ML20003F116
| ML20003F116 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/31/1981 |
| From: | Fehringer J, Rockhold H EG&G IDAHO, INC., EG&G, INC. |
| To: | Nerses V Office of Nuclear Reactor Regulation |
| References | |
| CON-FIN-A-6258 EGG-EA-5348, TAC-11245, NUDOCS 8104200209 | |
| Download: ML20003F116 (36) | |
Text
EGG-EA-5348 P00R sususHHL March 1981 SAFETY EVALUATION REPORT, INSERVICE TESTING PROGRAM, TROJAN NUCLEAR PLANT - DOCKET NO. 50-344 l
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This is an informal report intended for use as a preliminary or working document t
NRC Researc1 anc Tec1nical ssistanCe lep0ft Prepared for the U.S. Nuclear Regulatory Connission Under DOE Contract No. DE-AC07-76ID01570 Q
8104200 sob g
hEGsG..e h ",IN**
INTERIM REPORT Accession No.
Report No. EGG-EA-5348 Crntract Program or Project
Title:
Systems Engineering Support Subject of this Document:
Safety Evaluation of the Inservice Testing Program for Pumps and Valves at the Trojan Nuclear Plant (Docket No. 50-244) for the Period 9-20-79 through
~5-19-81 Type of Document:
Safety Evaluation Report t
Author (*):
J. M. Fehringer NRC Researc,i anc' 7ecinical H. C. Rockhold ASSIStag by3l.
DIte of Document:
March 1981 P
R:sponsible NRC Individual and NRC Office or Division:
Victor Nerses, NRC-DE e
\\
This document was prepared primarily for preliminary or internal use. It has not received full review and approval. Since there may be substantive changes, inis document should not be considered final.
EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclesr Regulatory Commission Washington, D.C.
Under DOE Contract No. DE-AC07-76lD01570 NRC FIN No.
A6258 INTERIM REPORT
NRC Researc1 ancechnica f$$lSI80Ce Rep 0ft CONTENTS I.
I NT R O D UC T I ON....................................................
I 1
II.
PUM P T E ST I N G PRO GR AM............................................
2 1.
Serv ice Wa ter Pumps (P-108A, B, and C)......................
2 2.
Diesel Fuel Oil Punps (P-144A and B)........................
3 III.
V AL VE TE STING PROGR AM EVALUATION................................
4 1.
General Considerations......................................
4 1.1 Testing of Valves which Perform a Pressure Isolation Function...........................
4 1.2 ASME C ode, S ec t i on X I, Req u i ren en t s...................
5 1.3 Stroke Testing of Check Valves........................
5 4
1.4 Stroke Tes ting of Mo tor-0pera ted Val ves...............
5 1.5 Test Frequency of Check Valves Tested at Co l d S hu t d o wn s........................................
6 1.6 Licensee Request for Relief to Test Valves a t Co l d S hu t d o wn s.....................................
6 1.7 Changes to the Technical Spec ificat ions...............
6 i
1.8 S a f e t y-R e l a t ed V a l v e s.................................
7 j
1.9 Valve Testing at Cold Shutdowns.......................
7
- 1. 10 Category A Valve Leak Check Requirenents l
f or Con tai nmen t I sol at ion Valves (CIVs)...............
7 1.11 Application of Appendix J Testing to the IST Program...........................................
8 l
2.
Safety-Related Valves (Generic Reliefs).....................
8 j
2.1 Containnent Isolation Valves..........................
8 i
2.2 Event V Configurati on Valves....................
9 2.3 Valves Designated Category E......................
11 2.4 Passive Valves........................................
12 l
- 3. Reactor Coolant.............................................
13 ii
3.1 Category A/C Valves...................................
13 4.
Chemi c al a nd Vol ume C on trol.................................
14 4.1 Ca tegory A/C and A Val ves.............................
14 5.
R e s i du al H e a t R eno v al.......................................
15 5.1 Category C Valves.....................................
15 6.
S a f e ty I nj ec t i on............................................
16 6.1 Category A/C Valves...................................
16 6.2 C a t e g ory C V a l v e s.....................................
16 7.
Containment Spray...........................................
17 7.1 C a te g or y C V a l v e s.....................................
17 8.
M a i n and Aux i l i ary F eedwa te r................................
18 8.1 C a te g ory C V a l v e s.....................................
18 9.
Other Systems...............................................
19 9.1 C a te g ory A /C V a l v e s...................................
19 IV.
APPENDIX A......................................................
21 V.
AT TAC H M E N T I....................................................
22 1.
Reactor Coolant.............................................
22 1.1 C a te g ory A /C V al v e s...................................
22 1.2 Category C Valves.....................................
22 2.
Cnemi c al a nd Vol ume C on trol.................................
22 2.1 Category B Valves.....................................
22 2.2 C a t eg ory C V a l v e s.....................................
22 2.3 Category C Valve......................................
23 3.
R e s i du u l H e a t R emo v a l.......................................
23 3.1 Category A/C Valves...................................
23 3.2 C a te g ory A /C V a l v e s...................................
23 3.3 C a t e g o ry B Va l ve s.....................................
23 111 s
3.4 Category B Valve......................................
23 3.5 C a teg ory B V a l v e s.....................................
23 3.6 Category B Valve......................................
24 3.7 C a te g ory C V a l v e s.....................................
24 4.
Safety Injection............................................
24 4.1 C a te g ory B V a l v es.....................................
24 4.2 Category B Valves.....................................
24 4.3 C a teg ory B Val ve s..................................... 24 4.4 C a t e g o ry A/C V a l v e s...................................
25 4.5 C a t e g or y C V a l v e......................................
25 4.6 Category C Valves.....................................
25 4.7 C a t eg ory C V a l v e s.....................................
25 5.
Main Steam..................................................
25 5.1 C a teg ory 8 /C V al v e s...................................
25 6.
Main and Auxiliary Feedwater................................
26 6.1 C a teg ory C V a l v e s.....................................
26 6.2 Category C Valves.....................................
26 6.3 C a te g ory C V a l v e s.....................................
26 7.
C om p o n e n t C o o l i n g...........................................
26 7.1 C a teg ory B V a l v e s.....................................
26 I
7.2 C a t e g o ry B V a l v e s.....................................
26 8.
O t h e r Sy s te ms...............................................
27 8.1 Category A Valves.....................................
27 8.2 C a teg ory A V a l v e s.....................................
27 VI.
ATTACHMENT II...................................................
28 VII.
ATTACHMENT III..................................................
29 VIII. ATTACHMENT IV
........................s 30 iv
I.
INTRODUCTION Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Portland General Electric Company (PGE) on 8-14-79 for its Trojan Nuclear Plant.
The program applies to Troj an f or the period 9-20-79 through 5-19-81.
The working session with PGE and Trojan representatives was conducted on 7-29, 7-30, and 7-31-80.
Tne licensee resubmittal was issued on 12-8-80 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 Sunmer of 1975 Addenda.
PGE has also requested relief from the ASME Code from testing specified pumps and valves because of practical reasons.
These requests have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed imp rac tical.
Tne evaluation of the pump testing program and associated relief requests is contained in Section II; the evaluation of the valve testing program anJ associated relief requests is contained in Section III.
All evaluations for Sections II and III are the recommendations of EG&G Idaho, Inc.
A sumnary of 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 three months are contained in Attacnment I.
A listing of P& ids used for this review is contained in Attachment II.
Valves that are never full stroke exercised or that have a testing interval greater than eacn refueling outage and relief requests with insuf-ficient tecnnical basis where relief is not recomnended are suamarized in Attacnment III.
Valves that are included in the IST program that should be reviewed by tne NRC, Appendix J, review committee to determine if they should be cate-gorized A, A/C, or A/E are sunnarized in Attachment IV.
W 9
1
d II.
PLNP TESTING PROGRAM The IST program submitted by PGE for its Trojan Nuclear Plant was examined to verify.that Class 1, 2, and 3 safety-related pumps were included in the program and tnat those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that Class 1, 2, and 3 safety-related pumps were included in the IST program and, except for those pumps identified below for which specific relief from testing has been requested, the pump tests and frequency of testing comply with the code.
Each PGE basis for requesting specific relief from testing pumps and the EG&G evaluation of that request is summarized (Sections 2 and 3) below and grouped according to the system in which the pumps reside.
1.
Service Water Pumps (P-108A, B, and C) 1.1 Relief Request The licensee has requested specific relief for the service water pumps from the Section XI requirements to measure inlet pressure (Pj), vibra-tion amplitude (V), and bearing temperature (T ), and proposed to calcu-b late P i and measure V on the motor bearing.
1.1.1 Code Requirement Refer to Appendix A.
1.1.2 Licensee's Basis f or Requesting Relief.
" Instrumentation Not Originally Prov ided."
Class 3 pumps at Trojan were not required to be designed f or testing f or operational readiness as per 10 CRF 50.55a(g).
The pumps are totally submerged inside the Intake Structure.
Pump bearings are inaccessible and the instrumentation required for measurement of pump inlet pressure, vibration amplitude, and bearing temperature was not provided in the original system design.
Inlet pressure for these pumps will be detennined by measuring the Intake Structure water level and substituting the measured value into tne following formula which relates this level to the pump inlet pressure:
Pj = 0.433 (24.75 - Intake Structure level).
Tne pumps are submerged in the Intake Structure and are not accessible f or attachment of transducers f cr displacement measurement of vibration amplitudes during pump operation.
The pump motor inboard bearing will be periodically monitored for vibration amplitude. Motor inboard bearing vibration measurements provide indication of pump shaf t alignment and de ter i ora tion. The pump bearing vibration amplitude will not be measured.
The pump bearing temperature will not be measured.
1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should oe granted from the Section XI requirement to measure Pj, V, and To f or the service water pumps. The licensee has demonstrated that, because their pumps are submerged and inaccessible and instrumentation was not provided, measuring Pj, V, and Tb in accordance 2
with the Section XI requirements is not practical. We conclude that calcu-lating P, measuring V on the pump motor bearing, and measuring all other i
parameters (except T ) in accordance with the requirements of Section XI b
should provide the required imformation to determine any hydraulic or mech-anical degradation of these pumps.
2.
Diesel Fuel Oil Pumps (P-144A and B) 2.1.
Relief Request The licensee has requested specific relief for the diesel oil transfer pumps from the Section XI requirements to measure inlet pressure (P ),
i differential pressure (dp), vibration amplitude (V), and bearing tempera-ture (T ), anJ proposed to calculate Pi and dp and measure V on the b
motor bearing.
2.1.1 Code Requirement. Refer to Appendix A.
2.1.E Licensee's Basis for Requesting Relief.
" Instrumentation Not Originally Provided." Class 3 pumps at Trojan were not required to be designed f or testing for operational readiness as per 10 CFR 50.5Sa(g).
Tnese pumps are located inside the diesel oil storage tanks.
The pumps are inaccessible and and instrumentation was not provided for measurement of inlet pressure, differential pressure, flow, vibration amplitude, or bearing temperature.
Pump discharge pressure will be measured and the inlet pressure will be calculated from tank level and tne suction head on the pump. The dif-ferential pressure will be taken as the difference between pump discharge pressure and calculated inlet pressure.
The pumps are enclosed within the diesel oil storage i.anks and accessi-bility is not available for measuring pump vibration amplitude. The pump motor will be periodically monitored for vibration amplitude. Motor vibra-l tion measurements provide indication of pump shaf t alignment and deterioration.
The pump bearing temperature will not be measured.
2.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief shouTd be granted from the Section XI requirements to l
measure Pj, dp, V, and Tb for the diesel fuel oil pumps.
The licensee has demonstrated that, because these pumps are submerged and inaccessible and instrumentation was not provided, measuring Pj dp, V, and Tb in accordance with the requirements of Section XI is not practical. We con-clude that calculating Pt and dp, measuring V on the pump motor and measuring all other parameters (except T ) in accordance with the require-b I
ments of Section XI should provide the required information to determine any hydraulic or mecnanical degradation of these pumps.
t 3
III.
VALVE TESTING PROGRAM EVALUATION The IST program submitted by PGE f or its Trojan Nuclear Plant was examined to verify that Class 1, 2, and 3 safety-related valves were included in the program and that tnose valves are subjected to the periodic tests required by the ASME Code,Section XI, and the IRC positions and guidelines.
Our review found that Class 1, 2, and 3 safety-related valves were included in the IST program and, except for those valves identified below for which specific relief from testing has been requested, the valve tests and f requency of testing comply with the code requirements and the NRC positions and guidelines listed in Section 1.
Also, included in Sec-tion 1 is the fRC position and valve listings for the leak testing of valves that perform a pressure isolation function and a procedure for the licenee's use to incorporate these valves into the IST pre iram.
Each PGE basis for requesting specific relief from testing valves 2nd the EG&G evaluation of that request is sumarized (Section 2 through 9) below and grouped according to each specific system.
1.
General Considerations 1.1 Testing of Valves which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure boundary have design pressures below the reactor coolant system operating pressure.
Redundant isolation valves within the Class 1 boundary forming tne interf ace between these high-and low-pressure systems prevent the low-pressure systems from experiencing pressures which exceed their design limit.
In this role, the valves perform a pressure isolation function.
The NRC considers the redundant isolation provided by these valves to be imp or t an t.
The tRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and sys tem in tegr ity. For these reasons, EG&G and the tRC believe that some method, such as pressure monitoring, leak testing, radiography, or ultra-sonic testing, should be used to assure the condition of each valve is sdtisf actory in maintaining this pressure isolation function.
If lea < 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 A/C and leak tested according to IWV-3420 of Section XI of the applicable edition of the ASME Code.
These valves are:
i 8900A-D 8956A-D 8948A-D MO-8702 8949A-D M0-8701 8905A-D 8818A-D 8819A-D 8736A&B 88 15 4
The tRC and EG&G Idaho, Inc., have discussed this matter with the licensee and identified the valves listed above.
The licensee agreed to consider testing and categorizing each of these valves with the appropriate designation, depending on the testing method selected. Whatever method the licensee selects for determining the condition of each valve, the licensee will provide to the NRC for evaluation, the details of the testing method which clearly demonstrates the condition of each valve.
a 1.2 ASME Code,Section XI, Requirements Subsection IWV-3410(a) of the Section XI Code (which discusses full stroke and partial stroke testing) requires that Code Category A and B valves be exercised once every three months, with the exceptions as defined in IWV-3410(b-1), (e), and (f).
IWV-3520(a) requires that Code Category C valves te exercised once every three months, with the exceptions as defined in IWV-3520(b).
IWV-3700 requires no regular testing f or Code Category E valves.
Operational checks, with appropriate record entries, shall record the position of these valves before operations are performed and af ter 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 tasted 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 partial posit ion, during power operation 2.
It is not practical to observe the operation of the valves (with f all-safe actuators) upon loss of actuator power.
1.3 Stroke Test ing_of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full stroked.
If only limited operation is possible (and it has been demonstrated by the licensee and agreed to oy the N1C), the check valve shall be partial stroked.
Si nce disk position is rot 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 denonstration of the full stroke requirement.
Any flow rate less than design will be considered part stroke exercising unless it can belshown that the check valve's disk position at the lower flow rate would /oe equivalent to or greater than the design flow rate through the valye.
The licensee agreed to conduct flow tests to satisfy the above posit / ion.
/
1.4 Stroke Tel. ting of Motor-0perated Valves The licerl Section XI fc(/see has requested relief from the part stroke requirement of all power-operated valves.
The licensee has stated that none of the C;ategory A or B power-operated valves identified can be part stro<ed becayse of the design logic of the operating circuits.
These cir-cuits are sush that when an open or close signal is recieved, the valve i
Y 5
i
must conplete 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 Tne Code states that, in the case of cold shutdowns, valve testing need not be perf ormed more of ten than once every three months f or Cate-gory A and B valves and once every nine months for Category C valves.
It is the NRC's position that the Code is inconsistent and that Category C
/alves should be tested on the same schedule as Category A and B valves.
The licensee nas agreed to modify his procedures on cold shutdowns to read, "In the case of frequent cold shutdowis, valve testing need not be performed more of ten than once every three (3) months for Category A, B, and C valves."
1.6 Licensee Request for Relief to Test Valves at Cold Shutdowns The Code pennits valves to be tested at cold shutdowns, and the Code conditions under which this is permitted is noted in Appendix A.
These valves are specifically identified by the licensee and are full stroke exerc ised during cold shutdowns; tneref ore, the licensee is meeting the requirements of the ASME Code.
Since the licensee is meeting the require-ments of the ASME Code, it will not be necessary to grant relief; however, during our review of the licensee's IST program, we have verified that it was not practical to exercise tnese valves during power operation and that we agree with the licensee's basis.
It should be noted that the NRC dif-ferentiates, f or valve testing purposes, betwee the cold-shutdomi mode and the refueling mode.
That is, for testing purposes, the refueling mode is not considered as a cold shutdown.
1.7 Changes to the Technical Specifications In a November 1976 letter to the licensee, the NRC provided an attach-ment entitled, "tRC Guidelines f or 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 valvas in the remaining train should not be cycled if their f ailure in a non-sa're position would cause a loss of total system function.
For example, during power operation in some plants, tnere 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 requirenents within the time period specified in a plant's Technical Specifications (T.S.), the reactor is required to be put in some other mode. Furthennore, prior to initiating repairs, all valves and interlocks in the system that provide a duplicate function are i
required to be tested to demonstrate operability innediately and periodi-cally thereafter during power opration.
For some plants, this situation could be contrary to the NRC guideline as stated in the document mentioned auove.
It should be noted that a reduction in redundancy is not a basis f or a T.S. cnange nor is it by itself a basis f or relief from exercising in accordance with Section XI.
The licensee has agreed to review the plant's 6
~.
l l
T.S. and to consider the need to propose T.S. changes which would have the effect of precluding such testing. Af ter making this review, if the licen-see determines that the T.S. should be changed because the guidelines are i
applicable, the licensee will submit to the NRC, in conjuction with the proposed T.S. change, the inoperable condition for each system that is affected wnich demonstrates that the valve's failure would cause a loss of system function or if the licensee determines that the T.S. should not be thanged because the guidelines are not applicable or cannot be followed, tre licensee will submit the reasons that led to their determination for em.h potentially affected section of the T.S.
1.8 Safety-Related Valves l
This review was limited to safety-related valves.
Safety-related valves are defined as those valves that are needed to mitigate the conse-quences of an accident and/or to shut down the reactor and to maintain the 1
reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include some non-code class valves.
It should be noted that the licensee may have included non-safety-related valves in their IST program as a decision on the licensee's part to expand the scope of their program.
- 1. 9 Valve Testing at Cold Shutdowns i
Inservice valve testing at cold shutdowns is acceptable when the fol-losing conditions are met:
1.
It is understood that the licensee is to comence testing as soon as the cold-shutdown condition is 3
achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> af ter shutdown, and continue until complete or plant is ready to return to power 2.
Completion of all valve testing is not a prerequisite to return to power
]
3.
Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to meet the code-specified testing f requency.
t For planned cold shutdowns, wnere the licensee will complete all the j
valves identified in his IST program for testing in the cold-shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
1.10 Category A Valve Leak Check Requirements for Containment Isolation i,
Valves (CIVs) r l
All CIVs shall be classified as Category A valves.
The Category A valve-leak rate test requrements of IWV-3420(a-e) have been superseded by Appendix J requirements for CIVs.
The NRC has concluded that the applic-able leak-test procedures and requirements f or CIVs are determined by i
Relief from Paragraph IWV-3420(a-e) f or CIVs pre-sents no safety problem since the intent of IWV-3420(a-e) is met by Appen-dix J requirements.
The licensee shall comply with Sections f and g of IWV-3420 until re lief is requested from these paragraphs.
It should be noted that these paragraphs are only applicable where a Type C, Appendix J leak test is perf ormed.
Based on the considerations discussed above, the fRC concludes that tne alternate testing proposed above will give the reasonable assor-ance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and secur-ity 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 f rom the IST program review.
However, the determinations made by that review nas determined that the current IST program as submitted by the licensee correctly reflects the tRC's interpretation of Section XI vis-a-vis Appendix J.
The licensee has agreed that, should the Appendix J program be amended, tney will amend their IST program accordingly.
2.
Safety-Related Valves (Generic Reliefs) 2.1 Containment Isolation Valves 2.1.1 Relief Request.
The licensee has requested specific relief f rom leak testing all identified containment isolation valves in accordance with the requirements of Section XI and proposed to leak test the valves in accordance with tne criteria specified in Appendix J.
2.1.1.1 Code Requirements. Category A valves shall be l eak-te s ted.
Tests shall be conducted at the same (or greater) frequency as sched-uled 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:
1.
Any globe type valve may be tested with pressure under the seat.
2.
Butterfly valves may be tested in either direction, provided their seat construction is designed for sealing against pressure on either side.
3.
Gate valves with two-piece disks may be tested by pres-surizing them between the seats.
4.
All valves (except check valves) may be tested in either direction if the function differential pressure is 15 psi or less.
8
S.
Tne use of leakage tests involving pressure differen-tials lower than function pressure differentials are permitted in those types of valves in which service pressure will tend to diminish the overall leakage channel opening, as by pressing the disk into or onto the seat with greater force. Gate valves, check valves, and globe-type valves having f anction pressure differential applied over the seat, are examples of valve applications satisfying this requirement. When leakage tests are made in such cases, using pressures lower than function maximtsn pressure differential, the observed leakage shall be adjusted to function maximtrn pressure differential value by calculation appropriate to the test media and the ratio between test and func-tion pressure differential assuming leakage to be pro-portional 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 leaktested at full maximum function pressure differential, with adjustment by calculation if needed to compensate for a difference between service and test media.
Valve seat leakage may be determined by:
1.
Draining the line, closing the valve, bringing one side to test pressure, and measuring leakage through a down-stream telltale connection.
2.
Measuring feed rate required to maintain pressure between two valves, or between two seats of a gate valve, provided the total apparent. leak rate is charged to the valve or gate valve seat being tested, and that tne conditions required by IWV-3420(c) are satisfied.
The test medium shall be specified by the owner.
Leakage-rate measurements shall be compared with previous measurements and with the permissible leakage rates specified by the plant owner for a specific valve.
The values in Table IWV-3420-1 are permissible leakage I
rates and shall be used in evaluating inservice test results when leakage rates are not specified by the plant owner.
1.
Valves with leakage rates exceeding either the values specified by tne plant owner, or those rates shown in Table IWV-3420-1, as directed by IWV-3420(f), shall be replaced or repaired and retested to demonstrate satis-f actory operation before being returned to service.
l 2.
For valves 6 in. and larger, if a leakage rate exceeds l
the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate by 50% or more, the 9
test frequency shall be doubled and tests scheduled to coincide with a cold shutdown until corrective action is taken; at which time the original test frequency shall be restned. When tests show a leakage rate increasing with time, and a projection based on three or more tests indicates that the leakage rate of the next scheduled test will exceed the maximum permissible leakage rate by more than 10%, the valve shall be replaced or repaired and retested to demonstrate satis-f actory operation before being returned to service.
2.1.1.2 Licensee's Basis f or Requesting Relief. The containment isolation valves are tested for seat leakage under tne criteria of Appen-dix J to 10 CFR 50.
These valves are tested and analyzed for seat tight-ness in accordance with the Trojan Nuclear Plant " Containment Local Leak Rate Test." This procedure provides f ar local leak-rate testing of valves.
The acceptance criteria for allowable leakage rate under Appendix J to 10 CRF 50 varies from the acceptance criteria of Subsection IWV of ASME,Section XI, in that the allowed leakage is based on the total containment leakage rate rather than on individual valve seat leakage criteria. Th is test program provides adequate documentation and individual analysis for valves to verify maintenance of containment integrity. Failure of any valve to provide adequate seat tightness in maintaining containment integ-rity will require tne same corrective action for repair and replacement of tne valve.
Therefore, based on the Section XI requirements, this would only require duplication of documentation without any added benefit as f ar as testing or analyzing of test data for assurance of leakage integrity.
These valves are tested f or seat-leakage rate during local leakage-rate
~
testing in accordance with Appendix J to 10 CFR 50 and will not be tested under th is program.
2.1.1.3 Evaluation. We agree with the licensee's basis and, theref ore, f eel that relief should be granted from the Section XI leak-testing requirements for all containment isolation valves.
The licensee has demonstrated tnat leak-testing their containment isolation valves in accordance with the criteria specified in Appendix J to 10 CFR 50 should l
provide the data required for analyzing leakage integrity. We conclude l
that the acceptance criteria specified in Appendix J meets the intent of the Section XI leakage requirements and that this acceptance criteria should provide the required data necessary to analyze the integrity of the containment isolation valves associated with this plant.
l 2.2 Event V Configuration Valves l
2.2.1 Relief Request.
The licensee has requested specific relief from leak testing all pressure boundary valves identified in the Valve l
festing Program Evaluation, Paragraph 1.1, in accordance with the NRC requirements and proposed to only leak-test the valves identified below:
l Reactor Coolant 8948A through D 8949A through D l
l 10 l
.~~
Residual Heat Removal 8736A and B 8818A and B j
Safety Injection 8819A through D 8905A through D j
2.2.1.1 Code Requirement.
Refer to Valve Testing Program, i
Paragraph 1.1.
i 2.2.1.2 Licensee's Basis for Requesting Relief. These valves j
are designated from a configuration of inseries check valves which provide i
a boundary between a high-pressure system and a system with a design pres-j sure below that of the normal operating pressure of the high-pressure system.
j The present system at Trojan for testing inseries check valves is designed for testing the second inseries check valve at nonnal operating l
pressure only in the event that the first valve demonstrates leakage.
The WASH-1400 report does not consider added assurance of protection from l
periodic testing of the first valve.
The second valve will be leak-tested at reduced pressures at cold shutdown except for Check Valves 8905B and 89050, which will be tested with the inseries check valve to determine the combined leakage across the two valves.
2.2.1.3 Evaluation. We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the tRC's leak-testing requirements for all pressure boundary valves identified in Paragraph 1.1.
The licensee has not demonstrated that leak-testing the second in series check valve or two check valves together will provide the required data necessary to evaluate the actual condition of the high-pressure / low-pressure boundary isolation val /es. We conclude that the licensee should further investigate a manner to e :. ermine the condition of l
each valve identified in Paragraph 1.1. which is necessary to ensure the i
high-pressure / low-pressure system boundary isolation valves are performing their intended safety function (that is, to prevent an inter-system LOCA that could render the low-pressure safety system inoperable).
2.3 Valves Designated Category E I
2.3.1 Relief Request. The licensee has requested specific relief for all Category E valves identified in the IST program from the requirements i
of Section XI and proposed to use existing administrative procedures to i
control the position checks for Category E valves.
l 2.3.1.1 Code Requirement. Refer to Appendix A.
2.3.1.2 Licensee's Bas is f or Requesting Relief. The valves under this category are those which are normally locked open or locked l
closed to fulfill their function.
l l
i 11
! L r;
i
Under 10 CFR 50.55a(b)(2), the most recently approved addition of ASME,Section XI, is the 1977 with addenda through the sunner of 1978.
Category E was deleted from this edition. Valves at Trojan which are locked or sealed in position are covered by appropriate administrative procedures and documentation. The IST program would only duplicate existing requirements.
In an effort to prevent conflicting and confusing reports which would not provide any safety margin over the existing admin-istrative procedures, these valves have been listed for convenience, but will not be separately docunented under this program.
2.3.1.3 Evaluation. We agree with the licensee's basis and, theref ore, feel that relief should be granted from the Section XI require-ments for all Category E valves identified in the IST program.
The licen-see nas demonstrated that the existing administrative procedures and required documentation meets the requirements of Section XI for Category E valves. We conclude that using the existing procedures and required docu-mentation should ensure the proper alignment and positioning of valves designated Category 5 (the intent of Section XI). Also, we conclude that the Section XI requirements would only duplicate existing requirements and would not provide any additional meaningful infonnation about valve status.
2.4 Passive Valves The licensee has identified the below-listed valves as passive valves that are not required to change position to perform their safety function and will not be exercised.
EG&G has reviewed these valves and agrees with the licensee that they are passive valves in their safety-related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. We conclude that the operability of these valves is inconsequential with regard to the safety function which tney perform and that the Section XI quarterly stroke and stroke timing requirements are meaningless for passive valves.
Reactor Coolant 8079 i
8090A and 8 Chemical and Volume Control 8381 l
8180 8386A through D j
8369A through D l
Safety Inj ection 8808A througn D l
l l
l 12
h i
Spent Fuel Pn!
SF - s :
SF-052 and -e SF - 0 0 l
SF -0 7 i a
Make-co Vat.
Mn '
3-HCB-CK Containment Ventilation l
10610A and B l
10611A and B 3.
Reactor Coolant 3.1 Category A/C Valves 3.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C Valves 8948A through D, RCS.cqld leg injection header checks from tne SIS accumulators, SIS pumps, and the RHRS punps, in accordance with the requirenents of Section XI and proposad to partial stroke exercise these valves with RHRS flow during cold shutdown.
i 3.1.1.1 Code Requirenent. Refer to Appendix A.
3.1.1.2 Licensee's Basis for Requesting Relief. During power operation, the SIS accumulators, SIS pumps, or RHR5 punps cannot overcome RCS pressure.
l These valves will be partial stroke exercised for verification of operability during cold shutdown using RHRS flow.
3.1.1.3 Evaluation. We agree with the licensee's basis and, theref ore, f eel that tenporary relief should be granted for Category A/C Valves 8948A through D from the full stroke exercising requirements of i
Section XI.
Tne licensee has demonstrated that these valves cannot be l
exercised during power operation because the SIS accumulators, SIS punps, and the RHRS pumps cannot overcome RCS pressure. During cold shutdowns and refueling outages, design flow (SIS accumulator flow) cannot be accomp-Ilshed because the required accident conditions cannot be established. We conclude that, with the present plant design, the maximum available test flow through these valves is from the RHRS pumps which only provide partial j
Stroke exercising.
However, we also feel that the licensee should further Investigato sane alternate test method that will full stroke these valves.
13
3.1.2 Relief Request. The licensee has requested specific relief from exercising Category K/C Valves 8046 and 8047, PRT internal containment isolation checks, in accordance with the requirements of Section XI and proposed to verify valve closure (their safety-related position) during refueling outages.
3.1.2.1 Code Requirement. Refer to Appendix A.
3.1.2.2 Licensee's Basis for Requesting Relief. These valves cannot be verified closed during power operation because the test connec-tions are located inside the containment. The only available method to verify valve closure is during leak-rate testing during refueling outages.
These valves will be exercised for verification of operability during each refueling.
3.1.2.3 Evaluation. We agree with the licensee's basis and, theref ore, feel that relief should be granted f or Category A/C Valves 8046 and 8047 from the exercising requirements of Section XI.
The 1. ;ensee has demonstrated that, due to plant design, the only method available to verify valve closure (their 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 containment. We con-clude that the proposed alternate testing frequency of verifying valve closure during the performance of leak-rate testing at refueling outages snould demonstrate proper valve operability.
4.
Chemical and Voltrne Control 4.1 Category A/C and A Valves 4.1.1 Relief Request. The licensee has requested specific relief from exercising Category A/C Valve PSV-8117, PRT relief internal contain-ment isolation, in accordance with the requirements of Section XI and pro-posed to test this valve's relief setpoint in accordance with the schedule for testing safety and relief valves.
4.1.1.1 Code Requirement.
Refer to Appendix A and IWV-3512.
4.1.1.2 Licensee's Basis for Requesting Relief. This safety valve is inside the containment and is on the containment side of the iso-lation valves.
As such, it is labeled a containment barrier isolation valve with a specified leakage. An increase in pressure on the pressurizer relief tank side of the valve tends to seat the valve tighter; however, the design of the bellows is such that high pressure is directed to the inside of the bellows and testing with pressure external to the bellows could rasul t in damage to the relief-actuating mechan ism. Additionally, Para-graph IWV-3512 allows that safety and relief valves which are tested for their setpoint are not required to be additionally leak-tested.
This valve will be tested for its relief setpoint at refueling outages in accordance with the schec'ule for testing safety and relief valves.
14
4.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C relief Valve PSV-8117 from the exerc ising requirements of Section XI. The licen-see has demonstrated that the safety function of this valve is a contain-ment isolation barrier and an increase in PRT pressure will seat the valve tighter.
In addition, this valve is leak-tested in accordance with the Appendix J criteria and setpoint-tested in accordance with the requirements of Section XI. We conclude that Appendix J 1eak-testing and Section XI setpoint-testing of this valve during refueling outages should demonstrate proper valve operability.
4.1.2 Relief Request. The licensee has requested specific relief f rom exercising Category A Valves MD-8100 and M0-8112, RCP seal water return containment isolations, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during cold shutdowns that RCP; are secured and during refueling outages.
4.1.2.1 Code Requirement. Refer to Appendix A.
4.1.2.2 Licensee's Basis for Requesting Relief. Failure of either of these valves in a closed position would result in a loss of seal leakoff flow resulting in seal damage and loss of the RCP.
These valves will be full stroke exercised for verification of oper-ability during cold shutdowns when the RCPs are secured and during refueling outages.
4.1.2.3 Evaluation. We agree with the licensee's basis and, theref ore, f eel that relief should be granted f or Category A Valves Mj-G100 and M0-8112 from the exercising requirements of Ssction XI. The licensee has demonstrated that a failure of either of these valves in the closed position while RCPs are running would result in seal damage and loss of the RCP until repairs could be perf ormed. We conclude that exercising these valves during cold shutdowns that RCPs are secured and at least each refueling outage should demonstrate proper valve operability.
5.
Residual Heat Removal 5.1 Category C Valves 5.1.1 Relief Request.
The licensee has requested specific relief f rom exerc isi'ng Category C Valve 8958, RHR suction header to RWST backflow preventer check, in accordance with tne requirements of Section XI and proposed to full stroke exercise this valve during refueling outages.
5.1.1.1 Code Requirement. Refer to Appendix A.
S.1.1.2 Licensee's Bas is f or Requesting Relief.
Exercising this valve requires the RHR pumps drawing suction on tne RW5T. Operating modes do not allow this because there is no place to store the water unless ini-tiating large-scale RWST recirculation (opening Manual Valve 8735).
How-ever, this is not feasible due to the Rm system operating in a degraded condition. Cold-shutdown exercising is not feasible because the RHR is in 15
recirculation to the RCS.
The only feasible plant condition where this valve can be exercised is during refueling when the Rm system is utilized to fill the refueling cavity.
Valve 8958 will be full stroke exercised during refueling outages when the refueling cavity is filled.
5.1.1.3 Evaluation. We agree with the licensee's basis and, tneref ore, feel that relief should be granted f or Category C Valve 8958 from the exercising requirements of Section XI.
The licensee has demon-strated that this valve cannot be exercised during power operation because the only available test flowpath requires a manual valve line-up which diverts RmS flow from the loops, rendering the system inoperable. During cold shutdown, the RSS system is required to be recirculating RCS water, removing decay heat. We conclude that, with the present piping configura-tions, the only time this valve can be exercised is during refueling out-ages when the RMS system is used to fill the refueling cavity from the RWST. This alternate test frequency and full stroke exercising should demonstrate proper valve operability.
6.
Safety Injection 6.1 Category A/C Valves 6.1.1 Relief Request. The licensee has requested specific relief f rom exercising Category A/C Valve 8968, N2 to SIS accumulator inside containment isolation check, in accordance with the requirements of Sec-tion XI and proposed to verify valve closure (its safety-related position) during refueling outages.
6.1.1.1 Code Requirement. Refer to Appendix A.
6.1.1.2 Licensee's Basis f or Requesting Relief.
There are no provisions for verifying tne valve to be in the closed position during nonnal operation.
Tnis valve will be exercised and verified closed during leak-rate testing at refueling outages.
6.1.1.3 Evaluatlon. We agree with the 1icensee's basis and, tneref ore, feel that relief shculd be granted f or Category A/C Valve 8968 from the exercising requirements of Section XI.
Tne licensee has denon-strated that, due to plant desig1, the only method available to verify valve closure (its safety-related position) is during leak-testing.
This valve is not equipped with valve-p0sition indicators and some of the required test connections are locaced inside the containment. We conclude that tne proposed alternate testing frequency of verifying valve closure during the performance of leak-rate testing at refueling outages should demonstrate proper valve operability.
6.2 Category C Valves 6.2.1 Relief Request.
The licensee has requested specific mlief from exercising Category C Valves 8956A through D, SIS accumulator to RCS 16
injection neader checks, in accordance with the requirements of Section XI and proposed to partial stroke exercise these valves during cold shutdowns.
6.2.1.1 Code Requirement. Refer to Appendix A.
6.2.1.2 Licensee's Basis for Requesting Relief. During normal operation, the accumulator cannot overcome RCS pressure. Full stroke testing is not feasible due to limited plant conditions for testing.-
These valves will be partial stroke exercised during cold shutdown.
6.2.1.3 Evaluation. We agree with the licensee's basis and, theref ore, f eel that temporary relief should be granted f or Category C Valves 8956A through 0 from the exercising requirements of Section XI. The licensee has demonstrated that their valves cannot be exercised during power operation because the accumulator pressure cannot overcome RCS pres-sure. During cold shutdown, the installed test-line size limits exercising of tnese valves to a partial stroke.
During cold shutdowns and refueling outages, actual design accident conditions cannot be simulated and full stroke exercising is not possible. We conclude that, with the present plant design and piping configurations, only partial stroke exercising of these valves is possible. However, we also recommend that the licensee investigate alternate methods to full stroke exercise these valves at least each refueling outage.
7.
Containment Spray 7.1 Category C Valves 7.1.1 Relief Reque_st. The licensee has requested specific relief from exercising Category C Valves 10-HCB-CK (2), containment spray inside containment isolation checks, in accordance with the requirements of Sec-tion XI and proposed to partial stroke exercise these valves every five years.
7.1.1.1 Code Requirement. Refer to Appendix A.
7.1.1.2 Licensee's Bas is f or Requesting Relief. These valves do not have provisions for testing under normal conditions.
Exercising the valves would require injection of the test mediuin into the containment through the spray nozzles with no means available for verification of flow.
Equipnent damage and requirements for extensive cleanup of the containment would result.
These valves are partial stroke exercised during containment smoke testing at a maximum of five years under Technical Specification 4.6.2.1.
7.1.1.3 Evaluation. We agree with the licensee's basis and, theref ore, f eel that temporary relief should be granted f or Category C Check Valves 10-HCB-CK (2) from the full stroke exercising requirements of Section XI.
The licensee has demonstrated that exercising these valves by injecting water spray into the containment under any plant conditions would 17
result in extensive danage to electrical equipnent and other components inside the containment. We conclude that the smoke-test in accordance with plant Technical Specifications is a satisf actory partial stroke exercise test.
However, we recommend that the licensee further investigate alter-nate methods to allow a full stroke exercise test at least each refueling outage (that is, disassembly and manual exercising, etc.).
7.1.2 Relief Request.
The licensee has requested specific relief from exercising Category C Valves 14-HCB-CK (2), RWST to containment spray pump suction header checks, in accordance with the requirements of Sec-tion XI and proposed to partial stroke exercise these valves every three months.
7.1.2.1 Code Requirement. Refer to Appendix A.
7.1.2.2 Licensee's Bas is f or Requesting Relief. Full stroke exercising of these valves would require injection of the test medium into the containnent.
Equipnent danage and requirenents f or extensive cleanup of the containment would result.
These valves will be partial stroke exercised with flow through the containment spray pump miniflow lines every three months.
7.1.2.3 Evaluation. We agree with the licensee's basis and, theref ore, feel that tenporary relief should be granted f or Category C Valves 14-HCB-CK (2) from the full stroke exercising requirements of Sec-tion XI.
Tne licensee has denonstrated that the only full flow / full stroke exercising method requires injecting water spray into the containment, resulting in danage to electrical and other equipment inside the contain-ment. This test would also require an extensive containment cleanup and cannot be perf ormed under any plant conditions. We conclude that, with the present piping design and configuratioas, that only partial stroke exer-cising is possible through the pump recirculation line.
However, we recom-mend that the licensee further investigate alternate testing methods that will allow full stroke exercising of these valves at least each refueling outage.
8.
Main and Auxiliary Feedwater 8.1 Category C Valves 8.1.1 Relief Request. The licensee has requested specific relief f rom exercising Category C Valves 6-HBD-CK (2), auxiliary feed pump suction from service water checks, in accordance with the requirements of Section XI.
8.1.1.1 Code Requirement. Refer to Appendix A.
8.1.1.2 Licensee's Basis for Requesting Relief.
The only flow-path which will acconnodate full flow is into the steam generators.
Taking suction on the SWS would result in injecting contaminants into the steam generators and/or condensate storage tanks.
These valves will not be tes ted.
18
8.1.1.3 Evaluation. We agree with the licensee that, with the present plant design, the only available flowpath to exercise these valves is directly into the steam generators. We also agree that injecting ser-vice water into the steam generators or condensate storage tanks would result in severe contamination, chemical, and metalurgical problems that could result in permanent equipment damage. However, we feel that all safety-related valves must be exercised to ensure operability. Thus, we,
conclude that the licensee should further investigate some test method that would permit full stroke exercising of these valves without causing equip-ment danage (that is, plant modifications may be required).
9.
Other Systems 9.1 Category A/C Valves 9.1.1 Relief Request. The licensee has requested specific relief from exerc ising Category A/C Valve 1-GBB-CK, N2 to reactor coolant drain tank containment isolation check, in accordance with the requirements of Section XI and proposed to verify valve closure (its safe.ty-related post-tion) during refueling outages.
9.1.1.1 r de Requirement. Refer to Appendix A.
o 9.1.1.2
' icensee's Bas is f or Requesting Relief.
This valve can only be verified it the closed position during leak-rate testing at refueling outages.
This valve will be exercised for operability at each refueling outage.
9.1.1.3 Evaluation. We agrde with the licensee's basis and, therefore, feel that relief should be granted for Category C Valve 1-GBB-CK from the exercising requirements of Section XI.
The licensee has demon-strated that, due to plant design, the only method available to verify valve closure (its safety-related position) is during leak-testing.
This valve is not equipped with valve-position indicators and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak-rate testing at refueling outages should demonstrate proper valve operability.
9.1.2 Relief Request. The licensee has requested specific relief from exercising Category A/C Valves 2-HBE-CK (2), instrument air contain-men t isolation checks, in accordance with the requirements of Section XI and proposed to verify valve closure (their safety-related position) during refueling outages.
9.1.2.1 Code Requirement. Refer to Appendix A.
9.1.2.2 Licensee's Basis for Requesting Relief.
Failure of either of these valves in a closed position removes the air supply to the containment air-operated valves and pneumatic instrumentation. 2-HBE-CK can only be verified closed during leak-testing at refueling outages.
19
These valves will be full stroke exercised for verification of oper-ability during leak-rate testing at refueling outages.
9.1.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A/C Valves 2-HBE-CK (2) from the exercising requirements of Section XI.
The licensee has demonstrated that, due to plant design, the only method avail-able to verify valve Closure (their safety-related position) is during leak-testing. These valves are not equipped with valve-position indicators and some of the required test connections are located inside the contain-e ment. We conclude that the proposed alternate testing frequency of veri-fying valve closure during the perfonnance of leak-rate testing at refueling outages should demonstrate valve operability.
9.1.3 Relief Request. The licensee has requested specific relief from exercisiiig Category A Valve CV-4471, instrument air outside contain-ment isolation, in accordance with the requirements of Section XI and pro-posed to full stroke exercise this valve during refueling outages.
9.1.3.1 Code Requirement. Refer to Appendix A.
9.1.3.2 Licensee's Basis for Requesting Relief. Failure of this valve in a closed position removes the air supply to the containment air-operated valves and pneumatic instrumentation.
This valve will be full stroke exercised for verification of oper-ability during leak-rate testing at refueling outages.
9.1.3.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief skuld be granted for Category A Valve CV-4471 from the exercising requirements of Section XI.
The licensee has demon-strated that an air supply to the air-operated valves and pneumatic instru-
- a.. ation is required f or safe plant operation in all modes except certain phases of refueling outages. We conclude that the proposed alternate testing f requency of full stroke exercising this valve during refueling outages should demonstrate proper valve operability.
20
[
IV. APPENDIX A Code Requirement--Valves Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code (which discussed full stroke and partial stroke requirements) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3410(b)(1), (e), and (f).
IWV-3520(a)(which discusses full stroke and partial stroke requirements) requires that Code l
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 post-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 fallsafe actuators) upon loss of actuator power.
Subsection IWV-3410(c) requires all Category A and B power-operated i
valves to be stroke-time tested to the nearest second or 10% of the maximum allowable owner-specified time.
Code Requirements--Pumps An inservice test snall be conducted on all safety-related pups, nminally once each month during normal plant operation.
Each inservice test shall include the measurement, observation, and recording of all quan-titles in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.
l i
l l
21 L___.___________.__.__._.._________,_...-__..
V.
ATTACHMENT I Tne 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-fled by the owner and are full stroke exercised during cold shutdowns and refueling outages.
EG&G has reviewed all valves in this attachment and agrees with the licensee that testing these valves during power operation is not possible, due to the valve type and location, system design, or because this action would place the plant in an unsafe condition. We feel that tnese valves should not be exercised during power operation.
These valves are listed below and grouped according to the system in which they are located.
1.
Reactor Coolant 1.1 Category A/C Valves Category A/C Valves 8949A through D. RCS hot leg injection checks, cannot be exercised during power operation. During power operation, the SIS and RMS pumps cannot overcome RCS pressure.
These valves will be full urcke exercised for verification of operability during cold shutdowns.
1.2 Category C Valves Category C Valves 8900A through D, boron injection to RCS cold leg checks, cannot be exercised during power operation.
Exercising these valves during power operation would require the injection of concentrated uoric acid into the RCS causing a power transient that could result in a reactor trip. These valves will be full stroke exercised for verification of operability during cold shutdown.
2.
Chemical and Volume Control 2.1 Category B Valves Category B Valves M0-8105 and M0-8106 (these valves close to re-direct charging ptsnp discharge to the BIT) cannot be exercised during power oper-ation. Failure of either of these valves in a closed position would result in loss of pressurizer level control that could result in a reactor shut-down.
These valves will be full stroke exercised for verification of oper-ability during cold shutdown.
2.2 Category C Valves Category C Valves 8481A and B, charging pump discharge checks, cannot be full stroke exercised during power operation.
The charging flowpath cannot acconinodate full flow except through the BIT which would require injection of concentrated boric acid into the RCS causing a power transient that could result in a reactor trip. These valves will be partial stroke exercised at power every three months and full stroke exercised at cold shutdowns.
22
2.3 Category C Valve Category C Valve 8546, VCT to RWST reverse flow preventor check, can-not be exercised during power operation.
Exercising of this valve would require injection of concentrated boric acid from the RWST into the RCS, causing a power transient which could result in a reactor trip. This valve a
will be full stroke exercised for verification of operability during cold s hu tdowns.
3.
Residual Heat Removal 3.1 Category A/C Valves Category A/C Valves 8736A and B, RHRS hot leg injection header checks, cannot be exercised during power operation. During normal operation, the RHRS pumps cannot overcome RCS pressure. These valves will be full stroke exercised for verification of operability during cold shutdowns.
3.2 Category A/C Valves Category A/C Valves 8818A through D, RHRS cold leg injection header cr r ss, cannot be exercised ouring power operation.
Exercising of these valves would require reducing RCS pressure to an unacceptable level for nomal operation because the RHRS pumps cannot overcome RCS operating pres-suse. These valves will be exercised for verification of operability during cold shutdowns.
3.3 Category B Valve _ss Category B Valves M0-8701 and M0-8702, RCS to RHRS pump suction isola-tions, cannot be exercised during power operation.
Exercising of these valves during normal operation would require overriding of a safety inter-lock when RCS pressure is greater than 425 psig. The potential for over-pressurization of the Rms and depressurization of the RCS makes testing of these valves at normal RCS pressure unsafe. These valves will be exercised for verification OT operability during cold shutdowns.
3.4 Category B Vgl,v_e Category B Valve 110 0703, RHRS to RCS hot leg isolation, cannot be exercised during power operation. Failure of this valve in the open posi-tion would redirect low-head safety-injection flow from the safety-injection flowpath, thus rendering the system inoperable. This valve will be full stroke exercised for verification of operability during cold shutdowns.
3.5 Category B Valves Category B Valves M0-8804A and B, RHR pump discharge to safety injec-tion and charging pump suction isolations, cannot be exercised during power operation. Failure of these valves in the open position would result in redirection of the safety-analysis flow required for accident mitigation.
These valves will be full stroke exercised during cold shutdowns.
23
3.6 Category B Valve Category B Valve M0-8812, RIRS ptsnp suction from the RWST, cannot be exercised closed during power operation. Failure of this valve in the closed position would render the entire RHRS sy' stem inoperable.
This valve will be full stroke exercised for verification of operability during cold shutdowns.
3.7 Category C Valves Category C Valves 8730A and B, RHRS pumps discharge checks, cannot be full stroke exercised during power operation. During power operation, the RHR pressure cannot overcome RCS pressure, thus, the only flowpath which can accormiodate full flow is on recirculation to the RWST.
This flowpath is unacceptable because it would require repositioning of the RWST Return Isolation Valve 8735 (nonnally locked closed), which would render the RHRS injection system inoperable.
Valves 8730A and B will be full stroke exer-c ised during cold shutdown.
4.
Safety Injection 4.1 Category B Valves Category B Valves M0-8808A through D, SIS accumulator isolations, cannot be exerc ised during power operation.
These valves are categorized as B passive in that, under normal condittoris, they are open and remain open in perfonnance of their safety function. The valves have been included in the IST program for testing due to their critical location in a safety-related system and the imposed administrative requirements which require plant shutdown for f ailure of one of these valves in a closed position.
These valves will be exercised f or verification of operability during cold shutdowns.
4.2 Category B Valves Category B Valves M0-8806, SIS pump suction from the RWST isolation, and MO-8835, SIS to RCS cold leg injection isolation, cannot be exercised during power operation.
Failure of either valve in the closed position would render SIS inoperable.
These valves will be full stroke exercised for verification of operability during cold snutdowns.
4.3 Category B Valves Category B Valves M0-8814 and M0-8813, SIS pump minimum flow series isolations, cannot be exercised during power operation. Failure of either valve in a closed position would render the SIS ptsnps inoperable.
A mini-mum flow rate through the pumps is required to ensure pump cooling.
The miniflow flowpath guarantees this minimum flow during the safety injection i n i t i a t i on.
These valves will be full stroke exercised for verification of operability during cold shutdowns.
24
4.4 Category A/C Valves.
Category A/C Valves 8819A through D, SIS to RCS cold leg injection header checks, cannot be exercised during power operation.
Exercising of these valves would require injection of concentrated beric acid into the RCS that could result in a reactor trip. During power operation, the SIS
. pumps cannot overcome RCS pressure.
These-valves will be full stroke exer-cised for verification of operability during cold shutdowns.
4.5 Category C Valve 1
Categcry C Valve 8815, BIT to RCS cold leg injection header check, f
cannot be etercised during power operation.
Exercising of this valve would require injection of concentrated boric acid into the RCS causing a power transient that could result in a reactor trip. This valve will be full stroke exercised for verification of operability during cold shutdowns.
4.6 Category C Valves Category C Valves 8905A through D, SIS to RCS hot leg injection checks, cannot be exercised during power operation.
Exercising of these 4
valves would require injection of concentrated boric acid into the RCS causing a power transient that could result in a reactor trip. During power operation, the SIS pumps cannot overcome RCS pressure. These valves will be full stroke exercised for verification of operability during cold shu tdowns.
4.7 Category C Valves Category C Valves 8922A and B, SIS pumps discharge checks, and 8926, SIS pump suction check from the RWST, cannot be exercised during power
,i operation. The SIS pumps cannot overcome RCS pressure during power oper-l ation and, as a result, full flow cannot be acconmodated. These valves will be partial stroke exercised during power operation and full stroke exercised for verification of operabi ?ity during cold shutdowns.
5.
Main Steam 5.1 Category B/C Valves Category B/C Valves CV-2216, -2236, -2256, and -2276, main steam iso-lations, cannot be exercised during power operation.
Closing one of these-valves during operation would result in three-loop operation, thereby causing abnonnal RCS flow. This results in unnecessary distortion of the reactor flux, causing a decrease in the design thermal safety margins.
i Failure of a valve in the closed position would remove its respective steam generator from operation.
These valves will be exercised for verification of operability during cold shutdowns.
i 25
6.
Main and Auxiliary Feedwater 6.1 Category C Valves Category C Valves 2-CCC-CK, 3-DBE-CK, 3-EBE-CK (four each), and 6-DBD-CK two each), auxiliary feed to main feed checks, cannot be exercised during power operation without thennal shocking of the feed system nozzles, resul ting in feed nozzle damage. These valves will be full stroke exer-cised during cold shutdowns.
6.2 Category C Valves Category C Valves 6-HBD-CK (2), condensate storage tank to auxiliary feed pump suction checks, cannot be full stroke exercised during power operation.
The only flowpath which will accommodate full flow is into the steam generators. Feeding the steam generators during power operation would result in thennal shocking of the feed system nozzles, resulting in nozzle damage.
These valves will be partial stroke exercised every three months on recirculation and full stroke exercised at cold shutdowns.
6.3 Category C Valves Category C Valves 14-EBE-CK (4), main feed header checks, cannot be exerc ised during power operation.
Closing any of these valves during power operation would secure feed to the respective steam generator causing the associated MSIV to close, and resulting in a reactor trip. These valves will be full stroke exercised during cold shutdowns.
7.
Component Cooling 7.1 C a teg ory B Val ve_s_
Category B Valves M0-3290, -3291, -3292, -3294, -3296, -3300 -3320,
-3346, RCP component cooling supply and return isolations, cannot ' e exer-o cised during power operation.
Failure of one of these valves in the closed position would result in loss of cooling water to the reactor coolant pumps, resulting in pump damage and a reactor shutdown. These valves will be exercised for verification of operability at cold shutdowns.
7.2 Category B Valves Category B Valves M0-3295 and M0-3319, letdown and seal water exchange cooling water isolation, cannot be exercised during power operation. Fail-ure of either of these valves in the closed position would result in loss of cooling water to the RCS letdown and the RCS pump seal water heat exchangers requiring reactor shutdown.
These valves will be exercised for verification of operability during cold shutdowns.
26
-8.
Other Systems 8.1 Category A Valves Category A Valves CV-10001, M0-10002, M0-10003, and CV-10004, main containnent purge _ isolations, cannot be exercised' during power operation.
PGE has committed to maintaining these valves in the closed position during Modes 1, 2, 3, and 4 in response to an NRC concern over containment purging during normal operation. These valves will be full stroke exercised during cold shutdowns.
8.2 Category A Valves Category A Valves M0-10005 through M0-10012, H2 <ent system contain-ment isolations, should not be full stroke exercised during power opera-tion. PGE has committed to limiting the opening of these valves to 500 to ensure closure under the most severe design flow conditions. These valves will be partial stroke exercised every three months and full stroke exercised during cold shutdowns.
a 9
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i l
VI.
ATTACHMENT II
)
1 The drawings listed below were used during the course of this review.
'I
__ Drawing Number System Reactor Coolant M-201 f~
Chemical and Volume Control M-202, -203 -204 Residual Heat Removal M-205 l
Safety Injection M-206 1
Containment Spray M-207 Main Steam M-208 M-213 Condensate and Feed Auxiliary Steam M-214 Component Cooling Water M-215 Circulating Water M-216 Service Water M-218 Clean Radioactive Waste M-220 Dirty Radioactive Waste M-221 Radioactive Gaseous Waste M-222 Instrunent and Service Air M-223 Diesel Fuel Oil M-226 4
Spent Fuel Pool Cooling M-227 Make-Up Water M-228 Process Sampling M-231, Sheets 1 and 3 o
Air Flow Containment Building M-243 Chilled Water M-248 l
Steam Generator,31owdown M-348 l
i 28 l
VII.
ATTACHMENT III 1.
The following valves are never full stroke exercised or have a testing f requency greater than each refueling outage.
a.
Valve Testing Program 1.
3.1.1
^
2.
6.2.1 3.
7.1.1 4.
7.1.2 5.
8.1.1.
2.
The following relief requests have insufficient tech-nical basis, and relief is not recomnended.
a.
2.2.1 G
29
I VIII.
ATTACHMENT IV Tne following valves were identified by-EG&G Idaho, Inc., during the IST working meeting and should be reviewed by the IRC Appendix J review comnittee to determine if they should be categorized A, A/C,'or A/ti, and o
leak-tested in accordance with the requirements of Appendix J.
The licensee has agreed to reevaluate testing these valves in accord-g.
ance with the requirements of Section XI and Appendix J upon the completion of the NRC Appendix J review. These valves were-included in the licensee's submittal for administrative documentation only. However, these valves are categorized and tested as indicated.
No te:
The licensee has identified the valves as Category _.
P
- passive valve E
- valve is exercised NE - valve is not exercised LT - valve is leak-tested NLT - valve is not leak-tested.
Reactor Coolant 8079 (A/C)
P NE NLT Chemical and Volume Control M0-8105 and -8106 (B)
E NLT PSV-8117 (A/C)
E NLT 8381 (A/C)
P NE NLT 8368A through D (A/C)
P NE NLT 8369A through D (A)
P NE NLT Residual Heat Removal M0-8700A and B (B)
E NLT M0-8701, -8702, and -8703 (B)
E NLT PSV-8708 (C)
E NLT i
M0-8809A and B (B)
E NLT CV-8825 (A)
NE NLT 30
... ~
~
i CV-8890A and B (A) i NE NLT 8958 (C)
.E NLT l
Safety Injection i
M0-8801A and B (B)
E NLT M0-8802A and B (B)
E NLT 8815 (C)
E NLT 8819A through D (A/C)
E LT 4
CV-8823 and -8824 (A)
NE NLT l
M0-8835 (B)
E NLT CV-8843 (A)
NE NLT CV-8881 (A)
NE-NLT 8925 (A/E)
NE NLT 8905A through D (C)
E LT Containment Spray M0-2053A and B (B)
E NLT 10-HCB-CK (2)
(C)
E(partial)
NLT 4
Component Cooling Water M0-3290, -3291, and -3292 (B)
E NLT f
M0-3346 (C)
E NLT 4
s l
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31
. ~.. - -, _.
-. -.. -...