ML20008E863
| ML20008E863 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/31/1981 |
| 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-5117, EGG-EA-5117-R1, NUDOCS 8103100106 | |
| Download: ML20008E863 (60) | |
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M EGG-EA-5117 Revision 1 January 1981 SAFETY EVALUATION REPORT, INSERVICE TESTING PROGRAM, ZION UNITS 1 AND 2 - DOCKET NOS. 50-295 AND 50-304 e
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3.,g This is an informal report intended for use as a preliminary or working document Prepared for the U.S. Nuclear Regulatory Commission g
Under DOE Contract No. DE-AC07-76ID01570 E G g G ldaho FIN No. A6258 YD 8103100/O(O
Il p EGcG,,,,,-
FORM EG&G 396 (Hov 11799 INTERIM REPORT Accession No.
Report No. EGG-EA-5117 Revision 1 Contract Program or Project
Title:
Systems Engineering Support Subject of this Document:
Safety Evaluation of the Inservice Testing Program for Pumps and Valves at Zion Units 1 and 2 (Docket Nos. 50-295 and 50-304) for the Period 1-17-78 through 9-16-79 Type of Document:
Safety Evaluation Report Author (s):
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NRC Researc1 anc ecanica
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Assistance Report Date of oocum-nt:
January 1981 Responsible NRC Individual and NRC Office 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 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
Under DOE Contract No. DE-AC07 761D01570 NRC FIN No. A6258 INTERIM REPORT
TABLE OF CONTENTS Page I.
Introduction.......................
1 II.
Pump Testing Program...................
2 III. Valve Testing Program 9
IV. Attachment I......
52 V.
Attachment II 53 VI.
Attachment III......................
56 VII. Attachment IV 57 I
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I.
Introduction T
Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Commonwealth i
Edison Company (CECO) 5-27-78 for its Zion Units 1 & 2 nuclear plants. The program applies to Zion Units 1 & 2 for the period l
1-17-78 through 9-16-79.
The working session with Zion Units 1
& 2 and CECO representatives was conducted on 12-13-78 and r
12-14-78. The licensee re-submittal was issued on 9-11-80 and was reviewed by EG&G Idaho Inc., to verify compliance of proposed b
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, i
Commonwea th Edisen Company has_ also requested relief from the f
ASME Code from testing specified pumps and valves because of-f practical reasons. These requests have been evaluated individually to determine whether they have significant risk i
implications and whether the tests, as required, are indeed impractical.
i The evaluation of the pump testing program and relief requests l
for pumps is contained in Section II below; the evaluation of the
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vaive testing program and associated relief requests is contained in Section III. All evaluations for Sections II and l
III are the recommendations of EG&G Idaho, Inc.
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Appendix J exemption requests for category A valves currently l
being reviewed by the NRC are centained in Attachment I.
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i Category A, B, and C valves that meet the requirements of the j
ASME Code Section XI and are not exercised every 3 months are contained in Attachment II.
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A listing of P&lD's used for this review are contained in Attachment III.
Valves that are never full stroke exercised or that have a testing interval greatcr than each refueling outage and relief requests witn insufficient technical basis where relief is not r econnended are summarized in Attachment IV.
II. Pump Testing The IST program submitted by Conmonwealth Edison Company was examined to verify that all Class 1, 2, and 3 safety related pumps were included in the program and that those -) umps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that all 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 Conmonwealth Edison Company request for relief from testing pumps, the code requirement for testing, the basis for requesting relief, and the EG&G evaluation of that request is summarized below and grouped according to the system in which the purrps reside.
A.
Service Water (SW-001, SW-002, SW-003)
Auxiliary Feedwater (FW-005, FW-006)
Containment Spray (CS-001, CS-002, CS-003)
Volume Cnntrol (VC-006,VC-007) l Residual Heat Removal (RH-001, RH-002) l Component Cooling (CC-003, CC-004, CC-005, CC-006, CC-007)
Safety Injection (SI-003, SI-004)
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1.
Relief-Request The licensee has requested specific relief from the requirements of Section XI Table IWP-3100-2 for the method of testing and allowable ranges for pump vibration measurements for all safety related pumps listed above.
Code Requirement An inservice test shall be conducted on all safety related pumps, nominally once each month during normal plant operation. Each inservice test shall include the measurement, observation, and recording of all quantitites in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year. The allowable ranges of inservice test quantities, in relation to the reference values, are tabulated in Teble IWP-3100-2.
In the event these ranges cannot be met, the owner shall specify in the pump record the reduced range limits to allow the pump to fullfill its function, and those limits shall be used in lieu of the ranges given in Table IWP-3100-2 for the monthly pump test.
Licensee's 3 asis-for-Requesting Ralief The component as designed and installed does not have instrumentation for the monitoring of vibration amplitudes of the rotating shaft as required by IWP-4510.
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Portable vibration sensing equipment is available to monitor vibration parameters. The normal maintenance routine is to monitor vibration velocity in inches per second. This allows a more accurate determination of abnormal vibration at frequencies other than the shaft rotational speed. The " General Machinery Vibration Severity Chart" published by IRD Mechanalysis, Inc.
will be used as a guideline. The " alert range will be 0.314 in/sec < V < 0.628 la/sec.
The required action range will be V 10.628 in/sec. The test frequency will be as specified in IWP-3000.
Evaluation The proposed alternate method of measuring pump
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vibration with the portable vibration monitoring equipment currently available at the plant site meets the intent of the code.
Since the units of measure of inches /second is different than that specified by the code (mils-peak-to-peak), a chart indicating the alert i
action and required action ranges is provided in the i
IST program. We feel relief should be grantea from the l
ASME Code specified method of measurement and feel the licensee's alternate test method meets the intent of the code and provides the information needed for analysis of pump degradation.
B.
Service Water (SW) Pumps (SW-001, SW-002, SW-003) 1.
Relief Request l
The licensee has requested specific relief from the Section XI requirement to measure service water pumps inlet pressure (P ) and flowrate (Q).
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Code Requirement j
i An inservice test shall be conducted on all safety I
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related pumps, nominally once each month during normal t
plant operation. Each inservice test shall include the
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measurement, observation, and recording of all f
j quantities in Table IWP-3100-1, except bearing temperatura, which shall be measured during at least one inservice test each year.
I Licensee's Basis for Requesting Relief l
j The service water pumps are vertical design with no
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means of direct inlet pressure measurement as required
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by IWP-4200.
Inlet pressure to these pumps will be f
established by reference to the level of lake water I
above the pump suction. Due to the demands of dependent systems, thE individual testing of service f
water pumps as required by IWP-3400(a) would jeopardize f
l safe plant operation. The plant design does not l
1 incorporate any flow measurement instrumentation.
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Technical Specification 3.8.7 B & C requires all three l
service water pumps to be operable.. If one of the three pumps is found inoperable, reactor operation is j
permissible for the seven succeeding days.
In addition I
the service water systems are crosstied between the two j
units as described in the FSAR. Correct performance of these pumps can only be assessed on their continued ability to perform the function for which they were f
installed.
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Evaluation We agree with the licensee's basis, and therefore feel relief should be granted from the Section XI requirements to measure P for the ser/ ice water 9
pumps SW-001, SW-002, and SW-003.
The talculation of the static pressure at the pump suction by measuring the lake level is an adequate alternate to actually measuring the pressure. However, si7ce the service water pumps are located in a variable resistance system, the code requires the measurement or calculation of both differential pressure and flow rate. We feel the utility has not fully investigated the alternate tests for determining the hydraulic performance of these pumps. The tests they are performing only evaluate the mechanical condition of these pumps. Therefore, we feel relief should not be granted unless an alternate test can be performed that will evaluate the hydraulic characteristics of these pumps.
C.
Component Cooling (CC) Pumps (CC-003, CC-004, CC-005, CC-006,CC-007) 1.
Relief Request The licensee has requested specific relief f.om the Section XI requirement to measure inlet pressure (P ), differential pressure (dP), and flowrate (Q),
j for component cooling pumps CC-003 through CC-007.
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Code Requirement i
An inservice test shall be conducted on all safety related pumps, nominally once each month during normal plant operation. Each inservice test shall include the t
measurement, observation, and recording of all i
quantities in Table IWP-3100-1, except bearing f
temperature, which shall be measured during at least one inservice test each year.
Licensee's Basis for Requesting Relief i
Due to the demands of dependent systems, the individual testing of component cooling pumps as required by i
IWP-3400(a) would jeopardize safe plant operation.
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Technical Specification 3.8.6 A & B requires a minimum i
of 3 component cooling pumps operable with one reactor f
critical. Of the 5 component cooling pumps, one can be i
inoperable without any effect on the system. Technical I
l Specification 3.8.6C requires some action if 2 pumps f
I are inoperable only with two reactors critical. One reactor may operate indefinitely in this condition.
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4 The design heat load is such that two pumps are f
required to operate during normal plant operation and j
three pumps are required with one unit at full load and i
the other shut down (para. 9.3.2 of the FSAR). There is no plant operating condition when a single pump f
could be run to determine performance parameters as i
j required by IWP-3400(a).
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i These pumps are visually checked at least once every 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift by the equipment attendant as part of a
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required routine.
Instrumentation is installed which j
will permit the recording of the inlet pressure at each
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pump. However, pressure measurement on the pump discharge can only be monitored at the common discharge header. The plant design does not incorporate any flow measurement instrumentation. Correct performance of these pumps can only be assessed on their continued ability to perform the function for which they were installed.
Evaluation Section XI of the ASME Code specifically identifies the parameters to be measured which describe the mechanical condition and the hydraulic condition of the pumps being tested. The licensee is not measuring any of the parameters which describe the hydraulic condition of these pumps. Therefore, we feel relief should not be granted from measuring Pi, dP, and Q for the service water pumps. We feel the licensee has not fully investigated the alternate testing methods available for evaluating tha hydraulic condition of these pumps.
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i III. Valve Testing Program i
The IST program submitted by Coninonwealth Edison Company was j
examined to verify that Class 1, 2, and 3 safety related valves l
were included in the program and that those valves are subjected 3
I to the periodic tests required by the ASME Code,Section XI, and t
the NRC positions and guidelines. Our review found that Class 1, i
2, and 3 safety related valves were included in the IST program I
and, except for those valves identified below for which specific l
l relief from testing has been requested, the valve tests and i'
frequency of testing cornly with the code requirements and the l
NRC positions and guidelines listed in General Section A.
Also l
j included in the General Section A is the NRC position and valve listings for the leak testing of valves that perform a pressure
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isolation function and a procedure for the licensee's use to incorporate these valves into the IST program.
Each Commonwealth t
j Edison Company request for relief from testing valves, the code j
requirement for testing, Commonwealth Edison Company's basis for
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2 requesting relief, and the EG&G evaluation of that request is l
summarized (B through K) below and grouped according to each j
j specific system.
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A.
General l
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1.
Leak-Testing of Valves which Perform-Pressure Isolation
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l-Function
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There are several safety systems connected to the j
reactor coolant pressure boundary that have design
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pressures that are below the reactor coolant system l
operating pressure. There are redundant isolation f
valves forming the interface between these high and low
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pressure systems to prevent the low pressure systems j
from being subjected to a pressure which exceeds their f
design limits.
In this role the valves are performing
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a pressure isolation function.
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It is the NRC's view that the redundant isolation provided by these valves regarding their pressure isolation function is important. The staff considers it necessary to provide assurance that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For thk reason we believe that some method, such as leak testing, should be used to ensure the condition of each valve is satisf actory to maintain this pressure isolation function.
In the event that leak testing is selected as the appropriate procedure for achieving this objective, we believe that the following valves should be categorized as A or AC and leak tested in accordance with IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are:
RH-8701 and RH-8702 (RHR take-off from loop A hot leg) 4 RH-8736A and RH-8949A (RHR to loop A hot leg inlet check valves) i RH-8'16B and RH-89498 (RHR to loop D hot leg inlet check valves)
SI-9001A through D (low head SIC check valves to loop cold legs)
SI-9002A through D (low head SIS check valves to loop cold legs)
SI-8948A through D (accumulator discharge check valves l
to loop cold legs) l SI-8956A through D (accumulator discharge check valves)
SI-8900A through D (BIT supply check valves to loop cold legs)
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SI-9032 (BIT discharge chet valve to loop cold legs) l SI-9012A through D (SIS check valves to loop cold legs) l SI-8905A and B (SIS check valves to loop hot legs) f i
SI-9004C and D (SIS check valves to loop hot legs)
SI-8957A and B (RHR return check valves to loop cold j
i legs) j i
SI-9011A and B (SIS MOV's discharge to loop hot legs)
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SI-8801A and B (BIT M0V's discharge te loop cold legs) l i
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The NRC has discussed this matter and ioentified the valves listed above to the licensee. The licensee has agreed to consider leak testing each of these valves in j
accordance with IWV-3420 of the applicable edition of
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i the ASME Code and to categorize these valves with the appropriate designa.lon.
If the licensee determines l
l that leak testing is not necessary because there are
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t other methods that the licensee has and will use to l
j determine each valve's condition, the licensee shall provide to the NRC for evaluation on a valve-by-valve f
basis the details of the method used that clearly demonstrates the condition of each valve.
I 2.
ASME Code Section XI Requirements Subsection IWV-3410(a) of the Section XI Code (which j
discusses full stroke and partial stroke) requires that l
Code Category A and B valves be exercised once every l
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 i
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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:
d.
It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during-power operation, b.
It is not practical to observe the operation of the valves (with fail-safe actuators) upon loss of actuator power.
The staff 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 poss'ble (and it has been demonstrated by the licensee and agreed to by the staff), the check valve shall be partial stroked. Since disk position is not always observable, the f;RC staff stated that verification 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 tne valve. The licensee agreed to conduct his flow tests to satisfy the above position, 12
The licensee has stated that none of the Category A or B power operated valves can be part-stroked because of the design logic of the operating circuits. These cicuits 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 dircction. 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.
3.
Cold Shutdown a.
Inservice valve testing at cold shutdown is defined as: Valve testing should commence 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 Gould be performed during the subsequent cold shutdowns to meet the code required testing frequency. We find the licensee's proposed cold r,hutdown condition testing acceptable.
b.
The Code states that, in the case of cold shutdowns, valve testing need not be performed mcre often than once every 3 months for Category A and B valves and once every 9 months for Category C valves.
It is the NRC's position that the code is inconsistent and that Categoy C valves should be tested on the same schedule as Category A and B valves. The licensee has agreed to modify any procedures as necessary on cold 13
shutdown, 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."
4.
Changes to-the Technical Specifications In a November 1976 letter to the Commonwealth Edison Company the NRC staff provided an attachment entitled "NRC Staff 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 in the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not be cycled since their f ailure would cause a loss of total system function. For example, during power operation in some plants, there are stated minimum requirements for systems which make up the ECCS which allow certain limiting conditions for cperation 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, the reactor is required to be put in some other mode. Furthermore, prior to initiating repairs, all valves and interlocks in the system that provide a duplicate function are required to be tested to demonstrate operability immediately and periodically thereafter during power operation.
For such plants this situation would be contrary to the NRC guideline as stated in the document mentioned above.
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Safety lelated Valves This review was limited to those Class 1, 2, and 3 valves of Section XI of the ASME Code that are safety related. Safety related valves are defined as those that are needed to mitigate the consequences of an accident and/or shut down the reactor and to maintain the reactor in a shutdown condition.
It should be noted that the licensee may have included nonsafety related valves in their Inservice Test Program as a decision on the licensee's part to expand the scope of their Inservice Test Program.
B.
Safety-Injection System-(SI) 1.
Category-B Valves a.
Relief-Request Specific re'ief is requested from the requirements of Section XI IWV-3300 for valves SI-8811 A and B, containment sump isolation valves.
Code Requirement "IWV-3300 Check of valve position indicators" states that all valves with remote position indicators, which during plant operation are inaccessible for direct observation, shall be visua ly observed at the same (or greater) 15
frequency as scheduled refueling outages but not less than one observation overy 2 years, to confirm that remote valve indications accurately reflect valve operation.
Licensee's-Basis-for Requesting Rellef l
These valves are located in a closed valve containment assembly which is designed as an l
extension of the containment boundary.
These valves can be made accessable during plant shutdown by disassembly of the valve containment assembly. This requires approximately t
100 man-hours per valve in a radiation field up to 50 mr per hour. Verification that the valve position indicat'on switches havr. : hanged in relation to valve position can be niade by observing that no significant change in valve
- iroke time has occurred.
Due to the burden in manpower and radiation exposure to perform the direct observation, relief is taken from the requirements of IWV-3300.
Evaluation We agree with the licensee's basis of keeping the exposure of workers to radiation fields to a
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minimum, however, we feel the licensee has not I
adequately justified never performing this test for the life of the plant. Therefore we feel relief should not be granted from the requirements j
of Section XI for verification of these valve l
position indicators properly identifying correct valve position.
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Category C Valves a.
Relief Request The licensee has requested specific relief from full stroke exercising the following Category C check valves in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.
SI-8922A and B safety injection pump discharge checks SI-9004C and D safety injection to hot legs checks SI-8949C and D safety injection to hot legs checks SI-8905A and B safety injection to hot legs checks SI-9012A, B, C, and D safety injection to cold legs checks Code-Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting-Relief These check valves cannot be tested during unit operation as the shutoff head of the pumps is lower than reactor coolant system pressure. Full stroke testing of all the branch run check valves will be demonstrated by total pump discharge flow during cold shutdown providing the reacter vessel head is removed. Performance of this test with the rcactor coolant system depressurized but intact could lead to an inadvertant overpressurization of the system. The alternative 17
A method of protecting against overpre%urization by partial draining of the reactor coolant system to provide a surge volume is not considered a safe practice due to concerns of maintaining adequate water level above the reactor core.
Evaluation The licensee has demonstrated that quarterly exercising these valves cannot be accomplished since the shutoff head of these pumps is less than RCS pressure, therefore we feel relief should be granted from the exercising requirements of Section XI for valves SI-8922A and B, SI-9004C and D, SI-8949C and D, SI-8905A and B, and SI-9012A, B, C and D with an alternate test frequency of full stroke exercising each refueling outage. The large volume of water required to full flow / full stroke exercise these check valves would cause thermal shocking of injection nozzles during power operation and could result in an overpressurization of the RCS during cold shutdowns.
b.
Relief Request Specific relief is requested from quarterly and cold shutdown exercising check valves SI-9032, boron injection tank discharge to loop cold legs l
l and SI-890%, B, C, and D, boron injection tank supply to loop cold legs. An alternate test frequency of full stroke exercising each refueling outage is proposed.
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Code-Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief 1-l These check valves cannot be tested during unit j
operation as the injection of cold, highly borated l
water would result in a change in reactor core reactivity and undue thermal cycling of the f
injection nozzles. Full stroke exercising of all i
the branch run check valves will be demonstrated by total pump discharge flow during cold shutdown providing the reactor vessel head is removed.
Performance of this test with the reactor coolant system intact could lead to an inadvertant overpressurization of the system. The alternative j'
method of protecting against overpressurization by
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partial draining of the reactor coolant system to
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provide a surge volume is not considered a safe i
j practice due to concerns of maintaining adequate water level above the reactor core.
Evaluation The licensee has demonstrated that exercising these check valves during power operation would require injecting cold bcrated water frorr. the Boron Injection Tank (BIT) into the loop cold legs. This would cause rapid power transients in addition to thermal shocking the injection nozzles. During cold shutdown full stroke exercising these check valves would require running a charging pump into the RCS and this i
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l could result in a low temperature overpressurization of the RCS. Therefore, we feel relief should be granted from quarterly and cold shutdown exercising these check valves and the alternate test frequency of full stroke exercising SI-9032 and SI-8900A, B, C and D during each refueling outage is a sufficient alternate test to demonstrate valve operability, y
c.
Relief Request Specific relief is requested from full stroke exercising Category C check valves SI-l 248A, B, C, and D, accumulator discharge to loops and SI-8956A, B, C, and D accumulator outlet check valves. An alternate test of partial stroke exercising during cold shutdowns is proposed.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for-Requesting Relief The accumulator check valves cannot be tested during unit operation due to the pressure differential between the.ccumulators ( 600 psig) and the reactor coolant system (2235 psig). These valves cannot be full stroke tested except by a rapid depressurization of the reactor coolant system as would occur during the design basis cold leg double guillotine break. These valves will be partial stroke tested during cold shutdown.
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l Evaltation i
The licensee has demonstrated that these valves cannot be exercised during power operation since the accumulator pressure is l', sufficient to overcome the Reactor Coolant System pressure.
During cold shutdown these valves can be partial stroke exercised but attempting to full stroke the valves could cause a low temperature overpressurization of the RCS since the axpansion volume available is not sufficient to accomodate the large quantity of water discharged from the accumulators. Therefore we feel relief should be granted from the quarterly exercising requirements of Section XI for these valves. The alternate test of partial stroke exercising these valves during cold shutdowns and refueling outages is sufficient to demonstrate proper valve operability.
d.
Relief Request Specific relief is requested from quarterly full stroke exercising SI-8926, SI pump suction check from RWST. An alternate test of partial stroke exercising quarterly and full stroke exercising during refueling outages is proposed, i
Code Requirement Ref6' to valve testing paragraph A.2.
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Licensee's Basis for Requesting Relief This check valve cannot be full stroke tested during unit operrtion as the shutoff head of the pumps are lower than reactor coolant system pressure. Partial stroke exercising of thi; check valve will be demonstrated by establishing proper pump discharge flow during periodic pump testing.
Full stroke exercising of this check valve will be demonstrated during cold shutdown providing the reactor vessel head is removed. Performance of this test with the reactor coolant system intact could lead to an inadvertant overpressurization of the system. The alternative method of protecting against overpressurization by partial draining of the reactm coolant system to provide a surge volume is not considered a safe practice due to concerns of maintaining adequate water level above the reactor core.
Evaluation The licensee has demonstrated that full stroke exercising this. valve cannot be accomplished during power operation since the SI pumps cannot achieve full flow through the pump recirculation line and the pumps do not develop enough head to discharge into the RCS. During cold shutdowns an l
overpressurization of the RCS could occur if the l
SI pumps were to discharge into the RCS, We feel relief should be granted from the Section XI requirements to full stroke exercise this valve 22
and feel the alternate test of partial stroke exercising quarterly and full stroke exercising during cold shutdowns with the reactor vessel head removed and during refueling outages is sufficient to demonstrate proper valve operability.
e.
Relief Request Specific relief is requested from Section XI requirements for exercising the following check valves:
SI-8957A and B RHR return to loop cold legs SI-9001A, B, C and D low head SIS to loop cold legs SI-9002A, B, C and D low head SIS to loop cold legs.
Code-Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief These check valves cannot be tested during unit operation as the shutoff head of the pumps is lower than reactor coolant system pressure. Full stroke exercising of all the branch run check valves can only be demonstrated by total pump discharge during cold shutdown providing the reactor vessel head is removed. This condition is required to establish suction from the RWST and 23
provide system flow conditions similc-to design injection flow.
Performance of this testing with the reactor coolant system depressurized but intact would not provide adequate surge volume for influx from the RWST to allow the RHR injection system to reach these design flows. The alternative method of providing a surge volume by partial draining of the reactor coolant system is not considered a safe practice due to concerns of maintaining adequate water level above the reactor Core.
Evaluation The licensee has shown that exercising these valves during power operation cannot be accomplished since the low head safety injection pumps do not develop sufficient discharge pressure i
to overcome the RCS pressure holding these check valves shut. However, we feel the licensee has the ability to perform a flow test on these check valves during cold shutdowns. While utilizing the RHR Systcm for shutdown cooling these valves will be at least partial stroke exercised and a full stroke might be accomplished depending on the maximum flow obtainable during shutdown cooling as compared to design accident flow. Therefore, we feel relief should not be granted from the exercising requirements for these valves until the utility denonstrates f hat the testing is indeed impractical.
i 24 I
f.
Relief Request Specific relief is requested from exercising requirements of Section XI for valve SI-8958, RHR j
pump suction check from RWST.
Code Requirement Refer to valve testing paragraph A.2.
?
Licensee's Basis for Requesting Relief i
These check valves cannot be tested during unit operation as the shutoff head of the pumps is lower than reactor coolant system pressure.
Full stroke exercising of all the branch run check valves can only be demonstrated by total pump discharge during cold shutdown providing the reactor vessel head is removed.
This condition is required to establish suction from the RWST and provide system flow conditions similar to design injection flow.
Performance of this testing with the reactor coolant system depressurized but intact would not provide adequate surge volume for influx from thr RWST to allow thr RHR injection system to reach these design flows. The alternative method of providing a surge volume by partial draining of the reactor coolant system is l
not considered a safe practice due to concerns of
[
maintaining adequate water level above the reactor j
core.
i e
b 25
i Evaluation We agree with the licensee's basis and therefore
[
feel relief should be granted from the
[
r requirements of Section XI for valve SI-8958. The l
licensee has demonstrated that exercising this I
valve requires injecting RWST water into the RCS and the RHR pumps cannot overcome RCS pressure i
t during power operation.
During cold shutdown the RHR pumps are aligned to the RCS for residual heat removal and cannot be aligned to the RWST. We r
feel the licensee's proposed test of full stroke j
exercising this valve during cold shutdown when i
the reactor head is removed and during refueling l
outages will adequately demonstrate proper valve operability.
l C.
Chemical and Volume Control System (VC)
' [
1.
Category A Valves
[
I a.
Relief Request Specific relief is requested from quarterly exercising the following valves and an alternate i
test of full stroke exercising during cold shutdown when the reactor coolant pumps are not running is proposed.
r l
VC-8372A, B, C, and D seal water supply to reactor I
coolant pumps i
l VC-8369A, B, C, and D seal water supply to reactor l
coolant pumps l'
26 l
_ _ = _
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis-for Requesting Relief These manually operated valves in the reactor coolant pump seal injection lines remain in a normally open condition during unit operation.
Manually operated needle valves are adjusted to regulate seal injection flow to maintain correct pressure differentials at the pump seals.
The seal injection system remains in operation following any postulated accident contributing to the safety injection flow to the reactor coolant systen while maintaining and protecting the pump seals.
Should it be required during a protracted accident these valves may be closed and provided with isolation valve seal water. These valves will be manually stroke tested each cold shutdown providing all reactor coolant pumps are not in operation. This testing period will be each refueling outage as a minimum. Relief is taken from measuring stroke time on manual valves.
Evaluation We agree with the licensee's basis and feel relief should be granted from the quarterly exercising requirements of Section XI for valves VC-8369A, B, C and D and VC-8372A, B, C, and D.
The alternate exercising frequency of each cold shutdown that 27
. -. =_
the reactor coolant pumps are not in operation is sufficient to demonstrate operability of these manual isolation valves. We also feel relief should be granted from measuring stroke time on these manual valves since this measurement would be meaningless.
b.
Relief Request Specific relief is requested from exercising manual valves VC-8480A and B, charging supply to loop fill header.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief These manual valves are maintained passively closed during unit operation and are not required to function, other than to provide containment isolation, to safely shutdown the reactor or
[
mitigate the consequences of an accident.
l Exception is taken to the performance of f
exercising tests as required by IWV-3410.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for valves VC-8480A and 8.
These valves are in their safety related 1
28
position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. The operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
c.
Relief Request Specific relief is requested from the exercising requirements of Section XI for valve VC-8100, RCP seal water return line isolation.
Code Requirement t
Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief This motor operated vaive in the reactor coolant pump seal injection return line must remain in a normally open condition during unit operation in order to maintain proper pump seal flow. This valve will be stroke tested each cold shutdown providing all reactor coolant pumps are not in operation. This testing period will be each refueling outage as a maximum.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for valve VC-8100.
29
Exercising this valve during power operation or cold shutdown with the RCP's running could result in RCP seal damage or failure and would require plant shutdown for repairs. We feel the licensee's proposed alternate test of full stroke exercising and stroke timing this valve during cold shutdowns when all RCP's are not rdnning and during refueling outages will adequately
)
dem:nstrate proper valve operability.
2.
Category C Valves i
I a.
Relief Request l
Specific relief is requested from the exercising j
requirements of Section XI for valves VC-8481 A and B, charging pump discharge check valves.
l Code Requirement Refer to valve testing paragraph A.2.
Qcensee's Basis for Requesting Relief Full stroke exercising of the charging pump discharge check valves cannot be demonstrated during unit operation as the reactor coolant system pressure prevents the pumps from reaching full injection flow conditions.
Partial stroke exercising of these check valves will be demonstrated by establishing proper pump discharge flow during periodic pump testing. Full stroke exercising of this check valve will be 1
30 l
f i
demonstrated during cold shutdown providing the reactor vessel head is removed.
Performance of l
this test with the reactor coolant system intact j
could lead to an inadvertant overpressurization of l
the system. The alternative method of protecting
{
against overpressurization by partial-draining of j
the reactor coolant system to provide a surge volume is not considered a safe pracatice due to
[
concerns of maintaining adequate water level above
[
the reactor core.
i l
Evaluation We agree with the licensee's basis and therefore f
feel relief should be granted from the exercising f
requirements of Section XI for valves VC-8481 A and B.
The licensee has demonstrated that full
[
stroke exercising these check valves during power operation cannot be accomplished since the charging pumps cannot develop the full injection f
flowrate while pumping into the RCS at operating l
pressure. During cold shutdowns full flow / full i
stroke exercising these check valves cannot be t
accomplished since a low temperature overpressurizatic:. W she RCS could occur. We f
feel the licere c'r all?rnate test of partial
[
stroke exerc di +
- crterly and full stroke f
exercising during rt@eling outages will f
demonstrate proper valve operability.
b.
Relief Request j
i Specific relief is requested from the exercising
{
requirements of Section XI for valve VC-8546, charging pump suction check from the RWST.
l t
i.
31
[
i s
_..., ~
Code-Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief Full stroke exercising of the charging pump suction check valve cannot be demonstrated during unit operation as the reactor coolant system pressure prevents the pumps from reaching full injection flow conditions. Partial stroke exercising of this check valve will be demonstrated by verifying charging flow is maintained when the charging pump suction path is transferred from the Volume Control Tank to the Refueling Water Storage Tank during the quarterly valve exercise test. Full stroke exercising of this check valve will be domonstrated during cold shutdown providing the reactor vessel head is removed. Performance of this test with the reactor coolant system intact could lead to an inadvertant overpressurization of the system. The alternative method of protecting against overpressurization by partial draining of the reactor coolant system to provide a surge volume is not considered a safe pracatice due to concerns of maintaining adequate water level above the reactor core.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising requirements of Section XI for valve VC-8546. The i
32
L licensee has demonstrated that full stroke exercising this check valve cannot be performed during power operation since the charging pumps cannot achieve full flow with the RCS pressurized to operating pressure.
Full stroke exercising this valve during cold shutdowns could result in a low temperature overpressurization of the RCS since an adequate expansion volume in the RCS to accomodate the finw required for full stroke exercising this valve does not exist. We feel the licensee's alternate test of partial stroke exercising this valve quarterly and full stroke exercising during refueling outages adequately demonstrates proper valve operability.
D.
Containment Spray System (CS) 1.
Category A Valves a.
Relief Request Specific relief is requested from the leak testing requirements of Section XI for the following containment isolation valves:
CS-0002 CS-0040 CS-0004 CS-0041 CS.0006 CS-0042 CS-0037 CS-0043 CS-0038 CS-0044 CS-0039 CS-0045 33
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis-for Requesting Relief These valves will be leak tested in accordance with 10 CFR 50, Appendix J.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the leak testing requirements of Section XI for these valves. We feel the leak testing requirements of Appendix J meets the intent of Section XI and the licensee's present piping configurations and testing procedures are established for the Appendix J type of testing.
l 2.
Category C-Valves a.
Relief-Request Specific relief is requested from the exercising requirements of Section XI for valves CS-0016, CS-0021 and CS-0026, spray additive check valves.
An alternate test frequency of full stroke exercising one valve each year is proposed.
Code -Requirement Refer to valve testing paragraph A.2.
34
1 i -
Licensee's Basis for-Requesting-Relief i
Check valves in the spray additive system cannot
{
be exercised without introducing Na0H contaminants into the spray system. Operability of these three i
valves will be verified at a frequency of one valve each year. Operability will be verified by i
4 either disassembly of the valve to check for free i
j movement of the moving parts or by a special full flow flushing procedure.
i Evaluation I
i The licensee has shown that with the current
[
piping configuration exercising these check valves by utilizing flow through them would introduce the i
highly corrosive spray additive (NaOH) into the f
main piping of the containment spray system and l
the refueling water storage tank. This action I
would require extensive clean-up operations and l
generate considerable low level contaminated waste i
?
t water to flush these systems free of the j
corrosive. However, the licensee has not shown
[
why each of these valves cannot be either f
i disassembled or checked for full stroke exercising i
with a full flow flush each refueling outage.
j F
4 Therefore, we recommend relief not be granted j
unless more information can be provided by the licensee to demonstrate this impracticality.
E.
Residual-Heat Removal System.(RH) 1.
Category-C-Valves
)
l 35 i
e
a.
Relief Request Specific relief.is requested from the quarterly exercising requirements of Section XI for check valves RH-8730A and B, RHR pumps discharge check valves.
l Code Requirement Refer to valve testing paragraph A.2.
Licensee's-Basis for Requesting-Relief These check valves cannot be full stroke tested during unit operation as the shut off head of the pumps is lower than reactor coolant system i
pressure. Partial stroke exercising of these check valves will be demonstrated by establishing proper pump discharge flow during periodic pump testing. Full stroke exercising of this check valve can only be demonstrated during cold shutdown providing the reactor vessel head is removed. This condition is required to establish suction from the RWST and provide system flow conditions similar to design injection flow.
Performance of this testing with the reactor coolant system depressurized but intact would not provide adequate surge volume for influx from the RWST to allow the RHR injection system to reach these design flows. The alternative method of providing a surge volume by partial draining of the reactor coolant system is not considered a safe practice due to concerns of maintaining adequate water level above the reactor core.
36
Evaluation The licensee has shown that full stroke exercising these check valves during power operation can not be accomplished since the only full flow flowpath is into the RCS and the low head safety injection 1
pumps are not capable of developing enough discharge head to pump into the RCS. These valves will be partial stroke exercised quaiterly via the pump recirculation line. However, we feel the licensee has the ability to perform a full flow test on these check valves during cold shutdowns.
While utilizing the RHR System for shutdown cooling these valves will be at least partial stroke exercised and a full stroke might be
~
accomplished depending on the maximum flow obtainable during shutdown cooling as compared to design accident flow. Therefore we feel relief should not be granted from the exercising requirements for these valves until the utility demonstrates that the testing is indeed impractical, b.
Relief Request Specific relief is requested from the Section XI requirements for exercising the following check valves:
RH-8736A and B, low head SIS to hot legs RH-8949A and B, low head SIS to hot legs Code Requirement Refer to valve testing paragraph A.2.
37
Licensee's Basis for Requesting Relief These check valves cannot be tested during unit operation as the shutoff head of the pumps is lower than reactor coolant system pressure. Full stroke exercising of all the branch run check valves can only be demonstrated by total pump discharge during cold shutdown providing the reactor vessel head is removed. This condition is l
required to establish suction from the RWST and provide system flow conditions similar to design injection flow. Performance of this testing with the reactor coolant system depressurized but intact would not provide adequate surge volume for influx from the RWST to allow the RHR injection system to reach these design flows. The alternative method of providing a surge volume by partial draining of the reactor coolant system is not considered a safe practice due to concerns of maintaining adequate water level above the reactor Core.
Evaluation The licensee has shown that exercising these valves during power operation cannot be accomplished since the low head safety injection pumps do not develop sufficient discharge pressure to overcome the RCS pressure holding these check valves shut. However, we feel the licensee has the ability to perform a flow test on these check valves during cold shutdowns. While utilizing the RHR System for shutdown cooling these valves will be at least partial stroke exercised and a full stroke might be accomplished depending on the 38
maximum flow obtainable during shutdown cooling as j
compared to design accident flow. Therefore we feel relief should not be granted from the exercising requirements for these valves until the utility demonstrates that the testing is indeed i.
impractical.
F.
Component Cooling System-(CC) 1.
Category A and B Valves a.
Relief-Request Specific relief is requested from quarterly exercising the following valves and an alternate test of full stroke exercising during cold r
shutdowns when the RCPs are not running and f
refueling outages is proposed.
CC-9413A and B component cooling to RC pump coolers CC-9414 component cooling return from RC pump coolers CC-9438 component cooling from RC pr.inp coolers CC-685 component cooling from RC pump coolers Code Requirement Refer to valve testing paragraph A.2.
1 Licensee's Basis for Requesting-Relief l'
Component cooling water flow to the reactor coclant pumps is required at all times the pumps are in operation. Failure of one of these valves in a closed position during exercise test would i
39 i
I
-.. ~..
result in a loss of the cooling flow to the pumps.
Exemption is taken to the quarterly exercise test. The valves will be exercise tested during cold shutdown providing all reactor coolant pumps are not in operation. This t, sting period will be each refueling outage as a maximum.
Evaluation The licensee has demonstrated that exercising these valves when the RCPs are running would result in damage to the Reactor Coolant Pumps which would require plant shutdown. Therefore we feel relief should be granted from exercising component cooling valves CC-9413A and B, CC-9414, CC-9438 and CC-685 with the alternate test of full stroke exercising these valves during cold shutdowns when the reactor coolant pumps are not running and refueling outages is satisfactory to ensure these valves perform their intended safety function.
G.
Demineralized Water System-(DW) 1.
Category A-Valves a.
Relief Request Specific relief is requested from exercising Category A valves DW-0030 and DW-0038, demineralized flushing water to containment.
40
1 e
Code Requirenent i
Refer tu valve testing paragraph A.2.
j Licensee's Basis for Requesting-Relief l
t These manual valves are maintained passively
(
[
closed during unit operation and are not required to-function, other than to provide containment isolation, to safely shut down the reactor or mitigate the consequences of an accident.
4 Exception is taken to the performance of exercising tests as required by IWV-3410.
Eval uat' in We agree with the licensee's basis and therefore t
feel relief should be granted from the exercising requirements of Section XI for valves DW-0030 and 1
l DW-0038. These valves are in their safety related f
position and are not required to open or close to
(
t mitigate the consequences of an accident or safely i
shutdown the plant. The operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
l f
i H.
Containment Air Sampling System-(PR) 1.
Category A Valves 5
i t
6 h
t 8
41 1
?
e~
>+
W
-w wy us rn?r,p
-pgsy-+ny+
e m
~ - -
-qm-op s
ew,,
-e e
a.
Relief Request Specific relief is requested from exercising the following Category A valves:
PR-0007 PR-0008 PR-0009 PR-0011 PR-0012 PR-0013 Manual isolation valves F5-0015 containment air sampling PR-0016 system.
PR-0017 PR-0019 PR-0020 PR-0021 Code Requirement Refer to valve testing paragraph A.2.
Li:ensee's-Basis for Requesting Relief These valves function as containment isolation valves. These manual valves are maintained passively closed during unit operation and are not required to function, other than to provide containment isolation, to safely shut down the reactor or mitigate the consequences of an accident.
Exception is taken to the performance l
of exercising tests as required by IWV-3410.
l I
42
. ~. -..
1 i'
Evaluation We agree with the licensee's basis and therefore f
feel relief should be granted from the exercising i
and stroke timing requirements of Section XI for the following manual valves:
PR-0007 PR-0008 l
PR-0009 PR-0011 PR-0012 PR-0013 PR-0015 PR-0016 PR-0017 PR-0019 PR-0020 4
PR-0021 These valves are in their safety related position I
l and are not required to open or close to mitigate t
the consequences of an accident or safely shut
]
down the plant. The operability of these valves is inconsequential with regard to the safety i
function which they perform. We conclude that the f
quarterly stroke and stroke time measurer.ents are meaningless for passive valves.
I' I.
Category B Valves l
)
l.
I j
43
a.-
Relief Request Specific relief is requested from the stroke timing requirements of Section XI for valves FW-0016, FW-0017, FW-0018 and FW-0019, feedwater isolation valves.
Code Requirement Refer to valve testing pecagraph A.2.
Licensee's Basis for-Requesting Relief Stroke timing of these valvac can only be performed during cold shutdown whertaver the feedwate and condensate systems are not in operatic.
ed during refueling outages. These valves are exercised each cold shutdown but cannot be stroke timed since the valves are controlled automatically and an operator may not be available to stroke time them when they close.
In cold shutdown the steam generators are placed in the
" wet layup" conditions with the secondary side essentially filled with feedwater. Stroke testing in this condition with the feedwater or condensate systems in operation would introduce an overfill of the steam generators filling the main steam j
piping with feedwater. The potential of l
overpressurizing the secondary side of the steam generators would then exist. This testing period will be e_ h refueling outage as a maximum.
O l
l 44 l
_ -.~.., -., -, _.. _.,
... ~,...-.,,,.,-~,--.-- -
1--
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the stroke time measurement requirements of Section XI for the feedwater isolation valves FW-0016, FW-0017, FW-0018 and FW-0019. We feel the licensee's present system control configuration prevents practical ope ator t' ming of these valves and the stroke timing for determination of valve degradation can adequately be accomplished with the licensee's proposed frequency of cold i
shutdowns (providing the feedwater and condensate systems are not o arating) and refueling outages.
r J.
Spent Fuel Cooling System (SF) 1.
Category A Valves f
a.
Relief Request L
Specific relief is requested from the exerciting requirements of Section XI for passive Category A valves SF-0010, SF-0011, SF-8767 and SF-8787, spent fuel cooling containment isolation valves.
Code Requirement Refer to valve testing paragraph A.2.
W 45
Licensee's Basis for Requesting Relief These manual valves are maintained passively closed during unit operation and are not required to function, other than provide containment isolation, to safely shutdown the reactor or mitigate the consequences of an accident. Exception is taken to the performance of exercising tests as required by IWV-3410.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted from the exercising and stroke timing requirements of Section XI for manual valves SF-0010, SF-00ll, SF-8767 and SF-8787.
These valves are in their safety related position and are not required to change position to mitigate the consequences of an accident or safely shut down the plant. The operability of these valves is inconsequential with regard to the safety function they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
K.
Containment Isolation Valves 1.
Category A Valves a.
Relief Request Specific relief is requested from the leak testing requirements of Section XI for the following list of containment isolation valves, i
l l
46
Liquid Waste Disposal System WD-17A WD-17B Reactor Coolant System RC-8025 RC-8026 RC-8028 RC-8029 Chemical and Volume Control System VC-8152 VC-8153 VC-8369A, B, C&D VC-8372A, B, C&D VC-8100 VC-8105 VC-8106 VC-8480A&B Spent Fuel Cooling System SF-0010 SF-0011 SF-8767 SF-8787 Demineralized Water System DW-0030 DW-0038 47
Containment Air Monitoring System VF-01A&B VN-01A&B PR-0007 PR-0008 PR-0009 PR-0011 PR-0012 PR-0013 PR-0015 PR-0016 PR-0017 PR-0019 PR-0020 PR-0021 PR-19A&B PR-20A&B PR-21A&B PR-22A&B PR-23A&B PR-24A&B Service Air System SA-01A&B Primary Sample System SS-9354A&B SS-9355A&B i
l SS-9356A&B SS-9357A&B 48
Heating System RV-111 RV-112 RV-113 RV-114 Waste Drain System t
DT-9159A&B DT-9160A&B DT-9170 DT-LCV1003 Containment Purge System l
RV-0005 RV-0006 Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief These valves function as containment isolation valves. Relief is requested from performing seat leakage testing required by IWV-3420. As an alternative these valves are tested in accordance with 10 CFR 50 Appendix J as required by Tech.
Spec. 4.10.
Additionally these valves are supplied by an isolation valve seal water system, which is functionally tested as part of this t
49 1
l
program and Tech. Spec. 4.9.1.
These alternative tests will adequately ensure that the containment isolation valves perform their intended function as described in the FSAR.
Evaluation We agree with the licensee's basis aad therefore feel relief should be granted from the leak testing requirements of Section XI. We feel the licensee's present method of verification that these valves perform as containment leak limiting barriers is acceptable and meets the intent of Section XI.
L.
Isolation Valve Seal Water System 1.
Category C Valves a.
Relief Request Specific relief is requested from the exercising requirements of the following check valves in the Isolation Valve Seal Water System.
IW-0001 IW-0181 IW-0062 IW-0003 IW-0182 IW-0063 IW-0073 IW-0183 IW-0064 IW-0074 IW-0184 IW-0065 IW-0075 IW-0185 IW-0066 IW-0076 IW-0198 IW-0067 IW-0077 IW-0058 IW-0068 IW-0078 IW-0059 IW-0069
~
l 50
b i
1 i
i t
t IW-0079 IW-0060 IW-0070 j
IW-0080 IW-0061 IW-0072 l
IW-0081 IW-0160 I
4 IW-0082 IW-0162 r
t IW-0003 IW-0090 l
IW-0084 IW-0095 j
IW-0186 i
Code Requirement Refer to valve testing paragraph A.2.
f i
i Licensee's Basis for Requesting Relief f
These IVSW check valves can only be tested by 1
observing flow through downstream tell-tale drain I
or by disassembly of the valve to verify pre,qr
[
i disk freedom of movement. This testing would render the system unable to perform its safety i
function. These valves will be tested at a I
refueling outage frequency as an alternative to isolation valve seat leakage testing.
l l
Evaluation f
F We agree with the licensee's basis and therefore f
feel relief shou M oe granted from the exercising f
requirements of Section XI for these isolation i
valve seal water system check valves. We feel l
that since tFis system is utilized as an alternate
..j to leak testing the applicable containment i
isolation valves and leak testing is performed at refueling outages and testing of this system l
renders many other systems inoperable, exercising i
these valves at a refueling outage frequency would j
adequately demonstrate proper system operability.
t 51 j
i i
f
VI. Attachment I During the course of our review of the Zion Units 1 and 2 IST program we found no valves that need further review by the NRC for compliance with the requirements of 10 CFR 50, Appendix J.
0 0
52
V.
Attachment II The following are Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not full stroke exercised every three months during plant operation. These valves are specifically identified by the owner and are full stroke exercised during cold shutdowns and refueling outages.
EG&G has reviewed all valves in this attachment and agrees with the licensee that testing these valves during power operation is not possible due to the valve type and location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be exercised during power operation.
These valves are listed below and grouped according to the system in which they are located.
A.
Residual Heat Removal System (RH) 1.
RH-8701 and RH-8702, RHR suction from loop A hot leg, cannot be exercised during power operation due to valve
~
interlocks that keep these valves shut when the primary system is at operating pressure. These valves will be full stroke exercised during cold shutdown and refueling outages.
B.
Main Steam System (MS) 1.
MS-0001 MS-0002 Main steam stop valves.
MS-0003 MS-0004 G
53
I These valves cannot be full stroke exercised during power operation since a turbine trip and subsequent reactor trip woi!!d result. These valves are part j
stroke exerc ed during cold shutdowns and refueling outages.
C.
Main Feedwater System (FW) l l
1.
FW-0016 FW-0017 Main feedwater stop valves.
FW-0018 l
FW-0019 These valves cannot be exercised during power operation since a turbine trip and subsequent reactor trip would result. These valves are full stroke exercised during cold shutdowns and refueling outages.
t D.
Instrument Air System (IA)
~
1.
FCV-IA1A and FCV-IAIB, Instrument air to valves in containment, cannot be exercised during plant operation since this would isolate valve control air to air operated valves in containment.
Loss of control air could cause some safety related valves to go to their j
fail position and subsequently result in a reactor trip. These valves will be full stroke exercised during cold shutdowns and refueling outages.
E.
Containment Air Monitorinq 1.
PR0030, containment air particulate and gas monitoring sample return line isolation valve, cannot be exercised during power operation since this would render this sample system inoperable and unable to perform its function.
This valve will be full stroke exercised during cold shutdowns and refueling outages.
54
F.
Isolation Valve Seal Water System (IW) 1.
Category B valves IW-01, IW-02, and IW-03 cannot be exercised during power operation without rendering their control systems inoperable and this system is required to be in operation during power operation.
These valves will be full stroke exercised durino cuid shutdowns and refueling outages.
i 4
l s
55
1 VI. Attachment III The P& ids listed below were used during the course of this review.
System P&ID No.
Revision Main Steam (st-1)
M-20 X
Steam Generator Feedwater M-22 BB Service Water (st-1)
M-32-1 S
Service Water (st-2)
M-32-2 Y
Service Water M-34 U
Condensate Storage M-37-1 H
Containment Spray M-44 Y
Waste Disposal System (st-1)
M-45-1 S
Reactor Coolant M-52 P
Reactor Coolant M-53 S
Chemical & Volume Control M-54 R
Chemical & Volume Control M-55 Chemical & Volume Control M-56 L
Chemical & Volume Control M-57 M
Residual Heat Removal M-62 R
Safety Injection M-64 T
Safety Injection M-65 Q
Component Cooling M-66 N
Component Cooling M-67 N
Nuclear Sample M-74-1 J
Penetration & Support Cooling M-93 H
0 56
VII. Attachment IV A.
The following is a list of valves that are never full stroke exercised or that have a testing frequency greater than each refueling outage.
1.
Safety Injection System a.
SI-8948A, B, C and D - accumulator discharge to loops b.
SI-8956A, B, C and D - accumulator outlet check valves 2.
Containment Spray System
~
a.
CS-0016 CS-0021 spray additive check valves to CS-0026 containment spray pumps suctions B.
The following is a list of valves the utility is presently exercising quarterly but by doing so renders an entire safety system inoperable.
1.
SI-8806 -
safety injection pump suction from the RWST 2.
SI-8802 -
safety injection pump common discharge to the cold legs 3.
SI-8812A & B - low head SIS pump suction from RWST C.
Commonwealth Edison / Zion Units 1 & 2 personnel have decided to not include the turbine driven auxiliary feed p;mp in their IST pump testing program. This is inconsiszent with NRC guidelines.
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