testing of these-valves during plant operation has the potential of isolating the scram discharge volume and the increasing water level in the volume would then cause a reactor scram. Consistent with NRC staff guidelines con-cerning the cycling of valves that could potentially place the plant in an unsafe mode of operation, it is felt that these valves should be tested at cold shutdown. This applies to the vent and drain valves since the air supply to the valves and the test circuit is common for all three valves.

These valves will be full stroke exercised during each cold snutdown.

!* 3. Residual Heat Removal

3.1 Category A Valves Category A valves 1(2)-1001-29A and 29B, LPCI injection containment isolations, and Category B valves 1(2)-1001-28A and 288, LPCI injection pressure isolations, cannot be exercised durin] power operation. Both sets 30

of valves are included because they are interlocked such that one of the two valves must be closed at all times to provide the pressure isolation function. A failure of any one of these valves in the closed position would render the entire LPCI function technically inoperable since botn injection loops .nust be available in the design basis accident to provide coolant to the unbroken recirculation. loop and this loop could be either one of the two.

To ensure that v; ve exercising procedures do not place the plant in an unsafe mode of operation, these valves will be full stroke exercised only at cold shutdowns.

3.2 Category A Valves Category A valves 1(2)-1001-60,63,47,ar. 50, primary contair. ment isolation valves for RHR head spray and shutdow.. ooling cannot be exer-cised during power operation. Relief is request from partial or full stroke testing these valves during power operati These valves, which are normally closed during plant operation, servu isolation between the high and low pressure piping. Protective interloc prevent opening these valves while the reactor is at operating pressure. he valves will be exercised during colo shutdown.

3.3 Category B Valves Category B valves 1(2)-1001-19A and 198, RHR cross ie isolations, should not be exercised during power operation. These s' 1es are normally in their safety position (open) and are only closed a ver, small percentage of plant operating time when the system is in the residual i,-=t removal mode. Testing these valves during normal opeation places the piant in an unsafe mode because a failure of either valve in the closed position ren-ders the low pressure coolant injection (LPCI) function inoperable. The LPCI function of RHR is designed such that three of the four pumps are required to provide makeup flow to either recirculation loop in the event of a design basis loss of coolant accident. This requires the crosstie line to be open and, hence, both the 1001-19A and B valves. In accordance with NRC staff guidelines on excluding the cycling of valves whose failure in a non-conservative position would cause a loss of system function, these valves will be exercised during cold shutdown conditions.

3.4 Category C Valves Category C valves 1(2)-1001-68A and 688, RHR/LPCI header checks, can- t not be exercised during power operation. These valves have air-operators and remote position indicators for remote testing purposes. However, during normal operation the high differential pressure across the valve *

seats prohibits exercising. Additionally, the RHR/LPCI system valves 1(2)-1001-68A, 688 are located inside the primary containment which is inerted with nitrogen during normal operation. These valves will be full stroke exercised during cold shutdown.

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4. Core Spray  !

4.1 Category C Valves Category C valves 1(2)-1402-9A and 98, core spray header checks, can-not be. exercised during power operation. These valves have air-operators and remote position indicators for remote testing purposes. However, during normal operation the high differential pressure across the valve seats prohibits exercising. Additionally, the core spray system valves 1(2)-1402-9A and 98 are located inside the primary containment which is

inerted with nitrogen during normal operation. These valves w;11 be full Q oke exercised during cold shutdown.

5. Pressure Suppression

! 5.1 Category A Valves

! Category A valves 1(2)-1601-20A and 208, reactor building to torus i vacuum breaker and primary containment isolations, should not be exercised during power operation. Exercising these valves open during normal plant

operation compromises primary containment integrity and reduces safety margins by. leaving only a single check valve (1601-31A_or 8) to maintain the primary containment boundary. These valves will be full stroke exer-cised during cold shutdown.

5.2 Category C Valves Category C valves 1(2)-220-81A through 81E, vacuum breakers for main

steam relief valve discharge lines, cannot be exercised during power oper-ation. These check valves have no external means of actuation for exer-cising. The only practical method for exercising these valves open is by manually pushing the disc from its seat using a small diameter rod. Since

this requires access to the valves which are located within primary con-J tainment, the test must be deferred to cold shutdowns when the primary 1 containment is de-inerted. These check valves will be verified to freely l swing to their full open position at cold shutdowns when the (rywell is de-inerted.

6. High Pressure Coolant Injection 6.1 Category A Valves

' , Category i valves 1(2)-230-4 and 5, primary containment isolations and steam supply tc HPCI turbines, should not be exercised during power i operation.

The above valves are normally open to supply steam to the turoine driven HPCI injection pumps. Conservatively these valves are left in the

open position to insure that driving steam can be supplied to these tur-bines at all times during operation. Also, these valves serve a primary containment isolation function (Group 4).

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

l Quad Cities Station feels that to close these valves during operation would place the operation of the system in an untenable condition. Fur-ther, if either were to fail closed it would render the HPCI system inoper-able. These valves will be full stroke exercised during cold shetdowns.

6.2 Category C Valves Category C valves 1(2)-2301-7, HPCI header checks, cannot be exercised during power operation. These valves have air-operators and remo'.e posi- ,

tion indicators for remote testing purposes. However, during normal oper- "

ation the high differential pressure across the valve seats prohibits exer-cising. The high pressure coolant injection valve 1(2)-2301-7 is located inside the main steam isolation valve room which is a designated high radi- 9 ation area where normal power operation radiation dose rates are one to two rem / hour. Also high temperatures exist in this area (120* to 140*F) which i

further increases the hazards involved in eqtering the area for this testing. The accumulated dose to conduct this test would be approximately 1.5 man / rem. These valves will be full stroke exercised during cold shutdown.

7. Main Steam j

7.1 Category A Valves Category A valves 1(2)-203-1A through 1D and 1(2)-203-2A through 20, primary containment isolations for the main steam lines, cannot be r

exercised during power operation. Full stroke testing these valves during

, normal reactor operation requires isolating one of the four main steam

lines. Isolation of these lines results in primary system pressure spikes, reactor power fluctuations, and increased flow in the unisolated steam lines. This unstable operation can lead to a reactor scram and, as discussed in NUREG-0626, pressure transients resulting from full stroke testing MSIVs increase the chances of actuating primary system relief valves.

It is proposed that only partial stroke testing be performed during power operation and that full stroke testing be performed at cold shut-downs. These valves are provided with the circuitry to permit partial stroking to a 10% closed position. This partial stroke exercising provides an acceptable means of verifying valve performance during plant operation without affecting safety margins. This request also contributes to the reduction of the relief valves challenge rate as recommended in NUREG-0626.

These valves will be part stroke exercised every three months and full

! stroke exercised during cold seutdown. The fail-safe operation of these valves will also be checked during cold shutdown since this is done coinci- ,;

. dent with full stroke exercising. The fail-safe testing of valves i 1(2)-203-lA, B, C and D howevcc, will be completed only at cold shutdowns l When the primary containmer.c is deinerted since access to the valves to i perform this testing requires entry into the drywell.

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I VI. ATTACHMENT II The drawings listed below were used during the course of this review.

Drawings System Unit 1 Unit 2 Main Stema ISI-13-1 and -2( A) ISI-60-1 and -2 Reactor Feedwater 151-15 IS I-62 Service Water / Emergency Diesel ISI-?' ISI-69 Nuclear Boiler ISI-35-1 ana -2 IS I-77-1 and -2 e Core Spray ISI-36 151-78 Re:idual Heat Removal ISI-37 and -39 ISI-79 and -81 Standby Liquid Control 151-40 IS I-82 Control Rod Drive ISI-41 151-83 High Pressure Coolant Injection IS I-46 IS I-87 Reactor Water Clean-up IS I-47 151-88 Reactor Core Isolation Cooling 151-50 IS I-89

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l VII. ATTACHMENT III )

i The valves listed in Section 8.3.1 have a proposed testing frequency '

greater than each refueling outage and relief is not reconmended due to an insufficient technical basis.

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f VIII. ATTACHMENT V The following valves should be reviewed by the NRC Appendix J review committee to determine if they should be categorized A, A/C, or A/E, included in the IST program, and leak tested in accoraance with the requirements of Appendix J and, thus, exercised in accordance with the requirements of Section XI or specific relief requested.

Control Rod Drive s

1(2)-0301-74-95 and -98 ca Reactor Core Isolation Cooling 1(2)-1301-25, -26, and -60 Core Spray 1(2)-1402-4A,-48,

-3A, -38,

-9A, -98,

-25A, -258,

-38A, -388 High Pressure Coolant Injection 1(2)-2301-14, -35, and -36 Instrument Air 1(2)-4722A and -47228 9

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