Text

SER of Pump & Valve Inservice Testing (IST) Program Submitted by AL Power Co for Joseph M Farley Nuclear Plant, Unit 2, Interim Rept
	ML20028B498
Person / Time
Site:	Farley
Issue date:	10/31/1982
From:	Cook T, Hubble W, Rockhold H; EG&G, INC.
To:	Hammer C; Office of Nuclear Reactor Regulation
References
	CON-FIN-A-6430 EGG-EA-6078, NUDOCS 8212020108
	Download: ML20028B498 (141)
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& OSd en* */ Sift k ee f EGG-EA-6078 OCTOBER 1982 SAFETY EVALUATION OF THE PUMP AND VALVE INSERVICE TESTING [d4

_(IST') PROGRAM SUBMITTED BY THE ALABAMA POWER COMPANY (APC0)

FOR THE JOSEPH M. FARLEY NUCLEAR PLANT, UNIT 2 M7/$

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This is an informal report intended for use as a preliminary or working document Prepared for the U.S. NUCLEAR REGULATORY COMMISSION Under DOE Contract No. DE-AC07-761001570 Q FIN No. A6430 pg N 6 E 6 1daho 8212O20108 821031 PDR RES' I 8212O20108 PDR ___ __ )

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INTERIM REPORT

( Accession No.

EGG-EA-6078 Report No

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Contract Program or Project

Title:

, Review of Pump and Valve Inservice. Testin.g ' f Programs for Operating License Plants

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u Subject of this Document:

Safety Evaluation of the Pump and Valve Inservice Testing (IST)

Program Submitted by the Alabsma Power Compo,y (APC0) for the ,

Joseph M. Farley Nuclear Plant', Unit 2 Type of Document: ,

Safety Evaluation Report ,

Author (s):

T. L. Cook' ,f W. H. Hubble .

H. C. Rockho,ld j Date of Document: 4 .

October 1982 ,

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Responsible NHC Individual and NRC Office r f vision:

C.G. Hammer,DivisionofEngineering ' , *- \'

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This document was prepared primarily for preliminary or interdaW3e. lihas'not received )

fuXteview and approval. Since there may be substantive changes, this document should '

rJt be considered final. ,

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, ,, EG&G Idaho. Inc.

Idaho Falls, Idaho 83415

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U.S. Nuclear Regulatory Commission Washington, D.C.

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7g-SAFETY EVALUATION OF THE PUMP AND VALVE INSERVICE TESTING (IST)

PROGRAM SUBMITTED BY THE ALABAMA POWER COMPANY (APCO)

FOR THE JOSEPH M. .FARLEY NUCLEAR PLANT, UNIT 2 i:

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,. October 1982-T. L.' Cook W. H. Hubble

-A. H. C. Rockhold 1

gr Reliability an( 9tatistics Branch Engineering Analysis Division EG&G Idaho, Inc.

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r-i ABSTRACT This EG&G Idaho, Inc., report presents the results of our evaluation of'the Joseph M. Farley Nuclear Plant, Unit 2, Inservice Testing Frogram '

for' safety-related pumps and valves.

FOREWORD This report is supplied as part of the " Review of Pump and Valve Inservice Testing Programs for Operating License Plants" being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering, by EG&G Idaho, Inc., Reliability and Statistics Branch.

The U.S. Nuclear Regulatory Commission funded the work under the auth'orization B&R 20 19 04 09,- FIN No. A6430.

NRC FIN No. A6430--Review of Pump and Valve Inservice

. Testing Programs for Operating License Plants 11

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CONTENTS INTRODUCTION .......................................................... 1 PUMP TESTING PROGRAM .................................................. 3

1. CHARGING (HHSI) SYSTEM........................................... -3 2 .' - RES I DUAL H EAT REMOVAL ( RHR) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 e 3. . COMPONENT COOLING WATER (CCW) .................................... 13

4. SERVICE' WATER (SW) ............................................... 17

5. AUXI LI ARY FEEDWATER (MOTOR DRIVEN) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

6. AUXILIARY FEEDWATER (TURBINE DRIVEN) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

7. CONTAINMENT SPRAY ................................................ 31

8. RIVER WATER.(RW) ................................................. 34 VALVE TESTING PROGRAM EVALUATION ...................................... 41

1. . G EN E RAL CON S I D E RAT I ON S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 1.1 Testing of Valves Which Perform a Pressure Isolation Function ................................................... 41 1.2 ASME Code,-Section XI, Requirements......................... 41 1.3 Stroke Testing of Check Valves ............................. 42 1.4 ' Stroke Testing of Motor-0perated Valves .................... 42

, 1.5 Test Frequency of Check Valves Tested at Cold Shutdowns .... 43 1.6 Licensee Request for. Relief to 3t Valves at Cold Shutdowns .................................................. 43 1.7: Valve Testing at Cold Shutdowns ............................ 43 1.8 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIVs) .................................... 44 1.9 Application of Appenaix J Testing. to the IST Program . . . . . . . 45 ,

1.10 Safety-Related Valves ...................................... 45 1.11 Pressurizer Power Operated Relief Valves ................... 45 a

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2. R EACTO R COO LAN T SY ST EM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

'2.1 Category A Valves .......................................... 47 2.2 Category A/C Valves ........................................ 48

3. RESIDUAL HEAT REMOVAL / LOW HEAD SAFETY INJECTION . . . . . . . . . . . . . . . . . . 50 3.1 Category A Valves .......................................... 50 3.2 . Category A/C Valves ............................. .......... 52 3.3 Category B Valves ........ ............ ..... ....... ...... 56 111

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4. CONTAINMENT SPRAY ............................................. .. 59 4.1 C a t e g o ry A Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 4.2 C a t e g o ry C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

5. CONTAINMENT ISOLATION ............................................ 65 5.1 Ca t e g o ry A/C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65

6. HIGH HEAD SAFETY INJECTION / CHEMICAL AND VOLUME CONTROL ........... 66 6.1 C a t e g o ry A/ C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 .

6.2 Category B Valves .......................................... 80-6.3 C a t e g o ry C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81

7. POST ACCIDENT' CONTAINMENT VENTING AND SAMPLING SYSTEM ............ 84 7.1 Ca t e g o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84

8. LIQUID WASTE DISPOSAL SYSTEM ..................................... 86 8.1 Category A Valves ............ ............................. 86 8.2 . Category A/C Valves ........................................ 87 9, SPENT FUEL P0OL COOLING AND CLEAN-UP SYSTEM . . . . . . . . . . . . . . . . . . . . . . 89 9.1 _ Category A Valves .......................................... 89 9.2 Category A/C Valves .................................... ... 90 102 AUXILIARY FEEDWATER SYSTEM ....................................... 91 10.1 Category B Valves .......................................... 91

11. CONDENSATE AND DEMINERALIZED WATER TRANSFER AND STORAGE .......... 93 11.1 Category A/C Valves ........................................ 93

12. SERVICE WATER SYSTEM ............................................. 94 12.1 C a t e g o ry A/ C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94

13. COMPONENT COOLING WATER .................................... ..... 96

13.1 Category A/C Valves ........................................ 96 ,

14. SERVICE AIR SYSTEM ............................................... 99 14.1 Category A Valves .......................................... 99

15. INSTRUMENT AIR SYSTEM ............................................ 100 15.1 Category A Valves ...... ........................ ...... .. 100 15.2 Category A/C Valves ........................................ 101 iv

16. CONTAINMENT COOLING AND PURGE SYSTEM ............................. 103

'16.1 Category A Valves .......................................... 103

-APPENDIX A ....................................... .................... 105

.1. Code Requirement -. Valves ....................................... 107

2. Code Requirement - Pumps ........................................ 108

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APPENDIX B ............................................................ 109 e

1. SER SUPPLEMENT FOR J. M. FARLEY UNIT 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . 111 1.1 Testing of Valves Which Perform a Pressure Isolation Function ................................................... 111 ATTACHMENT 1 .......................................................... 115 ATTACHMENT 2 .......................................................... 116

1. VALVES EXERCISED DURING COLD SHUTDOWNS AND REFUELING ............. 116 1.1 -Relief Request ............................................. 116 1.2 Relief Request ............................................. 117

2. RESIOUAL HEAT REMOVAL / LOW HEAD SAFETY INJECTION .................. 119 2.1- C a t e g o ry A Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119

'2.2 C a t eg o ry B Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119

3. CONTAINMENT ISOLATION SYSTEM ..................................... 120 3.1 Category A Valves ......................'.................... 120

~4. HIGH HEAD SAFETY INJECTION / CHEMICAL AND VOLUME CONTROL . . . . . . . . . . . 121 4.1 Category A Valves .......................................... 121 4.2 Category B Valves .......................................... 121

5. HAIN STEAM ....................................................... 125 A

5.1 Category B Valves .......................................... 125

6. CONDENSATE AND FEEDWATER SYSTEM .................................. 126 6.1 Category B Valves .......................................... 126

.-- 6. 2 Ca t e g o ry B/C Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126

7. AUXILIARY FEEDWATER SYSTEM ....................................... 128 7.1 Category C Valves ................................... .. ... 128 y

8 .' . CONTAINMENT PURGE SYSTEM ......................................... 131 8.1 Category A Valves .......................................... 131

9. SERVICE WATER SYSTEM ............................................. 132'

. 9.1 Category A Valves .......................................... 132

9.2 _ Category B Valves .......................................... 132

10. COMPONENT COOLING WATER SYSTEM ................................... 134 10.1 C a t e g o ry A Va l v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 134 .

11. INSTRUMENT AIR SYSTEM ............................................ 135 11.1 Category A Valves .......................................... 135

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ATTACHMENT 3 .......................................................... 136 ATTACHMENT 4 .......................................................... 137

' ATTACHMENT 5 .......................................................... 138 e

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INTRODUCTION Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Alabama Power Company (APCO) for its Joseph M. Farley Nuclear Plant, Unit 2.

The working session with APC0 and Joseph M. Farley, Unit 2 representa-tives was conducted on October 7,1981. The licensee's resubmittal dated March 16, 1982, was received by EG&G Idaho, Inc., on May 7, 1982, and reviewed to verify compliance of proposed tests of safety-related Class 1, 2, and.3 pumps and valves with requirements of the ASME Boiler and Pressure Vessel Code,Section XI, 1974 Edition, through the Summer of 1975 Addenda.

Revision 2 to the IST program dated August 6, 1982, was received by EG&G on October 4, 1982, and has been incorporated into this SER. APC0 has also requested relief from the ASME Code rcquirements for testing specified pumps and valves because of practical reasons. These requests have been i

evaluated individually to determine whether they have significant risk I

implications and whether the tests, as required, are indeed impractical.

The evaluation of_the pump and valve testing programs and associated relief requests are the recommendations of EG&G Idaho, Inc.

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

A supplement to the Joseph M. Farley, Unit 2 SER that addresses test-ing of valves which perform a pressure isolation function is contained in Appendix B.

. Valves that we feel should be reviewed by the NRC for compliance with

-Appendix J containment isolation criterion are listed in Attachment 1.

I 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 Attachment 2.

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A listing of P& ids used for this review is contained in Attachment 3.

Valves.that are never full stroke exercised or that have a testing interval greater than each refueling _ outage, and relief requests with insufficient. technical-basis where relief is not recommended are summarized

.in Attachment 4.

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Items. discussed via telephone after the IST meeting with the licensee that result in-changes to their program and may appear as differences lbetween.their~ISTprogramandthisreportaredetailedinAttachment5.

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PUMP TESTING PROGARM The IST program sumitted by Joseph M. Farley, Unit 2 was examined to verify that Class 1, 2, and 3 safety-related pumps were included in the pro-gram'and that those pumps are subjected to the periodic tests as required by the ASME Code,Section XI. Our review found that all Class 1, 2, and 3

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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 J; M. Farley, Unit 2 basis for requesting relief from testing pumps and the EG&G Idaho evaluation of that request is summariced below. The information contained in the Licensee's Basis for Requesting Relief, including references made to paragraphs and tables, is contained in the

. licensee's IST program.

1. CHARGING (HHSI) SYSTEM 1.1 Relief Request The licensee has requested specific relief from the morthly inservice test on the Charging (HHSI) pumps, Q2E21P002A-A, 2B-AB, and 2C-B, in accord-ance with the requirements of Section XI and proposed to test these pumps in compliance with Section XI quarterly and to run these pumps and measure inlet (Pi) and outlet (Po)' pressure monthly.

1.1.1 Code Requifement Refer to Appendix A.

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1.1.2 Licensee's Basis for Requesting Relief i

The intent'of imposing the pump testing program is to provide assurance of.an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides such assurance; however, monthly testing also requires additional run times 3

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n an'd' unusual' operation of the equipment necessary to drive the pump and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possibly failure. An optimized test-ing program would provide assurance of pump operability and have the least

. impact on:the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. In addition, extensive investigation has been ~

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-conducted within the ASME Section XI' Subgroup for inservice testing of pumps and valves concerning the optimization of the test frequency. The investigation has resulted in a revision to the Code which requires a pump

' test frequency of nominally once every 3 months.

Alternate Testing:

.The pumps will be tested and the required parameters measured nominally i once every three (3) months. If deviations fall within the " alert range" of Table IWP-3100-2, the frequency of testing shall be increased to monthly unt'.1 the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent ether undesir-able occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating ,

sufficiently to satisfy system requirements. The parameters to be measured monthly.are indicated in Table P-I. Any pumps whose measured parameters .

-indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and parameters measured in accordance with the quarterly test interval indicated in Table P-I. Any further corrective action will result from the quarterly

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test parameters.

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F 1.1.3- Evaluation We agree with the licensee's basis and, therefore, feel that relief should_be granted from the testing requirements of Section XI for Charging

.(HHSI) pumps Q2E21P002A-A, 28-AB, and 2C-B. The licensee has demonstrated th' rough previously conducted testing that the proposed alternate testing frequency is sufficient to determine any pump degradation (the intent of

-Section XI).

o 1.1'. 4 Conclusion

'We conclude that the licensee's proposal of running these pumps monthly to measure Pi and Po to ensure no pump degradation, and of measuring all parameters quarterly and bearing temperature annually, meets the intent of the Section XI testing requirements and should be sufficient to adequately monitor pump degradation. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of pump operability intende<1 by the Code and that t!.e relief thus granted will not endanger life or property or the common defense and secu-rity of the public.

1.2 Relief Request The licensee has requested specific relief from the test re;uirement t of measuring Charging (HHSI) pumps, Q2E21P002A-A, 28-AB, and 2C-B, dP while the pumps are operating in a fixed resistance system and proposed to determine pump dP while the pumps are operating in their nomal configuration.

.- 1.2.1 Code Requirement Sub-Article IWP-3100 requires that each measured test quantity be compared to the reference value of the same quantity and any deviation determined shall be compared to the limits given in Table IWP-3100-2.

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1.2.2 Licensee's Basis for Requesting Relief n

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In order.t'o comply.with this test requirement for the Charging /HHSI pump dP, the pumps:must be aligned to their fixed resistance recirculation flow path. This alignment to the test configuration requires'that normal charging and RCP seal water requirements be provided from a pump in the other train. and isolation of the pump train to be tested. The pump now .

-providing normal charging and, seal water must be provided with its cooling

.water;from the appropriate train source which may cause realignment in that system and its support systems. The pump now aligned in the test configur-ation is not available for charging or HHSI.

'In-addition, the normal charging and seal supply configuration is not considered fixed resistance and adequate flow instrumentation is not provided.

Alternate. Testing: #

A test parameter of dP will be determined while the pumps are operat-ing, either normally or in accordance with the alternate testing specified in paragraph 2;1.1.2, in their normal operating configuration providing charging and RCP seal requirements. The acceptable limit for each pump's

-dP will be equivalent to 93% of the manufacturer's curve at a maximum charging and recirculation flow of 180 GPM (dP 22315 psi). Inability to meet this criteria will result in corrective action as provided in para-graph'2.1.1.2. -The dP parameter will be measured, compared, and analyzed in:acco'rdance with Code nominally once every 3 months.

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1.2.3 Evaluation

- l We agree with the licensee's basis and, therefore, feel that relief should be granted from the testing requirement of Section XI, Sub-Article IWP-3100, for Charging (HHSI) pumps Q2E21P002A-A, 2B-AB, and

-2C-B dP measurement. The licensee has demonstrated that the proposed alternate testing is sufficient to determine any pump degradation (the intent of Section XI).

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1.2.4 Conclusion We conclude that the' licensee's proposal of measuring pump dP quarterly

,- while these pumpsLare running in their normal configuration should provide sufficient information to adequately monitor pump. degradation. In addition, the establishment of two reference values (Pi and Po monthly, dP quarterly) for-these pumps should provide the required degradation information waether

. the pump is lined up to the normal charging flow path or the recirculation flow path. Based on the considerations'dircussed above we conclude that the alternate. testing proposed will give reasonable :ssurance of pump oper-ability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

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2. RESIDUAL HEAT REMOVAL (RHR).

2.1 Relief Request The licensee has requested specific relief'from the monthly inservice test on the Residual Heat Removal (RHR) pumps, Q2E11P001A-A and IB-B, in accordance with the requirements of Section XI and proposed to test these -

pumps in compliance with Section XI quarterly and to run these pumps and measure a single hydraulic parameter (dP or Q) monthly. (Reference Relief Request 2.2 to determine parameter.)

2.1.1 Code Requirement

' Refer to Appendix A.

-2.1.2 Licensee's Basis for Requesting Relief '

The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides.

such assurance; however, monthly testing also requires additional run' times and unusual operation of the equipment necessary to drive the pump and to align the system for the test. A penalty for increased usage and run time is increased equipment degradation and possibly failure. An optimized test-ing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. In addition, extensive investigation has been ,

conducted within the~ASME Section XI Subgroup for inservice testing of pumps and valves.concerning the optimization of the test frequency. The .

Investigation has resulted in a revision to the Code which requires a pump test frequency of nominally once every 3 months.

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m Alternate Testing:

The pumps will be tested and the required parameters measured nominally once every three (3) months. If deviations fall within the " alert range" of Table IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to maintain the-lubrication of the pump bearings and to prevent other undesir-able occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-I. Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and parameters measured in accordance with the quarterly test interval indicated in Table P-I. Any further corrective action will result from the quaterly test parameters.

2.1.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted from the testing requirements of Section XI for Residual Heat Removal (RHR) pumps Q2E11P001A-A and 1B-B. The licensee has demon-strated through previously conducted testing that the proposed alternate

, testing frequency is sufficient to determine any pump degradation (the intent of Section XI).

2.1.4 Conclusion We conclude that the licensee's proposal of running these pumps monthly to measure dP or Q to insure no pump degradation, and of measuring all 9

parameters quarterly and bearing temperature annually, meets the intent of

'the Section XI testing requirements and should be sufficient to adequately monitor pump degradation. Based on the considerations discussed above we conclude.that the alternate testing proposed above will give reasonable assurance of pump _ operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the.public.

2.2 Relief Request The licensee has reqvested specific relief from the test requirement of

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measuring Residual Heat Removal (RHR) pumps, Q2E11P001A-A and 18-B, dP or Q while the pumps are operating in a-fixed resistance system and proposed to determine pump dP or Q while the pumps are operating in their normal con-figuration for a given plant operating condition.

-2.2.1 Code Requirement Sub-Article IWP-3100 requires that each measured test quantity be compared to the reference value of the same quantity and any deviation determined shall be compared to the limits given in Table IWP-3100-2. '

2.2.2 Licensee's Basis for Requesting Relief In order to satisfy the test requirement for dP, each pump must be aligned to a fixed resistance. recirculation flow path, In the event the system is providing reactor coolant flow or is aligned to do so, each of the pumps'must be realigned for the test while the other pump is realigned ,

to satisfy reactor coolant flow requirements. The test configuration also requires the train to be isolated from the RCS and aligned to the RWST. -

This test configuration jeopardizes the overpressurization protection requirements outlined in the Technical Specifications.

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' Alternate Testing:

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Test parameters will be measured and. acceptability determined in- !

accordance'with'the'following:

Test RCS Function Measured Criteria Basis

~C f(1)' 4 Power Operation .ECCS dP, each Per Test Code

.or Pressure pump Requirement 2450 psig- (2.1.11)

(2) Pressure'<450 Aligned to dP, each 2126.5'psid .93 dPc* @ :

1 - psig and/or RCS for pump Qc*=3000 temperature. RHR

~s310*F, RC Pump (s)

Operating.

(3) ' Pressure <450- Reactor Q, each 23000 GPM Tech. Spec.

psig and/or Coolant . pump temperature Flow-

.5310'F, RC Pump

.Not.0perating.

'Where Qc and dPc are~ points on the mfg. curve.

Inability to meet this criteria wil1~ result in corrective action as provided in paragraph 2.'1.1.2. The alternate tests (2) or (3) will not be conducted coincidently with the quarterly requirements of Table P-I and Test-(1) are required when the RCS condition is as specified in tests (2)

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or'(3), tests-(2) or (3) will be conducted in lieu of the quarterly require-ments. Tne Quarterly Test Parameters and the test (1) parameter will then be measured, compared, and analyzed in accordance with the test requirement (2.1.11) within one (1) week after the plant is returned to normal operation.

2.2.3 Evaluation -

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We agree with the licensee's. basis and, therefore, feel that relief should be granted from the testing requirement of Section XI, Sub-Article ,

IWP-3100, for Residual Heat Removal (RHR) pumps Q2E11P001A-A and IB-B dP or

.Q measurement. The licensee.has demonstrated that the proposed alternate testing is sufficient to determine any pump degradation (the intent of Section XI).

2.2.4 Conclusion We conclude that the licensee's proposal of measuring pump dP or Q (determined by plant operatiog status) monthly while these pumps are operating in their normal configuration for a given plant operating condi-tion should provide sufficient information to adequately monitor pump degradation and that the proposed acceptability criteria meets the intent of the Section XI requirements. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of pump operability intended by the Code and that the relief thus granted will not erdanger life or property or the common defense and security of the public.

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3. COMPONENT COOLING WATER (CCW)

. 3 .- 1 Relief Request The licensee has requested specific relief from the monthly inservice test on the Component Cooling Water (CCW) pumps, Q2P17P001A-B, IB-AB, and IC-A,'in accordance with the requirements of Section XI and proposed to

-test these pumps in compliance with Section XI quarterly and to run these pumps and measure flow (Q) monthly.

l 3.1.1 Code Requirement

-Refer.to. Appendix A.

3.1.2 Licensee's Basis for Requesting Relief The intent of imposing the pump testing program is to provide assurance

-of an increased level of plant safety obtained by verifying that the pumps are capable ~of performing their safety function. A monthly test provides

-such assurance; however, monthly testing also requires additional run times and unusual operation of the equipment necessary to drive the pump and to align the system for the 19st. A penalty for increased usage and run time is increased equipment degradation and possibly failure. An optimized test-ing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. In addition, extensive investigation has been

, conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test frequency. The c investigation has resulted in a revision to the Code which requires a pump test frequency of nominally once every 3 months.

Alternate-Testing:

The pumps will be tested and the required parameters measured nominally once every three (3) months. If deviations fall within the " alert range" 13

of Table IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set established per IWP-3111.

.In addition, the pumps will be operated nominally once every month to inintain the lubrication of the pump bearings and to prevent other undesir-able occurrences. The test will require the pumps to be run in either their-

test or normal operating configuration for at least five (5) minutes and a

~

single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system ir, which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P_-I. Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and parameters measured in accordance with the quarterly test interval indicated in Table P-I. Any further corrective action will result from the quarterly test parameters.

3.1.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted from the testing requirements of Section XI for Component Cooling Water (CCW) pumps Q2P17P001A-B, IB-AB, and IC-A. The licensee has demonstrated through previously conducted testing that the proposed alter-nate testing frequency is sufficient to determine any pump degradation (the intent of Section XI).

3.1.4 Conclusion We conclude that the licensee's proposal of running these pumps monthly to measure Q to ensure no pump degradation, and of measuring all parameters quarterly and bearing temperature annually, meets the intent of the Section XI testing requirements and should be suffictent to adequately mon-itor pump degradation. Based on the considerations discussed above we con-clude that the alternate testing proposed above will give reasonable 14

assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

3.2 Relief Request The licensee has requested specific relief from the test requirement of

-measuring Component Cooling Water (CCW) pumps Q2P17P001A-B, IB-AB, and IC-A, flow (Q)'while the pumps are operating in a fixed resistance system and pro-posed to determine system heat exchanger discharge flow monthly while the pumps are operating in their normal configuration.

3.2.1 Code Requirement

'Sub-Article IWP-3100 requires that each measured test quantity be compared to the reference value of the same quantity and any deviations determined shall be compared to the limits given in Table IWP-3100-2.

3.2.2 Licensee's Basis for Requesting Relief The flow measuring devices for the Component Cooling Water System are located downstream of the CCW heat exchangers and are neither designed nor si.rategically located to provide flow indication within sufficient accuracy to accommodate the test requirement. As a result, CCW pump dP must be measured while the pumps are aligned in a fixed resistance recirculation flow path in order to satisfy the test requirement. This alignment to the test configuration requires that each pump be manually isolated from its normal flow path each month. CCW system requirements must be met by the other CCW pumps which may cause train supply switchover for certain systems

, such as RHR or Charging. This alignment to a test configuration on a monthly frequency reduces pump availability and is contrary to the justifi-cation for quarterly testing provided in paragraph 2.1.1.1.

Alternate Testing:

A test parameter of flow (Q) will be measured while the pumps are operating, either normally or in accordance with the alternate testing 15

specified in paragraph 2.1.1.2, in their normal operating configuration.

Due'to variable resistance in the system and the accuracy of the flow measurement, the flow parameter will be required to meet or exceed a heat exchangerd'ischarge flow corresponding to hot shutdown loads (Q 26400 GPM).

Inability to meet this criteria will result in corrective action as pro-Vided in paragraph 2.1.1.2. This alternate test will not be conducted coincidently with the quarterly requirements of Table P-1 and '

paragraph 2.1.1.2.

3.2.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted from the testing requirement of Section XI, Sub-Article IWP-3100, for Component Cooling Water (CCW) pumps Q2P17P001A-B, IB-AB, and IC-A Q measurement. The licensee has demonstrated that the proposed alternate testing is sufficient to determine any pump degradation (the intent of Section XI).

3.2.4 Conclusion We conclude that the licensee's proposal of measuring system heat exchanger discharge flow monthly while these pumps are operating in their normal operating configuration should provide sufficient information to adequately monitor pump degradation and that the proposed acceptability criteria meets the intent of the Section XI requirements. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or ,

property or the common defense and security of the public.

16

4. SERVICE WATER (SW) 4.1 Relief Request The licensee has requested' specific relief from the monthly inservice test on the Service Water (SW) pumps, Q2P16P001A-A, IB-A, IC-AB, ID-B, and 1E-B, in accordance with the requirements of Section XI and proposed to

' test these pumps in compliance with Section XI quarterly.

s-

~4.1.1 " ode Requirement Refer to Appendix A.

4.1.2 Licensee's Basis for Requesting Relief. The intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of performing their safety _ function. A monthly test provides such assurance; however, monthly testing also; requires additional run times and unusual operation of the equipment necessary to drive the pump and to align the system for the test.

A penalty for increased usage and run time is increased equipment degrada-tion and possibly failure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment' expected over its service lifetime. Operating experience.has indicated that pumps will not degrade over a single 30-day period. In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the t9st frequency. The investigation has

,. resulted in a revision to the Code which requires a pump test frequency of nominally once every 3 months.

Alternate Testing:

The pumps will be tested and the required parameters measured nominally once every three (3) months. If deviations fall within the " alert range" of~ Table IWP-3100-2, the frequency of testing shall be increased to ntenthly 17

until the cause of the deviation is determined and corrected and either the

. existing-reference values reverified or a new set established per IWP-3111.

In addition, the pumps will be operated nominally once every month to

. maintain the lubrication of.the pump bearings and to prevent other undesir-able occurrences. ' The . test will require the pumps to be run in either their test or normal .operatir.g configuration for at least five (5) minutes and a. ~

- single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-I. Any pumps whose measured paramet::rs indicate-unsatisfactory performarce will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and

_ parameters measured in accordance with the quarterly test interval indicated in_ Table P-I. Any further corrective action wi.ll result from the . quarterly test parameters. 6

_4.1.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted from the testing requirements of Section XI for Service Water (SW) pumps Q2P16P001A-A, IB-A, IC-AB,10-B, and 1E-B. The licensee has demonstrated through previously conducted testing that the proposed alternate testing frequency is sufficient to determine any pump degradation

. (the intent of Section XI).

L 4.1.4 Conclusion ,

We conclude that since these pumps are running continuously during .

power operation performing their required safety function that measuring Pi, Po, dP, Q, V, lubricant -level or pressure quarterly, and bearing temper-

' ature annually meets the intent of the Section XI testing requirements and should be sufficient to-adequately monitor pump degradation. Based on the considerations discussed above we conclude that the alternate testing pro-

-posed above will give reasonable assurance of pump operability intended by 18

F the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

4.2 Relief Request The licensee-has requested specific relief from measuring inlet pres-sure (P1) for the Service Water (SW) pumps, Q2P16P001A-A,18-A, IC-AB,10-B, and~ IE-B, in accordance with the requirements of Section XI and proposed to calculate Pi based on service water structure wet pit water level.

- 4.2.1 Code Requirement Sub-Article IWP-4200 requires' direct pressure measurement.

4.2.2 Licensee's Basis for Requesting Relief The service. water pumps are of vertical design with no means of direct inlet pressure measurement as required by IWP-4200.

Alternate Testing:

Indirect inlet pressure measurement will be obtained utilizing. service j water structure wet pit station level instrumentation. The level is'then

. converted to pump-inlet pressure by the following calculation:

Inlet Pressure = Wet Pit2.3066Level ft/psig (ft.) - 152.5 ft )

4.2.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be. granted from the Section XI requirement to measure Pi on Service 19

n i

n Water (SW) pumps Q2P16P001A-A,18-A, IC-AB,1D-B, and 1E-B. The licensee has demonstrated that instrumentation does not exist to measure Pi.

~

j.- 4.2.4 _ Conclusion

-We conclude that using service water structure wet pit water level to calculate pump Pi is an adequate alternate parameter to utilize to evaluate -

pump performance. Based on the considerations discussed above we conclude that the alternate parameter proposed above will give reasonable assurance of. pump operability intended by the Code and that the relief-thus granted will not endanger life or property or the common defense and security of the'public.

1. 3 Relief Request The licensee has requested specific relief from individually testing Service Water (SW) pumps, Q2P16P001A-A, 18-A, IC-AB, 10-B, and IE-B, in accordance with the requirements of Section XI and proposed to test these pumps'in combinations of two pumps per test.

4.3.1 Code Requirement

~Sub-Article IWP-3400 requires that an inservice test shall be 'run on each pump.

4.3.2 ' Licensee's Basis for Requesting Relief -

! Due to the demands of dependent systems, the individual testing of ,

service water pumps as required by IWP-3400 would jeopardize safe plant operation and be impossible to accomplish during plant shutdown. .

Alternate Testing: :

7 .i p i i Tests involving combinations of two pumps within each train will i indicate the hydraulic condition of the pumping system. The combinations '

are arranged such that each pump is included in at least one combination L-p I 20 b

test in each train. The initial tests are run on all combinations in each train incTuding the swing pump to provide base line data for any subsequent tests. In'the event of a detection of hydraulic change by a test, the test results are applied to both pumps in the combination. Each of the pumps is then tested in combination with another appropriate pump to assess the individual pump operational readiness.

4.3.3 Evaluation t

We agree with the licensee's basis and, therefore, feel that relief should be granted from the Section XI requirement to individually test Service Water (SW) pumps Q2P16P001A-A,18-A, IC-AB,10-B, and IE-B. The licensee has demonstrated that, due to present piping configurations and system flow requirements, the service water pumps can only be tested in parallel instead of individually as requirad by Section XI.

4.3.4 Conclusion We conclude that the licensee's proposal of testing these pumps quarterly in various combinations of pumps meets the intent of the Section XI testing requirements and should be sufficient to adequately monitor. pump degradation. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasor,able assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

4.4 Relief Request The licensee has requested specific relief from the test requirement of measuring Service Vater (SW) pumps, Q2P16P001A-A, IB-A, IC-AB,10-B, and IE-B flow (Q) while the pumps are operating in a fixed resistance system and-proposed to determine SW train (sub-system) flow quarterly while the pumps are operating in parallel in a variable resistance system.

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g}ub-ArticleIWP-3100requiresthateachmeasuredtestquantjtybe

-compared to the reference value of the same quantity and any deviation y

- determined shall be compared to the limits given in Table IWP-3100-2.

4.4)2,;Licen'see'sBasisforRequestingRelief -

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s inpcated 'in; paragraph 2.1.3.1, the service water pumps carinot be YindIviduartytested. The pumps must be tested quarterly by train (twa'(2) ,

pumps) as a variable resistance system. This is accomplished by throttMng .

the-flowsto a repeatable quantity and measuring the dP. LThe monthly mea-

,surementof:asinglehydraulicparameter,ar,allowedinfaragraph2.1.1.2

..an'd"comparisonperthetestrequirement,ismeaninglesr[sinceeitherflow

(Q) or di_fferential pressure (dP) is readily attainable'regardless of pump d'perability. The monthly measurement of both hydraulic parameters imposes egtended abnormal operating conditions on, the pumps and the system in order sto', attain;the:

..,& repeatable values.and defeats the purpose of implementing d Sqe,cr,terly tests qs provided in paragraph 2.1'.1.1.

Alternate. Testing:

+~}['l y,

A test _ parameter of flow (Q) will be measured for each train (two-(2) pumps' operating in each train). The swing pump will be operated with either of the pumps 'in the train to which it is aligned and flow will be' measured

~

for the train. The pumps will be operationally acceptable if the test flow meets or exceeds a quantity ~ equivalent to the cold shutdown requirements for 2

that' system train (J215,200GPM). Inability to meet this criteria will

, result in corrective action as provided in paragraph 2.1.1.2. The flow

, parameter will be measured, compared, and analyzed in accordance with the .

Code nominally once every 3 months. i l-n ,

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4.4.3 -Evaluation. <-

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. 1* We acree with the licensee's basis and, therefore, feel that relief h'ould~be ranteh'fromthetestingrequirementofSectionXI, v.

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N .SubaAEticle IWP-3100, for Service Water (SW) pumps Q2PI6P001A-A,18-A,

'.,IC-AB,-10-B, and IE-B Q measurement. The licensee has demonstrated that

. - t' '

"the proposed alternate testing is-sufficient to determine any pump degrada-

., tic.n (the intent of Section XI)- .

s A O L4 .4.4 ' Conclusion ik.pf\h ild We conclude that the licensee's proposal of measuring SW train

(sub-system) Q quarterly.while the pumps are operating in parallel in a

^jvariableresistancesystemshouldprovidesufficientinformationto

^

4:

= adequately monitor pump degradation and that the proposed acceptability criteria meets the intent of the Section XI requirements. . Based on the

_ considerations discussed above we conclude that the alternate testing bproposedabovewillgivereasonableassuranceofpumpoperabilityintended by the Code and-that the relief thus granted will not endanger life or

, property or the common defense and security of.the public.

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17

-5. AUXILIARY FEEDWATER (MOTOR DRIVEN) 5.1 Relief Request The licensee has requested specific relief from the monthiy inservice test on the motor driven Auxiliary Feedwater Pumps, Q2N23P001A-A and 1B-B,

in accordance with the requirements of Section XI and proposed to test these -

pumps in compliance with Section XI quarterly ~and to run these pumps and measure inlet (P1), outlet.(Po), and differential (dP) pressure monthly.

-5.1.1. Code Requirement Refer to Appendix A.

5.1.2 Licensee's Basis for Requesting Relief The intent of imposing the pump testing program is to provide assur- '

ance of an increased level of plant safety obtained by verifying that the pumps'are. capable'of performing their safety function.' A monthly _ test provides such assurance; however, monthly testing also requires additional frun ~ times and unusual operation of the equipment necessary to drive the pump and to align the system for the test. A penalty for increased usage

and run time is increased equipment degradation and possibly failure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. In addition, extensive investiga-tion has_been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test frequency. The investigation has resulted in a revision to the Code which ,

requires a pump test frequency of nominally once every 3 months.

Alternate Testing:

The pumps will be tested and the required parameters measured nominally once every three (3) months. If deviations fall within the " alert range" l 24

I of Table'IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is-determined and corrected and either the

-existing' reference values reverified or a new set established per IWP-3111.

'In addition, the pumps will.be operated nominally once every month to maintain the lubrication of the pump bearings and to prevent other undesir-able occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five ~(5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to j

be measured monthly are indicated in Table P-I. Any pumps whose measured parameters-indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and parameters measured in accordance with the quarterly test interval indicated in Table P-I. Any further corrective action will result

~from the quarterly test parameters.

5.1.3 ~ Evaluation We agree with the licensee's basis and, therefore, feel that relief

.should be granted from the testing requirements of Section XI for motor

- driven Auxiliary Feedwater pumps Q2N23P001A-A and IB-B. The licensee has demonstrated through previously conducted testing that the proposed alter-nate' testing frequency is sufficient to determine any pump degradation (the

-intent of Section XI).

5.1.4 Conclusion We conclude that the licensee's proposal of running these pumps monthly to measure Pi, Po, and'dP to ensure no pump degradation, and of measuring all parameters quarterly and bearing temperature annually, meets the intent of the Section XI testing requiremants and should be sufficient to adequately monitor pump degradation. Based on the considerations discussed above we conclude that the alternate testing proposed above will give 25

7l.

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j . treasonable; assurance of. pump operability intended by~the Code and that the-Lrelief~thus granted will~not endanger life ~or property or the common defense

-and security of the public.

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6. AUXILIARY FEEDWATER (TURBINE ORIVEN) 6.1 _ Relief' Request The. licensee has requested specific relief from the monthly inservice

. test on the turbine driven Auxiliary Feedwater pump, Q2N23P002, in

~- accordance with the requirements of.Section XI and proposed to test this

. pump in compliance with Section XI quarterly and to run this pump and measure inlet (Pi) outlet (Po), and differential (dP) pressure monthly.

6.1.1 Code Requirement Refer to' Appendix A.

6.1.2 Licensee's Basis for Requesting Relief The intent of imposing the pump testing program is to provide assurance

< of antincreased level of plant safety obtained by verifying that the pumps are capable of performing their safety function. A monthly test provides such assurance; however, monthly testing also requires- additional run times and unusual operation of the equipment necessary to drive the pump and to align.the system for the test. A penalty for increased usage and run time is increased equipment degradation and possible failure. An optimized testing program would provide assurance of pump operability and have the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test

-frequency. The investigation has resulted in a revision to the Code which requires a pump test frequency of nominally once every 3 months.

Alternate Testing:

The pumps will be tested and the required parameters measured nominally once every three (3) months. If deviations fall within the " alert range" 27

o of. Table'IWP-3100-2, the frequency of testing shall be increased-to monthly until-the cause of the deviation is determined and corrected and either the existing reference values reverified or'a new set established per IWP-3111.

1

~

In addition, the pumps will be operated nominally once every month to maintain _the lubrication of the pump. bearings and to prevent other undesir-The test will require the pumps to be run in either their

, able occurrences.

test or normal operating configuration for at least five (5) minutes and a .

single hydraulic parameter to be measured to detect any gross degradation of the pumps or the system in which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-I. Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and parameters measured in accordance with the quarterly test interval indicated in Table P-I. Any. further corrective ~ action will result from the quarterly

' test' parameters.

6.1.3 Evaluation

'We agree with'the licensee's basis and, therefore, feel that relief should belgranted from the testing requirements of Section XI for the turbine driven Auxiliary Feedwater pump Q2N23P002. .The licensee has demon-strated through previously conducted testing that the proposed alternate testing frequency is sufficient to determine any pump degradation (the intent of Section XI).

6.1.4 Conclusion

- t We conclude that the licensee's proposal of running this pump monthly to measure Pi, Po, and dP to insure no pump degradation, and of measuring all parameters quarterly and bearing temperature annually, meets the intent of the Section XI testing requirements and should be sufficient to ,

adequately monitor pump degradation. Based on the considerations discussed above we conclude that the alternate testing proposed above will give :

28

reasonable assurance of pcmp operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

6.2 Relief Request

. The licensee has requested specific relief from the test requirement of measuring turbine driven Auxiliary Feedwater pump, Q2N23P002, flow (Q) in accordance with the requirements of Section XI and proposed to determine pump dP for comparison with the manufacturer's pump performance curve.

6.2.1 Code Requirement Sub-Article IWP-3100 requires that each measured test quantity be compared to the reference value of the same quantity and any deviation determined shall be compared to the limits given in Table IWP-3100-2.

6.2.2 Licensee's Basis for Requesting Relief 1

A test in accordance with the Code requires that variable resistance systems be varied until either the measured differential pressure or the measured flowrate equals a reference value. The flow device used is not designed for the accuracy limitations of the Code.

Alternate Testing:

The pump will be tested at least once per 31 days by verifying that the pump develops a differential pressure of at least 93% for the applicable ficwrate as determined from the manufacturer's pump performance curve when the secondary steam supply pressure is greater than 90 psig.

6.2.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted from the testing requirement of Section XI, Sub-Article 3100, for the turbine driven Auxiliary Feedwater pump, 29

[

r

-'Q2N23P002,'Q measurement. The licensee-has demonstrated that the accuracy of'the flow instrumentation does not-satisfy the. requirements of Section XI and that;somparing. pump.dP is an acceptable alternate parameter.

6.2.4 Conilusion

.We conclude that the licensee's proposal to measure pump dP for com-- -

parison:with the manufacturer's pump performance curve should provide sufficient information to adequately monitor pump degradation and that the '

y ; proposed. acceptability criteria meets the latent of_the Section XI requirements. Based on the considerations discussed above we conclude that Lthealternateparameterproposedabovewillgivereasonableassuranceof pump operability; intended by the. Code and that the relief thus granted will not endanger life or property or' the common defense and security of the public.

v,.-

30

57

7. CONTAINMENT SPRAY (CS)

'7.1 Relief Request The: licensee has requested specific relief from the monthly inservice test on the Containment Spray (CS) pumps, Q2E13P001A-A and 18-B, in

?- sccordance with the requirements of Section XI and proposed to test these pamps in compliance with Section XI quarterly and to_run these pumps and measure inlet-(Pi),_ outlet (Po), and differential (dP) pressure monthly.

7.1.1 Code Requirement Refer to Appendix A.

7.1 2 , Licensee's Basis for Requesting Relief The-intent of imposing the pump testing program is to provide assurance of an increased level of plant safety obtained by verifying that the pumps are capable of_pceforming their safety function. A monthly test provides such assurance; however, monthly. testing also requires additional run times and unusual operation of the equipment necessary to drive the

. pump and-to align the system for the-test. A penalty for increased usage

.and run time is increased equipment. degradation and possibly failure. An optimized testing program would provide assurance of pump operability and have the least' impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not degrade over a single 30-day period. In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for inservice testing of pumps and valves concerning the optimization of the test-frequency. The investigation has resulted in a revision to the Code which requires a pump test frequency of nominally once every 3 months.

Alternate Testing:

The' pumps will be tested and the required parameters measured nominally once every three (3) mo1ths. If deviations fall within the 31

- "alert) range" of Tab'e IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation.is determined and corrected and either toe existing reference values reverified'or a new set established per IWP-3111.

-In addition, the pumps will be operated nominally once every month to

~

maintain,the lubrication of the pump bearings and to prevent other

undesirable occurrences. The test will. require the pamps to be run in either their test'or normal operating configuration fer at least five (5) minutes and a single hydraulic' parameter to be measured to detect any gross degradation of the pumps or the system in which they operate. In cases of multiple pump operation within a system or train of a system, a system or train parameter will be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to be measured monthly are indicated in Table P-I. Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and parameters measured in accordance with the quarterly test

. interval. indicated in Table P-I. Any further corrective action will result from the quarterly test' parameters.

7.1.3 Evaluation We agree with the licensee's basis and,-therefore, feel that relief

.should.be granted from the testing requirements of Section XI for the Containment Spray (CS) pumps Q2E13P001A-A and IB-8. The licensee has demonstrated through previously conducted testing that the proposed alternate testing frequency is' sufficient to determine any pump degradation

'(the-intent of Section XI). .

7.1.4 Conclusion .

We conclude that the licensee's proposal of running these pumps monthly to measure' Pi, Po, and dP to insure no pump degradation, and of measuring all parameters quarterly and bearing temperature annually, meets the intent of the Section XI testing requirements and should be sufficient to adequately monitor pump degradation. Based on the considerations 32

c 1 V

t e

discussed above we conclude that the alternate testing proposed above will

. : give reasonableLassurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or the common

defense and security of_the public.

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. 8 .' . RIVER WATER (RW)

8.1 Relief Request Theilicensee has requested specific relief from the monthly inservice test ~on the. River Water (RW) pumps,_QSP25P001-B, 2-B, 3-B, 6-A, and 7-A, in accordance with the requirements of-Section.XI and proposed to test these pumps in compliance with Section XI quarterly and to run.these pumps and

~

s measure train (sub-system) outlet (Po) pressure monthly.

8.1.1 ; Code Requirement .

Refer to Appendix A.

.'8.1.~2 - Licensee's Basis for -Requesting Relief

The ; intent of. imposing the pump testing program is to provide assurance of an' increased-level of plant safety obtained by verifying that the pumps' are capable of performing their safety. function. A monthly test provides such assurance; however, monthly testing also requires additional

'run times.and unusual operation of the equipment necessary to drive the pump and to align the system for the test. A. penalty for increased usage

- and run time is increased equipment degradation and possibly failure. An

= optimized testing program would provide assurance of pump operability and

~have.the least impact on the normal degradation of equipment expected over its service lifetime. Operating experience has indicated that pumps will not.' degrade over a single 30-day period. In addition, extensive investigation has been conducted within the ASME Section XI Subgroup for ,

inservice testing of pumps and valves concerning the optimization of the testifrequency. The investigation has resulted in a revision to the Code .

which requires a pump test frequency of nominally once every 3 months.

Alternate Testing:

The pumps will be tested and the required parameters measured nominally once every three (3) months. If deviations fall within the 34

" alert range"'of Table-IWP-3100-2, the frequency of testing shall be increased to monthly until the cause of the deviation is determined and corrected and either the existing reference values reverified or a new set

-established per IWP-3111.

In addition,- the pumps ~will be operated nominally once every month to

r. - maintain,the. lubrication of the pump bearings and to prevent other undesirable occurrences. The test will require the pumps to be run in either their test or normal operating configuration for at least five (5) minutes and a single hydraulic parameter to be measured to detect any gross degradation of th9 pumps or the system in which they operate. In cases of multiple pump operation within a system or train-of a system, a system or train parameter will- be measured and used to verify that the pumps are operating sufficiently to satisfy system requirements. The parameters to

' e measured monthly are indicated in Table P-I. Any pumps whose measured parameters indicate unsatisfactory performance will be retested within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and parameters measured in accordance with the quarterly test interval indicated in Table P-I. Any_ further corrective action will result from the quarterly test parameters.

8.1.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted from the testing requirements of Section XI for the River

' Water (RW) pumps QSP25P001-B, 2-B, 3-B, 6-A, and 7-A. The licensee has demonstrated through previously conducted testing that the proposed alternate testing frequency is sufficient to determine any pump degradation (the intent of Section XI).

8.1.4 ' Conclusion We conclude that the licensee's proposal of running these pumps monthly to measure train (sub-system) Po to ensure no pump degradation, and of measuring all parameters quarterly and bearing temperature annually, meets the intent of the Section XI testing requirements and should be sufficient to adequately monitor pump degradation. Based on the 35

o considerations discussed above we conclude that the alternate testing proposed above will:give reasonable assurance of pump operability intended s ' by the Code and that the relief thus granted will not endanger life or fproperty or the common defense and security of the public.

8.2 Relief Request t

The' licensee has requested specific relief from the test requirement

- of measuring individual outlet (Po) pressure on the River Water (RW) pumps,

~ QSP25P001-B,-2-B,-3-B,-6-A, and 7-A, in accordance with the requirements of Section.XI during the mont'ly h test and proposed to measure Po for each train (sub-system) while the pumps are operating in combinations of two'in each train.

3.2.1 -Code Requirement Sub-Article IWP-3100 requires that each measured test quantity be compared to the reference value of the same quantity'and any deviation determined shall be compared to the limits given in Table IWP-3100-2.

8.2.2 Licensee's Basis for Requesting Relief tince.discherge pressure instrumentation is provided for each train, single pump tests are required in order to satisfy the test requirement for dP. Starting and stopping of individual pumps and aligning the system into

.a test configuration for testing on a monthly basis defeats the intent and purpose of quarterly testing provided in paragraph 2.1.1.

Alternate Testing:

A test parameter of discharge pressure (Po) will be measured for each train with two (2) pumps operating and providing normal pond supply. All pumps will be operated with another pump in that particular train. The pumps will be operationally acceptable if the test discharge pressure (Po) meets or exceeds a quantity corresponding to a dP for the system at minimum river level with two (2) pump flow. Inability to meet this criteria will L

36 1

result in corrective action as provided in paragraph 2.1.1.2. This

' alternate. test will not be conducted coincidentally with the quarterly requirements of-Table P-I-and paragraph 2.1.1.2.-

8.2.3 . Evaluation

~

a :We agree with the licensee's basis and, therefore, feel that relief should be grant'ed from the testing requirements of Section XI, Sub-Article IWP-3100, for the River Water (RW) pumps, QSP25P001-B, 2-B, 3-B, 6-A, and 7-A. The licensee has demonstrated that measuring RW train r

(sub-system) Po is the only method available to determine pump Po since individual pump discharge pressure instrumentation is not installed.

8.2.4 Conclusion We conclude that the licensee's proposal of running these pumps in combinations-of two and-of measuring RW train (sub-system) Po during the monthly test should provide sufficient information to adequately monitor pump degradation. Based on_the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of pump-operability intended by~the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

8.3 Relief Request The licensee has requested specific relief from measuring inlet pressure (Pi) for the River Water (RW) pumps, QSP25P001-B, 2-B, 3-B, 6-A, and 7-A, in accordance with the requirements of Section XI and proposed to calculate Pi based on river water structure ' wet pit water level.

8.3.1 Code Requirement Sub-Article IWP-4200 requires direct pressure measurement.

t 37

- -. , ~

8.3.2 Licensee's Basis for Requesting Relief The1 river water pumps are of vertical design with no means of direct inlet pressure measurement as required by IWP-4200.

Alternate Testing:

Indirect inlet pressure measurement will be obtained by using river water structure wet pit station level instrumentation. The level is then converted to pump inlet pressure by the following calculation:

Inlet Pressure-= Wet Pit2.3066 Level (ft.) - 62.5 ft.

ft/psig 8.3.3 Evaluation

.We agree with the licensee's basis and, therefore, feel that relief

.should be granted from the Section XI requirement to measure Pi on River Water (RW) pumps QSP25P001-8, 2-B, 3-B, 6-A, and A. The licensee has

. demonstrated that-instrumentation does not exist to measure Pi.

8.3.4 Conclusion-We conclude that using river water structure wet pit water level to calculate pump Pi is an adequate alternate parameter to utilize to evaluate pump performance. Based on the considerations discussed above we conclude

~

that the alternate parameter proposed above will give reasonable assurance of pump operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of '

the public. ,

i 38 1

+

8.4~ Relief Request The licensee has requested specific relief from the c.omparison of test results to reference values for the River Water (RW) pumps, QSP25P001-B, 2-B, 3-B, 6-A, and.7-A, in accordance with the requirements of Section XI, Sub-Article 3110, and proposed to maintain the.results of each pump test as

. reference. values for comparison with previous tests when inlet pressure of the tests-is within 12%.

L'

8. 4.1' Code-Rypirement Sub-Article IWP-3110 requires that all subsequent test results shall be compared to reference values established during preoperational testing or during the first inservice test run.

8.4.2 Licensee's Basis for Requesting Relief Due to a continuously fluct aating river level and the fixed resistance asso'ciated with the system, the determinatior. of readily duplicated points of operation as required by IWP-3110 is not possible.

Alternate Testing:

Each-pump's test results are maintained as reference values. When subsequent results provide an inlet pressure within 12% of a previous test-inlet' pressure, the tests are compared and an assessment of the pump hydraulic condition is made.

8.4.3 Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted from the Section XI, Sub-Article 3110, requirement of comparison of test results to reference values for the River Water (RW) pumps, QSP25P001-B, 2-B, 3-B, 6-A, and 7-A. The licensee has demonstrated that, due to fluctuating river level,-duplication of test results is not

_possible.

39

8.4.4 Conclusion We conclude that the licensee's-proposal to maintain the:results of.

.each pump' test as reference values and to compare those values to previous

! test results when. inlet pressure of the tests'is within +2% will duplicate -

test resultsLas clo~sely as possible and should. provide sufficient

? c;.;t;- ir.f;rration to~ adequately monitor pump degradation. Based on the-

~

considerat;'ns discussed'above we' conclude that.the alternate testing

~

proposed above will give' reasonable assurance of pump operability intended ,

byithe'CodeLand'that the relief thus granted will not endanger life or '

property or theJcommon defense and security of the public.

4 1

~

l i-t 40

i VALVE ~ TESTING PROGRAM EVALUATION The IST program submitted by Alab'ama Power Company was examined to verify that Class 1, 2, and 3 safety-related valves were. included in the program and that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. Our review found that all Class 1, 2, and 3 safety-related valves were included in the IST program and, except for those valves identified below for which

^

specific relief from testing has been requested, the valve tests and ,

frequency of testing comply with'the Code requirements and the NRC positions and guidelines listed.in Section 1. Included in Appendix B is the NRC. position and valve listing for the leak testing of valves that

' perform a. pressure isolation function and a procedure for the licensee's

.use to incorporate these valves into the IST program. Each Alabama Power

. Company. request for relief from testing valves, the Code requirement for testing,~ Alabama Power Company's basis for requesting relief, and the EG&G Idaho evaluation of that request is summarized below and grouped according to each specific system.

1. GENERAL CONSIDERATIONS 1.1 Testing of Valves Which Perform a Pressure Isolation Functinn Refer to Appendix B, SER Supplement for Joseph M. Farley Unit 2.

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 be exercised once every three months, with the exception

.as defined in IWV-3520(b). IWV-3700 requires no regular testing for Code

-Category E valves. Operational checks, with appropriate record entries, shall record the position of these valves before operations are performed I

r 41

{

,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 accordancewithIWV-3410(c). In the above exceptions, the Code permits the valves to be tested at cold shutdown where:

It 1s not practical to exercise the valves to the position

~

1.

f required to fulfill their function, or to the partial position,

~

during power operation

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

-1.3 Stroke Testing of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full stroked. If only limited operation is possible (and it has been demonstrated by the licensee and agreed to by the NRC), the check valve shall be partial stroked. Since disk position is not always observable, the NRC staff stated that 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 the valve. The licensee agreed to conduct flow tests to satisfy:the above position.

1.4 Stroke Testing of Motor-Operated Valves The licensea has requested relief from the part stroke requirement of Section XI for all pcwer-operated valves. The licensee has stated that none of the Category A or B power-operated valves identified can be part stroked because of the design logic of the operating circuits. These circuits are such that when an open or closed signal is received, the valve must complete a full stroke before the relay is released to allow the valve 42

F:

to stroke in the other direction. We find that the above relief request from part stroking.is warranted and should be granted because the required function of the valves involves only full open or full closed positions.

1.5 Test Frequency of Check Valves Tested at Cold Shutdowns

.' The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Category 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 valves should be tested on the same schedule as Category A and B valves.

The licensee has agreed to modify his procedures on cold shutdowns to read, "In the case of frequent cold shutdowns, valve testing need not be performed more often than once every three (3) months for Category A, B, and C valves."

1.6 Licensee Request for Relief to Test Valves at Cold Shutdowns The Code permits valves to be tested at cold shutdowns, and these valves are specifically identified by'the licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it will not be necessary to grant relief; howaver, 'during our review of the licensee's IST program, we have verified that it was not practical to exercise these valves during power operation and that we agree with the licensee's basis. It should be noted that the NRC differentiates, for valve testing purposes, between the cold shutdown mode and the refueling mode. That is, for testing purposes, the refueling mode is not considered as a cold shutdown.

-1.7 Valve Testing at Cold Shutdowns Inservice valve testing at cold shutdowns is acceptable when the following conditions are met:

43

It is understood that the licensee is to commence testing as soon

~

1.

as:the cold shutdown condition is achieved but not later than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months after shutdown, and continue until complete or the 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 frequency.

For planned cold shutdowns, where the licensee will complete all the valves identified in his IST.. program for testing in the cold shutdown mode,

-exceptions to the 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months may be taken.

1.8 Category A Valve Leak Check Requirements for Containment Isolation Valves (CIVs)

All CIVs shall t e classified as Category A valves. The Category A valve. leak rate test requirements'of IWV-3420(a-e) have been superseded by Appendix'J requirements for CIVs. The NRC has concluded that the applicable leak test procedures and requirements for CIVs are determined by

10 CFR 50,- Appendix J. Relief from Paragraph IWV-3420(a-e) for CIVs presents no safety problem since the intent of IWV-3420(a-e) is met by Appendix J requirements.

The licensee shall comply with Sections-f and g of IWV-3420 until ,

relief is requested from these paragraphs. It should be noted that these paragraphs are only applicable where a Type C, Appendix J leak test is .

performed. Based on the considerations discussed above the NRC concludes

'that the alternate testing proposed above will give reasonable assurance of valve operability -intended by the Code and that the relief thus granted will not endanger life ~or property or the common defense and security of the public.

44

1.9 ' Application of ADpendix J Testing to the IST Program

~

The Appendix J review for this plant is a completely separate review from.the IST program review. However,.the determinations made by that review are directly aplicable to the IST program. Our review has determined that'the current IST-program as submitted by the licensee i

1 correctly reflects the NRC's interpretation of Section XI vis-a-vis

-Appendix J. The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.

1.10 Safety-Related Valves This review was limited to safety-related valves. Safety-related valves are defined as those valves that are needed to mitigate the consequences of an accident and/or to shut down the reactor and.to maintain the reactor.in a shutdown condition. Valves in this category would

' typically include ccrtain 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.

1.11 Pressurizer Power Operated Relief Valves The NRC has adopted the position that the pressurizer power operated relief valves should be included in the IST program as Category B valves and tested to the requirements of Section XI. However, since the PORVs have 'shown a high probability of sticking open and are not needed for over pressure protection during power operation, the NRC has concluded that routine exercising during power operation is "not practical" and,

.. therefore, not required by IWV-3410(b)(1).

The PORVs' function during reactor startup and shutdown is to protect the reactor vessel and coolant system from low temperature-overpressurization

- conditions and should be exercised prior to initiation of system conditions for which vessel protection is needed.

1 45 i'

a- .- -

~The'following test schedule is recommended:

1. Full-stroke exercising should be performed during cooldown prior to achieving the water: solid condition in the pressurizer and during cold _ shutdown prior to heat up.

2. Stroke timing should be performed at each cold shutdown or, as a

minimum, once each refueling cycle.

3; ' Fail safe actuation testing is permitted by the Code to be performed at each cold shutdown if the valves cannot be tested during power operation. This testing should be performed at each cold shutdown.

4. The PORV block valves should be included in the IST program to

-provide protection against a small break LOCA should a PORV~ fail open.

The Joseph M. Farley Unit 2 pressurizer power operated relief valves, PCV445A and PCV445B, and associated block valves, V027A and V027B, have not been. included in the IST' program, therefore these valves are not tested in accordance with the above NRC recommendations. The NRC position and recommended test schedule was explained to Alabama Power Company representatives at the-working session and in the " Questions and Comments" submitted prior to the session.

APC0 feels the PORVs and associated block valves are not safety-related because the valves are'not utilized for low temperature-overpressure protec- ,

tion of.the reactor coolant system. Low temperature-overpressure protection is provided by relief valves, V015A and V0158, installed on the Residual .

Heat Removal system between the reactor coolant suction isolation valves and the pumps and are set to relieve at 450 lbs.

We' feel the licensee's basis is inconsistent with NRC guidelines and test recommendations for PORVs and that these valves should be included in the IST program and tested in accordance with the above recommended test schedule.

46

2. REACTOR COOLANT SYSTEM 2.1 Category A Valves s

2.1.1' Relief Request: -

-; ~ The. licensee has requested specific relief-from exercising Category A

-.val ves V026A and V0268, pressurizer pressure: dead weight pressure generator containment isolations, in accordance.with the requirements of Section XI.

'2.1.1.1 Code Requirement.

Refer to Appendix A.

-2.1.1.2 Licensee's Basis for Requesting Relief. The. operability 1 testing (full or. partial stroke) during normal operation or cold shutdown

of--these valves _provides n'o assurance of an increase in safety. The valves are containment isolation valves which are normally closed and passive.

. The~ valves' ciosed position-will be verified'during the performance of the leak rate-tests at each~ refueling outage.

~2.1;1.3 ' Evaluation. We agree with the licensee's basis and,

!therefore, feel that relief should be granted.from the exercising requirements of-Section XI for Category..A valves V026A'and V0268. These valves are manual valves, in their safety-related position, and are ot-required to open' or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is

- inconsequential with regard to the safety function which they perform.

'2.1.1.4 C'onclusion. We conclude that the quarterly stroke and stroke time' measurements are meaningless for manual, passive valves. Based

. on the ' considerations discussed above we conclude that the alternate

' testing proposed above will give reasonable assurance of valve operability

- intended by the Code and.that the relief thus granted will not endanger

. life or~ property or the-common defense and security of the public.

47

7 l

2.2 Category A/C Valves 2.2.1- Relief Request ss

'The licensee has requested specific , relief from exercising

_ Category A/C valve V-038,- make-up water to pressurizer celief tank check

~ valve, in'accordance with the requirement; 6f Section-XI'ar.d proposed to -

verify valve closure (its safety-related-p?osition) during'each refueling-outage.

~

2.2.1.1 Code Requirement. .RefertoAphendix'A. -

J 2.2.1.2 Licensee's ' Basis for Requesting Relief. _Due to plant design it is~not practical to verify,by any posiEde means, neither directly nor indirectly, the operability of tiiis n6rmallh.open check valv'e per'the -

-requirements of IWV-3520. , t s

s ,

~.

(

- Valve closure ~ will Se verified during the 'performange of- the valve

~

s t

' leak'ratetestwhichshallbeconductedatthesamefrequ'encyasreactIP- '

refueling outages per the plant-Technical Spe51fichtions.

~

7

~ ; Jc 2.2.1.3 Evaluation. We agree with,the.,. licensee's'-hasis and, ,

,therefore, feel:that relief should be granted from'.the exercising requirements of_Section XI for Category A/C valve V038. The licensee has demonstrated that, due to plant design, the only method available to verify Y

' valve closure (its safety-related position) is leak testing. .This va,1ve is not equipped with valve position indication and some of the required ' test

. connections are' located inside containment.

q .

2.2.1.4 Conclusion. -We conclude that the proposed alternat testing .

of verifying valve closure du/ing the, performance of leak rate testing at refueling outages should demonst'. rate p' roper valve operaoility. Based on the' considerations discussed abave we conclude that the alterna.e testicq proposedabovewillgivereasonableassuranceofvalveoperabilityintyQed by the Code' and that the relief thus granted will riot endanger life or i property or the common defense and security of the public.

48 -

r- ,

7 .

t t

'2s2.2 : Relief Request L ,

y 4 The licensee has requesteki sprecific relief from exercising

}

~'

Category A/C valve V054, charging pump relief valve discharge check, in

-accordance with the requirements of Section XI and proposed to verify valve l closure' (its safety-related position) during each refueling outage.

a

-2.2.2.1' Code Requirement. Refer to Appendix A.

~

h<:- . ,.

2.2.2.2. Licensee's Basis for Requesting Relief. Due to plant design it is not practical 1to verify by any positive means, neither directly nor N indirectly, the operability of. this normally open check valve per the t

y. requirements of;IWV-3520. Valve closure will be verified during the i performance of i.hefvalva leak rate test which shall be conducted at the 1,. :same. frequency as reactor refueling outages per the plant Technical 1j: 1 Specifications. -

s 2 2.2.2 ,u'ation. "We' agree with the licensee's- basis and, 6

&< . 'therefore, feel that relief should be granted from the exercising e-.

.Wn s

requirements of Section XI for Category A/C valve V054. The licensee has N' ' (( demonstrated 3 hat,duetoplantdesign,theonlymethodavailabletoverify E d. _.sG w

Evalve closure (its safety-related position) is leak testing. This valve is M_y',: not equipped with vajve position indication and some of the required test 3

7, ~2 , s . '. c'gnnections are'. located inside containment.

}k M 2m; . %,,

,i Qw x,^ 1., s.

2: 2. 2. 4 Conclusion. ;We'conclu3e that the proposed alternate testing s

N s of verifying tvalve closure t,uring the performance of leak rate testing at r

f refueling ' outages should demonstrate proper valve operability. Based on

/ -

the conhiderations discussed aboveiwe conclude that the alternate testing h,jproposed JaboyeJwill give reason,able assurance of valve operability intended

- ', }9tQ by the ,se - ,

Code a'nd ..that the reliefithus granted will not end propert'y.'orf,ths comnon defense ~and security of the public.

,. , .- ~-

'**i ;C '

o y.. s .

\

s \ i s 3 i. \ s

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% . 49 ase 4*

s 9i ~ '

45

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u. -1 h "

s.1 g. /. '

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3 -

N 3. RESIDUAL HEAT REMOVAL / LOW HEAD SAFETY INJECTION '. I 1

3/1 Category .' Valves 3.1.1. Ralief Request ri

- \ ,

The; licensee.has requested specific relief from performing leak rate-

; /

testing.of Category A valves-V025A and V025B,'RHR containment sump suction isolations,*in accordance with the requirements of Section XI and proposed to. leak test these valves by applying the test pressure between the primary and secondary isolaticn valves.

3.1.1.1 C, ode Requirement. Vilves.shall be leak tested with the differential' pressure in the samer direction as applie'd when the valves are performing th.str safety functions.

3.1.1.2 Licensee's-Basis for Requesting Relief. These valves

, provide primary isolation for containment sump penetrations with no provisions- for leak rate testing with the differential pressure in the same direction as applied when the valves are performing their function as required by IWV-3420(c).

Alternate Testing:

Leak rate testing will be performed by applying the differential pressure between the primary and secondary isolation valves.

3.1 1.3 Evaluation. We agree with the licensee's basis and, therefore,-feel that relief should be granted from the leak testing requirement .of Section XI for Category A valves V025A and V0258. The .

licensee has demonstrated that, due to the present piping configuration, test pressure applied between the primary and secondary containment isolation valves is the only method available to leak test these valves.

50 ,

y 3.1.1.4 Conclusion. We conclude that the proposed method of leak testing these valves should verify their integrity. Based on the considerations discussed above we conclude that the alternate testing

. proposed above will give reasonable assurance of valve operability intended by the Code and that the' relief thus granted will not endanger life or property or the common defense and security of the public.

3.1.2 Relief Request n The licensee has requested specific relief from verifying remote position indication on Category A valves V025A and V0258, RHR containment sump suction isolations, in accordance with the requirements of Section XI and proposed to verify <alve opening during performance of leak rate

-testing.

-3.1.2.1 Code Requirement. Normally inaccessible valves with remote position indicators shall be visually observed at the same (or greater)

-frequency as reactor refueling outages to confirm operability of g:<ition indicators.

3.1.2.2 Licensee's Basis for Requesting Relief. Remote position indicators will be used to verify valve position per IWV-3300. However, visual observation of valve operation is not practical. Such observation would require removal of the valve protective chamber which is also considered to be a portion of the containment pressure boundary. Since the valve is provided with redundant indicators, position is accurately reflected by the remote indications.

Alternate Testing:

The leak rate test during each refueling outage will verify that the remote. position indicators accurately reflect the closed position of the valves. No practical means exists to verify the open position of the valves. However, following each leak rate test the air pressure will be relieved by opening these valves, thus verifying that the disk moves away from the seat.

51

3.1.2.3 ' Evaluation. We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the position indication verification requirements of Section XI for Category A valves V025A'and V025B. These valves have two safety-related positions, shut to form a containment barrier and open to provide a recirculation suction flow

. path-to the RHR/LHSI pumps. We agree that leak testing is an acceptable e method to utilize to verify valve closure but do not agree that venting the -

test pressure after leak testing by opening the valve will ensure that the

~

valve has opened sufficiently to allow the safety analysis design flow rate.

3.1.2.4 Conclusion. We conclude that the valve position indication

-must be observed to ensure that the indication accurnely reflects the oosition of these valves.

3.2 Category A/C Valves 3.2.1 Relief Request The' licensee has requested specific' relief from exercising Category A/C valves V021A, V021B, and V021C, RHR/LHSI pump cold leg discharge checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

3. ' .1.1 Code Requirement. Refer to Appendix A.

l 3.2.1.2 Licensee's Basis for Requesting Relief. The operability testing of these normally closed check valves per IWV-3520 requires flow verification under LHSI into each RCS loop. These valves cannot be exercised during power operation because the LHSI/RHR pumps cannot overcome ,.

RCS pressure. During cold shutdown, these valves cannot be full stroke .

. exercised because design flow cannot be verified through the valve unless f all initial test conditions can be met (i.e., suction from RWST through !-

both pumps to the RCS with the RCS at atmospheric pressure). !

52

. . . , - . - p

(

Alternate Testing:

The valves will be full stroked using the LHSI design flow during each refueling outage.

3.2.1.3~ Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising

! requirements of Section.XI for Category-A/C valves V021A, V021B, and V021C. The licensee has demonstrated that these valves cannot be exercised

.during power operation because the RHR/LHSI pumps cannot overcome reactor coolant system pressure. ~ Specific initial conditions must be met to permit

.ful1~ stroke exercising during cold shutdown. The reactor vessel head must

.be removed to place the RCS at atmospheric pressure and to provide an

' adequate volume to accomodate full LHSI flow. Additionally, both RHR/LHSI pumps must be aligned to take suction from the Refueling Water Storage Tank. That alignment does not allow decay heat removal from the core during cold shutdown conditions.

3.2.1.4 Conclusion. We conclude that full stroke exercising these valves during refueling outages when the reactor vessel head is removed and the.RCS is at atmospheric pressure should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted wil.1_ not endanger life or property or the common defense and security of the public.

3.2'.2 Relief Request

, The licensee has requested specific relief from exercising Category A/C valves V042A and V042B, RHR/LH5I pump cold leg discharge checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

3.2.2.1 Code Requirement. Refer to Appendix A.

53 I

l 3.2.2.2 Licensee's Basis for Requesting Relief. The operability testing of these normally closed check valves per IWV-3520 requires flow verification under LHSI into.each RCS loop. These valves cannot be exercised during power operation because the-LHSI/RHR pumps cannot overcome

.RCS pressure. During cold shutdown, these valves cannot be full stroke exercised because design flow cannot be verified through the valve unless all initial test conditions can be met (i.e., suction from RWST through -

both pumps to the RCS with the RCS at atmospheric pressure).

Alternate Testing:

The valves will be full stroked usir.g the LHSI design flow during each refueling outage.

3.2.2.3 Evaluation. We agree with the licensee's basis and, therefore, . feel _ that relief should be granted from the exercising requirements of Section XI for Category A/C valves V042A and V042B. The licensee has demonstrated that these valves cannot be exercised during power operation because the RHR/LHSI pumps cannot overcome reactor coolant system pressure. Specific initial conditions must be met to permit full stroke exercising during cold shutdown. The reactor vessel head must be removed _to place the RCS at atmospheric pressure and to provide an adequate volume to accommodate full LHSI flow. Additionally, both RHR/LHSI pumps must be aligned to take suction from the Refueling Water Storage Tank.

That alignment does not allow decay heat removal from the core during cold shutdown conditions.

3.2.2.4 Conclusion. We conclude that full stroke exercising these valves during' refueling outages when the reactor vessel head is removed and L

the RCS is at atmospheric' pressure should demonstrate proper valve ,

operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

54

/

.3.2.3 Relief Request The licensee has requested specific relief from exercising

. Catetory A/C valves V051A, V051B, and V051C, boron injection tank to RCS cold leg checks, in accordance with.the requirements of Section XI and

~

proposed to full stroke these valves during refueling outages.

3.2.3.1 Code Requirement. Refer to Appendix A.

3.2.3.2 Licensee's Basis for Requesting Relief. The operability testing of these normally closed check valves per IWV-3520 requires flow verification under HHSI'or'LHSI into each RCS loop. This flow verification cannot be accomplished during normal operation or cold shutdown.

During normal operation with the Reactor Coolant System at operating pressure,'these valves cannot be full stroke exercised because the HHSI pumps cannot provide design flow and the LHSI pumps cannot provide any flow.

During normal operation, partial stroke exercising these valves would induce undesired thermal shock to the safety injection nozzles.

During colo shutdown, design flow (full stroke exercising) cannot be verified because the Reactor Coolant System is pressurized.

Alternat'e Testing:

The valves will ce verified as operable by comparing HHSI flow through the BIT to the sem of the established individual reactor loop injection flows. The valve test will coincide with the testing of the HHSI system via the BIT at each refueling outage.

3.2.3.3 Evaluation. We agree with the licensee's basis and, there-E

. fore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valvas V051A, V0518, and V0510. The licensee has demonstrated that these valves cannot be exercised during power operation because the RHR/LHSI pumps cannot overcome reactor system 55 L ._o_

r pressure and that partial stroke exercising using the High Head Safety LInjection pumps would result in thermal shock and possible damage to the safety' injection nozzles. Design flow required for f , stroke exercis-ing cannot be verified during cold shutdown because the reactor system is pressurized and could result in.a low temperature-overpressurization condi -

tion. Full stroke exercising with full design flow can be accomplished during refuel,ing when the reactor vessel head is removed to provide an -

adequate expansion ~ volume and the reactor coolant system is at atmospheric pressure. ~

3.2.3.4 Conclusion. 'We conclude that full stroke exercising these valves during refueling outages when the reactor _ vessel head is removed should demonstrate proper valve operability. Based on the considerations

, discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

3.3 Category B Valves 3.3.1 Relief Request.

The licensee has requested specific relief from stroke timing Category B valves V032A and V0328, residual heat removal heat exchanger discharge, in accordance with the requirements of Section XI.

3.3.1.1 Code Requirement. Refer to Appendix A.

3.3.1.2 Licensee's Basis for Requesting Relief. The measurement of stroke. time for these flow control valves provides no increase in the level ,

.of safety for this system. The valves have no active function when the system is aligned for the LHSI function.

The operability testing of these valves every three months will verify that_the valves will operate from a closed to an open position.

56 l 1

3.3.1.3 Evaluation. We agree with the licensee's basis and, there-

, fore, feel that relief should be granted from the stroke timing requirements of Section XI for Category B valves V032A and V0328. The licensee has demonstrated that these normally open valves are passive during LHSI conc' tions and are not required to change position to perform their safety function. They are required to function as modulating valves only during residual heat removal ooerations and that function is tested quarterly.

~

3.3.1.4 Conclusion. We conclude that the quarterly stroke time measurement is meaningless for passive valves and that the stroke time of these valves is inconsequential with regard to the safety function they perform. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

3.3.2 Relief Request The licensee has requested specific relief from stroke timing Category B valves V033A and V033B, residual heat removal heat exchanger

. bypass, in accordance with the requirements of Section XI.

3.3.2.1 Code Requirement. Refer to Appendix A.

3.3.2.2 Licensee's Basis for Requesting Relief. The measurement of stroke time for these flow control valves provides no increase in the level of safety for this system. The valves have no active function when the system is aligned for the LHSI function. The operability testing of these valves every three months will verify that the valves will operate from a

, closed.to an open position.

'3.3.2.3 Evaluation. We agree with the licensee's basis and, there-fore, feel that relief should be granted from the stroke timing requirements of Section XI for Category B valves V033A and V033B. The licensee has demonstrated that these normally closed valves are passive during LHSI conditions and are not required to change position to perform their safety 57

function. They are required to function as modulating valves only during residual heat: removal operations and that function is tested quarterly.

r .3.3.2.4 Conclusion. We conclude that the quarterly stroke time measurement is meaningless for passive valves and that the stroke time of these valves is inconsequential with regard to the safety function they perform. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve

_ operability intended by the Code and that the relief thus granted will not

' endanger life or property or the common defense and security of the public.

i SC

4. CONTAINMENT SPRAY 4.1 Category A Valves

'4.1.1 Relief Request, The licensee has requested specific relief from performing leak rate testing of Category A valves V003A and V003B, Containment Spray contairment sump suction isolations, in accordance with the requirements of Section XI and proposed to leak test these valves by applying the test pressure between the primary and secondary isolation. valves.

4.1.1.1 Code Requirement. Valves shall be leak tested with the differential pressure in the same direction as applied when the valves are performing their safety function.

4.1.1.2 Licensee's Basis for Requesting Relief. These valves provide primary isolation for containment sump penetrations with no provisions for leak rate testing with the differential pressure in the same direction as applied when the valves are performing their function as required by IWV-3420(c).

Alternate Testing:

Leak rate testing will be performed by applying the differential pressure between the primary and secondary isolation valves.

4.1.1.3 Evaluation. We agree with the licensee's basis and, there-fore, feel that relief should be granted from the leak testing requirements of Section XI for Category A valves V003A and V003B. The licensee has demonstrated that, due to the present piping configuration, test pressure applied between the primary and secondary isolation valves is the only method available to leak test these valves.

59

p

[

b c 4.1.1.4 Conclusion. We conclude that the proposed method of leak testing these valves'should verify their integrity. Based on the

. considerations discussed.above'we conclude that the alternate testing

j. : proposed above will give reasonable assurance of valve operability intended by the. Code and that the relief thus' granted will not endanger life or property or the common defense and security of the public.

p .

24.1.2 Relief Request The licensee has requested-specific relief from verifying remote position indication on-Category A valves V003A and V003B, Containment Spray containment sump suction isolations, in accordance with the requirements of Section XI and proposed to verify valve opening during performance of leak rate testing.

4.1.2.1 Code Requirement. Normally inaccessible valves with remote

. position. indicators shall be visually' observed at the same (or greater)

{ frequency as reactor refueling outages to confirm operability of position indicators.

?

r-4.1.2.2 Licensee's Ba' sis for Requesting Relief. Remote position indicators will be used to verify valve position per IWV-3300. However, visual observation of valve operation is not practical. Such observation would require removal of the valve protective chamber which is also considered to be a portion of.the containment pressure boundary. Since the valve is provided with redundant indicators, position is accurately reflected by the remote indications.

Alternate Testing:

e .

-The leak rate test during each refueling outage will verify that the remote position indicators accurately reflect the closed position of the i valves. However, following each leak rate test the air pressure will be relieved by opening these valves, thus "erifying that the disk moves away from the seat.

60

r 4.1.2.3 Evaluation. We do not agree with the licensee's basis and, therefore, feel that relief should not be granted from the position indication verification requirements of.Section XI for Category A valves

'V003A and V003B. These valv'es.have two safety-related positions, shut to from a containment barrier and open to provide ^a recirculation flow path to the Containment Spray pumps. We agree that leak testing is an acceptable method to utilize to verify valve closure but do not agree that venting the test pressure after leak testing by opening the valve will ensure that the

~

valve has opened sufficiently to allow the safety analysis design flow rate.

4.1.2.4 Conclusion. We conclude that the valve position indication must be observed to ensure that the indication accurately reflects the position of'these valves.

4.2 -Category C Valves ,

4.2.1 Relief Request The licensee has requested specific relief from exercising Category C valves V002A and V002B, Containment Spray pump discharge checks, in accordance with the requirements of Section XI and proposed to manually full stroke exercise these valves during refueling outages.

4.2.1.1 Code Requirement. Refer to Appendix A.

4.2.1'.2 Licensee's Basis for Requesting Relief. Operability testing of these normally closed check valves per IWV-3520 during power operation or cold shutdown is not practical. During power operation the CTMT is not available. During cold shutdown, valve disassembly or an air test for flow verification requires draining a portion of the system.

Alternate Testing:

The valves will be verified as operable by removing the bonnet and manually full stroke exercising the disk at each refueling outage.

61-r

4.2.1.3' Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category C valves V002A and V0028. The licensee has demonstrated that, since these valves are located inside containment, the.only methods available to full stroke exercise them open is by using system flow or an air test. System flow cannot be used because it would result in spraying the containment causing electrical equioment '

~ damage and extensive' containment clean up. The air test requires containment entry and partial system draining which is not possible during power operation and could result in a delay of reactor startup if performed during cold shutdown.

4.2.1.4 Conclusion. We conclude that the proposed alternate test method and frequency to disassemble these valves and manually full stroke exercise them during refueling outages should demonstrate proper valve operability. ' Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code-and that the relief thus granted will not endanger life or property or the common defense and security of the public.

~4.2.2 Relief Request The licensee has requested specific relief from exercising Category C valves V007A and V0078, spray additive tank discharge checks, in accordance with the requirements of Section XI and proposed to manually full stroke exercise these valves during refueling outages.

4.2.2.1 Code Requirement. Refer to Appendix A.

4.2.2.2 Licensee's Basis for Requesting Relief. Operability testing of these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operation, exercising these valves with flow would introduce sodium hydroxide into the RWST (ECCS water supply). During-cold shutdown, both trains of the system would have 62

to be made inoperable.in order to drain the system for bonnet removal and manual exercising of the valve disk.

Alternate Testing:

The valves will~be verified as operable by removing the bonnet and

- manually full stroke exercising the disk at each refueling outage.

~ 4.2.2.3 Evaluation. We agree with the licensee's basis and, therefore', feel that relief should be granted from the exercising The requirements of Section XI for Category C valves V007A and V007B.

~1icensee has demonstrated that exercising these valves during power operation would contaminate the RWST/ECCS water supply with sodium hydroxide resulting in corrosion of the Emergency Core Cooling Systems.

Draining the system during cold shutdown requires that the Containment

- Spray system be rendered inoperable and could result in a delay of reactor startup.

4.2.2'.4 Conclusion. We conclude that, with the present system design, manual exercising ts the only available method to. full stroke exercise these valves without system contamination or rendering the system inoperable and that the' proposed alternate test method and frequency should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the ( '

common defense and security u? the public.

4.2.3 Relief Request

.The licensee has requested specific relief from exercising Category C

. valve V014, Containment Spray RWST suction check, in accordance with the requirements of Section XI and proposed to partial stroke exercise this valve quarterly.

4.2.3.1 Code Requirement. Refer to Appendix A.

63 6

s l'

4.2.3.2 Licensee's Basis for Requesting Relief. The operability

~ testing (full stroke) of this normally closed check valve per IWV-3520 during plant operation, cold shutdown, or refueling is not practical. The only means of full stroking the valve is by initiating the Containment Spray System which would cause excessive damage to equipment in CTMT.

Manually exercising the valve would require removing the valve bonnet after draining the RWST. -

Alternate Testing:

- The valve.will be verified as operable during the quarterly testing of the Containment Spray Pumps.' Due to system design, the valve can only be ,

partial stroke tested.

-4.2.3.3 Evaluation. We agree with.the licensee's basis and, therefore, feel that temporary relief should be granted from the full

. stroke exercising requirements of Section XI for Category C valve V014.

The licensee has demonstrated that this valve cannot be full stroke exercised without initiating spray into the containment which would result in extensive electrical equipment damage.

4'.2.3.4 Conclusion. We conclude that, with the present piping design a partial stroke exercise in conjunction with the quarterly pump test is the only test possible, llowever, we recommend that the licensee further investigate some alternate test method to full stroke exercise this valve at least once each refueling outage. Based on the considerations

~ discussed above we conclude that the alternate testing proposed above will

-give reasonable assurance of valve operability intended by the Code and .

that the temporary relief thus granted will not endanger life or property or.the common defense and security of the public. .

64 EL

5. CONTAINMENT ISOLATION SYSTEM

[ 5.1 Category A/C Valves l

5.1.1 Relief Request

.The licensee has requested specific relief from exercising Category A/C valve V001, containment air sample return check, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety-related position) during each refueling outage.

5.1.1.1 Code Requirement. Refer to Appendix A.

.5.1.1.2 Licensee's Basis for Requesting Relief. Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve per the

- requirements of IWV-3520. Valve closure will be verified during the per-4 fo-mance of the valve leak rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

5.1.1.3 Evaluation. We agree with the licensee's basis and, there-

- fore, feel that relief should be granted from the exercising requirements of

'Section XI for Category A/C valve V001. The licensee has demonstrated that,

' due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.

5.1.1.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or

- property or the common defense and security of the public.

65 L

6. HIGH HEAD SAFETY INJECTION / CHEMICAL AND VOLUME CONTROL 6.1 Category A/C Valves 6.1.1 Relief Request The' licensee:has requested specific relief from exercising '

-_ _ Category A/C valves:V032A, V0328, and V032C, accumulator cold leg discharge ichecks, in accordance with the-requirements of Section XI and proposed to

partial' stroke exercise these valves during refueling outages.

6.'1.1.1 l Code Requirement. Refer to Appendix A.

26.1.1.2c Licensee's Basis for Requesting Relief. The operability testing of ~these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operations,

.these valves cannot be full or- partial stroke exercised because the.

accumulators cannot overcome'RCS pressure. During cold shutdown, these

. valves cannot be fully or partially stroked without overpressurizing the

~

RCS ~. During refueltag outages, these valves cannot be full stroke exercised at'acce:.ulator operating pressure without causing internal core damage due"to excessive flow rates. = Disassembly of the valves during refueling outages requires the draining of the accumulators and associated piping.

Alternate Testing:

The valves will be partial stroke exercised at each refueling outage .

by discharging the accumulators into the RCS with the accumulators at

, _ atmospheric pressure. The valves will be verified as closed prior to the .

exercising by testing for leakage with a differential pressure 2100 psi across the_ valves. A decrease in accumulator level when the system is

-discharged to the RCS will verify a partial stroke.

66 I'

6.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that temporary relief should be granted from the full stroke exercising requirements of Section XI for Category A/C valves V032A, V0328, and V032C. The licensee has demonstrated that the only full flow path available-is into the reactor coolant system and is not possible during power operation because accumulator pressure cannot overcome RCS pressure. These valves cannot be exercised during cold shutdown without the~possiblity of creat.ing a low temperature overpressurization condition

~

'in the RCS. Additionally, these valves cannot be full stroke exercised utilizing accumulator flow during refueling outages, when the reactor vessel head is removed to provide an adequate expansion volume, without the possibility of damage.to reactor vessel internal components due to excessive flow rates.

6.1.1.4 Conclusion. We conclude that, with the present piping configuration, only partial stroke exercising of these valves is possible.

However, we recommend that the licensee further investigate a method to full stroke exercise these valves. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the temporary relief thus granted will not endanger life or property or the common defense and security of the public.

6.1.2 Relief Request The licensee has requested specific relief from exercising Catetory A/C Valves V037A, V0378, and V037C, accumulator cold leg discharge checks, in accordance with the requirements of Section XI and proposed to partial stroke exercise these valves during refueling outages.

6.1.2.1 Code Requirement. Refer to Appendix A.

6.1.2.2 Licensee's Basis for Requesting Relief. The operability testing of these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operation, these valves cannot be full stroke exercised because the accumulators 67 o

p cannot overcome RCS pressure. The valves cannot be partial stroke exercised during normal operation without making the accumulators

-inoperable, thus placing the plant in an unsafe condition. During cold shutdown, these valves cannot;be fully or partially stroked without

~

overpressurizing the RCS. During refueling outages, these valves cannot b'e E full stroke exercised at accumulator operating pressure without causing

< internal core damage due to excessive flow rates. Disassembly of the -

H . valves during refueling outages requires the draining of tho accumulators

~

arid associated piping.

7 Alternate Testing:

The valves will be partial stroke exercised at each refueling outage by discharging the accumulators into the RCS with the accumulators at atmospheric pressure. The valves'will be verified as closed prior to the exercising by testing 'for leakge with a differential pressure 2100 psi

-across the valves. A decrease in accumulator level when the system is Ldischarged to the RCS will verify a partial stroke.

-6.1.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that temporary relief 'should be granted from the full stroke exercising. requirements of Section XI for Category A/C valves V037A, V0378, and V037C. The licensee has demonstrated that the only full flow path available is into the reactor coolant system and is not possible during power operation because accumulator pressure cannot overcome RCS pressure. These valves cannot be exercised.during cold shutdown without the possibility of creating a. low temperature-overpressurization condition in the RCS. Additionally, these valves cannat be full stroke exercised utilizing accumulator flow during refueling outages, when the reactor vessel head is removed to provide an adequate expansion volume, without the .

possiblity of_ damage to reactor vessel internal components due to excessive flow rates.

6.1.2.4 Conclusion. We conclude that, with the present piping

configuration, only. partial stroke exercising of these valves is possible.

However, we recommend that the licensee further investigate a method to 68

full' stroke exercise these valves. Based en the considerations discussed above-we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the

. temporary relief thus granted will'not endanger life or property or the common defense and security of the public.

-1 6.1.3 Relief Request

'The licensee has requested specific relief from exercising Category A/C valve V052, accumulator fill line check, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety-related position) during each refueling outage.

6.1.3.1 Code Requirement. Refer to Appendix A.

6.1.3.2 Licensee's Basis for Requesting Relief. The valve is a passive containment isolation valve whose safety function is to remain closed. . Valve-closure will be verified during the performance of the valve leak rate test which shall be conducted at the same frequency as refueling outages.

6.1.3.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve V052. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure _(its safety-related position) is leak testing. This valve is not= equipped with valve position indication and some of the required test connections are located inside containment.

6,1.3.4 Conclusion. We conclude that the proposed alternate testing

-of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

69

v

.6.1.4 Relief Request

.The licensee has requested specific relief from exercising

. Category A/C' valve V058, accumulator nitrogen supply check, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety-related position) during each refueling outage.

~

6.1.4.1 Code Requirement. Refer to Appendix A.

6.1.4.2 Licensee's Basis for Requesting Relief. Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve per the requirements of IWV-1520.

Valve closure will be verified during the performance of the valve leak rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

6.1.4.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve V058. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test

. connections are located inside containment.

6.1.4.4 Conclusion. Wa conclude that the proposed alternate testing of verifying valve closure during the perforcance of leak rate testing at ,

refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing .

proposed above will give reasonable' assurance of valve operability intended

-by-the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

70

6.1.5 Relief Request

The licensee has requested specific relief from exercising

. Category A/C valves V062A, V062B, and V062C, Boron Injection Tank cold leg injection checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

'6.1.5.1 podeRequirement'. Refer to Appendix A.

6.1.5.2 Licensee's Basis for Requesting Relief. The operability testing of'these normally closed check valves per IWV-3520 requires flow verification under HHSI into each RCS loop. This flow verification cannot be accomplished during normal operation or cold shutdown. During normal operation, full or. partial stroking would cause overboration of the RCS, possibly causing'a plant shutdown. During cold shutdown, stroking these valves would cause overpressurization of the RCS.

Alternate Testing:

i The valves will be verified as operable by initiation of HHSI through the BIT _to the RCS during each refueling outage.

6.1.5.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valves V062A, V062B, and V062C. The licensee has demonstrated that exercising these valves during power operation would require injecting highly borated water into the reactor system which would'cause power transients and a possible reactor shutdown. These valves cannot be exercised during cold shutdown because

, High Head Safety Injection flow could cause a low temperature-overpressurization condition in the reactor coolant system.

6.1.5.4 Conclusion. We conclude that full stroke exercising of these valves can only be accomplished during refueling outages when the reactor vessel head is removed to provide an adequate expansion volume and should demonstrate proper valve operability. Based on the considerations 71

discussed above-we conclude that the alternate testing proposed above will

. give reasonable assurance of valve operability intended by the Code and that the~ relief .thus granted will not endanger life or property or the common defense :and security of the public.

6.1.6. - Relief Request The licensee has requested specific relief from exercising Category A/C_ valves V066A, V0668, and V066C, HHSI cold leg injection "

checks, in accordance with the requirements of Section XI and proposed to full stroke exercise.these valves during refueling outages.

~6.1.6.1 Code Requirement. Refer to Appendix A.

6.1.6.2 Licensee's Basis for Requesting Relief. Operability testing of these normally closed check valves per IWV-3520 during normal operation or cold shutdown is not practical. During normal operation, these valves cannot be full stroke exercised because the HHSI pumps cannot aci.ieve design flow against RCS pressure. Partially stroking the valves at power would induce thermal shock to the safety injection nozzles. During c ud

- shutdown, full stroking would overpressurize the RCS.

, Alternate Testing:

The valves will be verified as operable by comparing HHSI flow to the sum of the established individual reactor loop injection flowe. The valve ;

test will coincide with the testing of the HHSI system during each i refueling outage.

6.1.6.3 Evaluation. We agree with the licensee's basis and, there- ,

f fore, feel that relief should be granted from the exercising requirements

of Section XI for Category'A/C valves V066A, V0668, V066C. The licensee has' demonstrated that these valves cannot be. exercised during power i operation because the HHSI pumps cannot deliver the design flow rate '

against reactor system pressure and that partial stroke exercising would ,

result in thermal shock and possible damage to the safety injection ,

72 1

't -- e- e r ,- ,, ...-e- - n+w--~ -~e - - - - - - - e+ ~ - - - --s~

nozzles. These valves cannot be full stroke exercised during cold shutdown

-because the flow required could cause a low temperature-overpressurization condition in the reactor coolant system.

6.1.6.4 Conclusion. We conclude that full stroke exercising of these valves during refueling outages when the reactor vessel head is removed to provide an adequate expansion volume should demonstrate propcr valve operability. Based on the considerations discussed above we conclude

~~

that the alternate testing proposed above will.give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the publ'c.

6.1.7~ Relief Request The licensee has requested specific relief from exercising Category A/C valves V076A and V0768, RHR hot leg injection checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

6.1.7.1 Code Requirement. Refer to Appendix A.

6.1.7.2 Licensee's Basis for Requesting Relief. Operability testing of these normally closed check valves per IWV-3520 during nornal operation or cold shutdown is not practical. During normal operation, these valves cannot be full or partial stroked because the RHR/LHSI pumps cannot overcome RCS pressure. During cold shutdown, these valves cannot be fully or partially stroked without bypassing the core during RHR and defeating the RHR cooling function.

Alternate Testing:

The valves will be full stroke tested at each refueling outage when RHR/LHSI design flow is used to fill the reactor cavity.

73

I 6.1.7.3 Evaluation. We agree with the licensee's basis and, there-

~ fore,-feel that relief should be granted from the exercising requirements of Section XI for Category A/C valves V076A and V0768. The licensee has demonstrated that these valves cannot be exercised during power operation

'because the RHR/LHSI pumps cannot~overcone reactor system pressure. These valves cannot be. exercised during cold shutdown without diverting RHR flow which results in flow bypassing the core and loss of the residual heat

removal function.

6.1.7.4 Conclusion. We conclude that full stroke exercising these valves during refueling outages when RHR/LHSI system flow is used to fill the reactor cavity should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or preparty or the common defense and security of the public.

6.1.8 Relief' Request The licensee has requested specific relief from exercising Category A/C valves V077A and V077B, HHSI/LHSI/RHR hot leg injection checks to loops 1 and 2, in accordance with the requirements of Section XI and

. proposed to full stroke exercise these valves during refueling outages.

6.1.3.1 Code Requirement. Refer to Appendix A.

6.1.8.2 Licensee's Basis for Requesting Relief. Operability testing of these normally closed check valves per IWV-3520 during normal operation ,

or cold shutdown is not practical. During normal operation, these valves cannot be full stroked because the HHSI pumps cannot provide design flow .

and the LHSI pumps cannot provide any flow. Partial stroking the valves at power would induce thermal shock to the safety injection nozzles. During cold shutdown, full or partial stroking would overpressurize the RCS.

74

Alternate Testing:

The valves will be full stroked by initiation of LHSI while filling the cavity during each refueling outage. Establishment of LHSI/ECCS design flow through the Hot Leg injection path will verify that the valves have sufficiently opened to perform their fu:ction.

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

~

therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valves V077A and V0778. The licensee has demonstrated that these valves cannot be full stro'se exercised during power operation because the HHSI pumps cannot deliver the design flow rate against reactor system pressure and that partial stroke exercising would result in thermal shock and possible damage to the safety injection nozzles. The RHR/LHSI pumps cannot overcome reactor system pressure during power operation and cannot be utilized to full stroke axercise these valves during cold shutdown because the flow required could cause a low temperature-overpressurization condition in the reactor coolant system.

6.1.8.4 Conclusion. We conclude that full stroke exercising these valves during refueling outages when RHR/LHSI system flow is used to fill the reactor cavity should demonstrate proper valve operability. Based on the consideratiors discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or

' property or the common defense and security of the public.

6.1.9 Relief Request The licensee has requested specific relief from exercising Category A/C valves V077C, V078A, V0788, V078C, V079A, V0798, and V079C, HHSI hot leg injection checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.

75

6.1.9.1 Code Requirement. Refer to Appendix A. -

~

+

6.1.9.2 Licensee's Basis for Requesting Relief /. 0perability testing ,

[ of these normally closed check valves per IWV-3520 during noral operation ~-

i or cold shutdown is not practical. During normal operation, these valv'es

{ cannot'be full. stroke exercised because the HHSI pumps cannot achieve design flow against RCS pressure. Partially stroking the valves at power -

would. induce thermal shock to the safety injection nozzles. During cold shutdown, full stroking would overpressurize the RCS.

Alternate Testing:

The valves will be verified as operable by comparing HHSI flow to the s sum of the established individual reactor loop injection flows. The valve test will coinicide with the testing of the HHSI system during each h refueling outage.

6.1.9.3 Evaluation. We. agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of SectionXI for. Category A/C valves V077C, V078A, V0788, L

'V078C, V079A, V0798,.and V079C. The licensee has demonstrated that these

. valves cannot be full stroke exercised during power operation because the HHSI pumps.cannot deliver the design flow rate against reactor system pressure and that partial stroke exercising would result in thermal shock '

and possibla damage to the safety injection nozzles ~. These valves cannot ;

be' full stroke exercised during cold shutdown because the flow required could cause a low temperature-overpressurization condition in the reactor coolant system. '

.- 6.1. 9. 4 Conclusion. We conclude that full stroke exercising'these .

valves during refueling outages when the reactor vessel head is removed to provide an adequate expansion volume should demonstrate proper valve operability. . Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of 76 L: __

,c 7.g g ;

4 6, a-2g 4:.

g-O .s ik valve: operability intended by the Code and that the relief'thus granted v

g y, wiltnot endanger life or property or the common defense and security of

't' the public. ,

.D

'6.1.10 ' Relief Request ," s E .

~( , The licensee has requested specific relief from exercising Category A/C valves V115A, V1158, and V115C, reactor coolant pump seal water indsction checks, in accordance with the requirements of Section XI

, and proposfd30 verify valve closure (their safety-related position) during each'refueliigioutage.

's f

Fx G.1.10.1 Code Requirement.i Refer to Appendix A.

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-- 6.1.10.2 Licensee's Basis for' Requesting Relief. Due to plant design it is not' practical to verify by any positive means, neither h directly nor indirectly, the operab'ility of these normally open check

~

y- valves per the requirements of IWV-3520.-

Valve closure will be verified during the performance of the valve a ..

leak iate test which shall be conducted'at the same frequency as reactor L. ..

V . , refuejing+ outages per, the plant Technical Spect fications.

~

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a y 6.1.10.3 Evaluation. We agree;with.the licensee's basis and, therefore, feel that relief should be granted from the exercising

[ t . requirements 16f Ssction XI'for Category A/C valves V115A, V1158, and 6 %; V115C. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (their safety-related position) is leak testing. These valves are not equipped with valve position indication and some of the required test connections are located inside containment.

6.1.10.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on the. considerations discussed above we conclude that the alternate testing

-proposed above will give reasonable assurance of valve operability intended 77

v

. by the Code!and that the relief thus . granted will not endanger life or

, property or the common defense and security of the public.

~ 6.1.11- Relief' Request

.The licensee has requested specific relief from. exercising

' Category A/C valve V119, normal charging header check,'in accordance with

the requirements.of Section XI and proposed to verify valve closure (its

~

safety-related position) during each refueling outage.

6.1.11.1 Code Reouirement. Refer to Appendix A.

6.1.11.2 Licensee's Basis for Requesting Relief. Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve per the requirements of IWV-3520.

Valve closure will be verified during the performance of the valve

- leak rata test.which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

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

- therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve V119. The licensee has

-demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.

6.1.11.4 Conclusion. We conclude that the proposed alternate . 1 testing of verifying valve closure during the performance of leak rate

. testing at refueling outages should demonstrate proper valve operability.

Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

, 78

n. -

6.1.12 Relief Request E The licensee has requested specific relief from exercising Category A/C valve V213, reactor coolant pump seal water return overpressure protection check, in accordance with the requirements of Section XI and proposed to verify valve c.losure (its safety-related position) during.each refueling outage.

6.1.12.1- Code Requirement. Refer to Appendix A.

6.1.12.2 Licensee's Basis for Requesting Relief. Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve per the requirements of IWV-3520.

. Valve closure will be verified during the performance of the valve

/ leak rate test which shall be conducted at the same frequency as-reactor refueling outages per the plant Technical Specifications.

6.1.12.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve V213. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is not equipped with valve-position indication and some of the required test connections are located inside containment.

6.1.12.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate

, testing at refueling outages should demonstrate proper valve operability.

Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

79 i

(

6.2 Category B Valves 6.2.'11 Relief Request The licensee has requested specific relief from exercising Category B valve-V264,- charging pump. boric acid. suction, in accordance with the

- requirements of Section XI. and proposed to full stroke exercise this valve -

during refueling outages.

6.2.1.1 Code Requirement. Refer to Appendix A.

6.2.1.2 Licensee's Basis for Requesting Relief. Operability testing of this valve during normal operation or cold shutdown would require that the boric acid system be made inoperable, thus placing the plant in an

-unsafe condition.

Alternate Testing:

The valve will be full stroke tested for operability at each refueling

' outage.

6.2.1.3 -Evaluation. We agree with the licensee's basis and, therefore, feel that relief-should be granted from the exercising requirements of Section XI for Category B valve V264. The licensee has '

demonstrated that the boric acid system would be made inoperable if this i

, valve failed while testing. The boric acid system is required to be operable at all times during power operation and cold shutdown.

~

6.2.1.4 Conclusion. We conclude that full-stroke exercising this valve during refueling outages when the boric acid system can be removed ,

from. service should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance ni valve operability intended by the. Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

80

t a

u 6.3 Category C Valves-6.3.1 ' Relief Request The licensee has requested specific relief from exercising Category C valve V026, HHSI RWST suction check, in accordance with the requirements of

-Section XI and proposed to full stroke exercise this valve during refueling outages.

6.3.1.1 Code Requirement. Refer to Appendix A.

-6.3.1.2 Licensee's Basis for Requesting Relief. The operability testing of this normally closed check valve per IWV-3520 requires flow

. verification under HHSI into each RCS loop. This flow verification cannot be accomplished during normal operation or cold shutdown. During normal

-operation, full or partial stroking would cause overboration of the RCS, possibly, causing a plant shutdown. During' cold shutdown, stroking the valve would cause overpressurization of the RCS.

Alternate Testing:

The valve will be verified as opera 'iation of HHSI through the BITfto the RCS during each refueling 6.3.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category C valve V026. The licensee has demonstrated that exercising this valve during power operation would inject highly borated water into the reactor coolant system causing power

, transients that could result in a reactor shutdown. This valve cannot be exercised during cold' shutdown because the flow required would cause a low temperature-overpressurization condition in the reactor coolant system.

6.3.1.4 Conclusion. We conclude that full stroke exercising of this -

valve during refueling outages when the reactor vessel head is removed to provide an adequate expansion volume should demonstrate proper valve 81

i h-l operability. Based on the considerations discussed above we conclude that '

the' alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not. endanger life ~ or property 'or the common defense and security of the public.

6.3.2 Relief Request The111censee has~ requested specific relief from exercising, Category C valve V210, charging pump boric acid suction check, in accordance with the requirements of Section XI and proposed to full stroke exercise this valve during refueling outages.

6.3.2.1 Code Requirement. Refer to Appendix A.

6.3.2.2 Licensee's Basis for Requesting Relief. Operability testing of this _normally closed check valve per IWV-3520 during normal operation or cold shutdown would require that the boric _ acid system be made inoperable, thus placing the plant in an unsafe condition.

Alternate Testing:

The valve will be full stroke tested at each refueling outage by verifying that the maximum required flowrate passes through the valve.

6.3.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief ~should be granted from the exercising requirements of Section XI for Category C valve V210. The licensee has ,

demonstrated that exercising this valve requires isolation of the boric acid. system and that the boric acid system is required to be operable at .

all-times-during power operation and cold shutdown.

6.3.2.4 Conclusion. We conclude that full stroke exercising this valve during refueling outages when the boric acid system can be removed

, from service should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing 82

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proposed above will give reasonable assurance of valve operability intended by. the Code and that the relief thus granted will not endanger life er property or'the~ common defense and security of the public.

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1 83

-7. POST ACCIDENT CONTAINMENT VENTING AND SAMPLING SYSTEM

~

7.1 Category B Valves

-7.1.1 Relief Request The licensee has-requested specific relief from exercising Category B -

valve V021, containment pressurization supply, in accordance with the

~

requirements of Section XI and proposed to full stroke exercise this valve

-during' refueling outages.

7.1.1.1 Code Requirement. Refer to Appendix A.

7.1.1.2 Licensee's Basis for Requesting Relief. The operability testing (full stroke) of this valve during normal operation or cold shutdown could cause a loss of system function. During normal operation, opening the valve dumps all instrument air into the CTMT atmosphere causing a loss of RCS pressure control for spray and a loss of letdown control.

-During cold shutdown, exercising the valve would cause loss of pressure control and level control. Valve design does not facilitate a partial stroke test.

Alternate Testing:

The valve will be full stroke tested for operability at each refueling outage.

7.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category B valve V021. The licensee has ,

-demonstrated that this valve cannot be exercised during power operation or cold shutdown. Exercising this valve during power operation would result in loss of pressurizer spray control for reactor system pressure control and loss of letdown (pressurizer level) control, both of which could cause a reactor trip. Exercising this valve during cold shutdown would result in 84

I loss.of pre'ssure and . level control ~and could result in a low

, it'emperature-overpressurization condition in the reactor coolant system.

7.1.1.41 Conclusion. We conclude that full stroke exercising this valve ~.during refueling outages when the reactor vessel head is removed should demonstrate proper valve' operability. Based on the considerations

-discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve ~ operability intended by the Code and

.that' the relief thus granted will not endanger life or property or the common defense and security of the public.

f k

85

8. LIQUID WASTE DISPOSAL SYSTEM 8.' 1 Category A Valves 8.1.1. Relief Request' The licensee has requested specific relief from exercising Category A -

valve V005,' reactor drain tank pump. discharge control valve bypass, 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 operability testing (full or partial stroke) during normal' operation or cold shutdown

'of this valve provides no assurance'of an increase in safety. The valve is a containment isolation valve which is normally closed and passive. The valve's closed position will be verified during the performance of the leak rate tests at each refueling outage.

8.1.1.3 Evaluation. We agree with the licensee's basis a'nd,

'therefore, feel-that relief should be granted from the exercising

~

requirements-of Section XI for Category A valve V005. This valve is a manual valve,.in its safety-related position, and is not required to open

~

or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of this valve is inconsequential with. regard to the safety function it performs.

8.1.1.4 Conclusion. We conclude that the quarterly stroke and stroke time measurements are meaningless for manual, passive valves. Based on the considerations discussed above we conclude that the alternate .

testing proposed above will:give reasonable assurance of valve operability

' intended by the Code and that the relief thus granted will not endanger

life or property or the common defense and security of the public.

83

o 8.2 Category A/C Valves

-8'.2.11 Relief Request

'The licensee has requested specific relief from exercising Category A/C-valve V204, containment sump recirculation check, in i

accordance with the requirements'of Section XI and proposed to verify valve closure (its safety-related position) during each refueling outage.

8.2.1.1 Code Requirement. Refer to Appendix A.

8.2.1.2 Licensee's Basis for Requesting Relief. Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve pg.r the

-requirements of IWV-3520. Valve closure will be verified during the

. performance of the valve leak rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

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

-therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve V204. The licensee has demonstrated that, due to plant design, the only method available tc verify valve closure (its safety-related position) is leak testing. This valve is not-equipped with_ valve position indication and some of the required test connections are located inside containment.

8.2.1.4 . Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended

, by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

87

r 8.2.2 Relief Request The licensee has requested specific relief from exercising Category A/C valve V291, containment sump pump discharge overpressure protection check, in accordance with.the requirements of Section XI and proposed to verify valve closure (its safety-related position) during each refueling outage. -

8.2'2.1 -Code Requirement.

. Refer to Appendix A.

8.2.2.2 Licensee's Basis for Requesting Relief. Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve per the requirements of IWV-3520. ' Valve closure will be verified during the performance of the valve leak rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

8.2.2.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve V291. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety related position) is leak testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.

8.2.2.4- Conclusion. We conclude that the proposed alternate testing

~ of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing ,

proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

88

9. SPENT FUEL POOL COOLING AND CLEAN-UP SYSTEM 9.1 Category A Valves 9.1.1 Relief Request The licensee has requested specific relief from exercising Category A valve V012, spent fuel pool refuel cavity isolation, in accordance with the

~-

requirements of Section XI.

9.1.1.1 Code Requirement. Refer to Appendix A.

9.1.1.2 Licensee's Basis for Requesting Relief. The operability testing (full or partial stroke) during normal operation or cold shutdown of'this valve provides no assurance of an increase in safety. This valve is a containment isolation valve which is normally closed and passive.

This valve's position will be verified during the_ performance of the leak rate' tests at each refueling outage.

-9.1.1.3 Evaluation. We agree with the licensee's basis and,

-therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A valve V012. This valve is a j manual valve, in its safety-related position, and is not required to open or close to mitigate the consequences-of an accident or safely shutdown the plant. Therefore, the operability of this valve is inconsequential with regard to the safety function it performs.

9.1.1.4 Conclusion. We conclude that the quarterly stroke and stroke time measurements are meaningless for manual, passive valves. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

89

/

.9.2 Category A/C Valves 9.2.1- Relief Request The licensee-has requested specific relief from exercising Category A/C valve V013, spent' fuel pool refuel cavity isolation check, in

accordance with the requirements of Section XI and proposed to verify valve

- closure-(its safety-related position) during each refueling outage.

9.2.1.1' Code Requirement. Refer to Appendix A.

9.2.1.2 Licensee's Basis for Requesting Relief. Due to plant design

~

it'is not practical to verify by any positive means, neither directly nor

?

indirectly, the operability of this normally open check valve per the

-requirements of-IWV-3520. Valve-closure will be verified during the performance of the-valve leak rate test which shall be conducted at the same f requency as reactor refueling outages per the plant Technical

- Specifications.

9.2.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve V013. The licensee has demonstrated that', due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.

,9.2.1.4 Conclusion. We conclude that the proposed alternate testing ,

of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on .

the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

90 L

=

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10. AUXILIARY _FEEDWATER SYSTEM 10.1 Category B Valves 10.1.1 Relief Request

~The licensee has requested specific relief from exercising Category B valves V013A, V013B, V014A, V0148, and V014C, auxiliary feedwater pumps

~

service water supply, in accordance with the requirements of Section XI and proposed to full stroke these valves during refueling outages.

10.1.1.1- Code Requirement. Refer to Appendix A.

10.1.1.2 Licensee's Basis for Requesting Relief. It is not practical to exercise these valves during normal plant operation or at cold shutdown per IWV-3410. The exercising of these valves would introduce chlorides and-fluorides into the Steam Generators, jeopardizing the secondary water chemistry which could result in SG mechanical damage.

-Alternate Testing:

These valves will be exercised at reactor refueling outages.

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

-therefore, feel that relief should be granted from the exercising requirements of Section XI for Category B valves V013A, V0138, V014A, V014B, and V014C. The licensee has demonstrated that these valves cannot be exercised during power operation or cold shutdown without introducing service water into the suction piping of the auxiliary feedwater pumps and

, from there into the steam generators. The service water contains chlorides and fluorides which would upset the secondary water chemistry and could cause mechanical stress damage to the steam generators.

10.1.1.4 Conclusion. We conclude that full stroke exercising these valves during refueling outages when the Auxiliary Feedwater System suction 91

1 l

~

piping can be isolated and flushed prior to'its return to service should demonstrate-proper valve operability. Based on the considerations

. discussed'above we conclude that the alternate testing proposed.above will

, give. reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

e i

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I i

92 e

11. CONDENSATE AND DEMINERALIZED WATER TRANSFER AND STORAGE 11.1 Category A/C Valves 11.1.1- Relief Request

The licensee has requested. specific relief from exercising

-C'ategory A/C valve V002, reactor vessel head storage stand demineralized

^

water supply check, in accordance with'the requirements of Section XI and

. proposed to' verify valve clasure (its safety-related position) during each

_ refueling outage.

11.1.1.1 Code Requirement. Refer to Appendix A.

11.1.1.2 ~ Licensee's Basis for Requesting Relief. -Due to plant design it is not practical to verify by any positive means, neither directly nor_ indirectly, the operability of this normally.open check valve per the requirements of IWV-3520. Valve closure will be verified during the performance of the valve leak rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

~11.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section -XI for Category A/C valve V002. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.

11.1.1.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.

Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended-by the Code and that the relief thus granted will not endanger life cr property or the common defense and security of the public.

93

m-

12. SERVICE WATER SYSTEM 12.1 Category A/C Valves 12.1.1.. Relief Request The licensee has requested specific relief from exercising

~

Category A/C: valva V075,' reactor coolant pump motor service water supply

.check, in accordance with-the requirements of Section XI and proposed to

- verify., valve closure (its safety-related position) during each refueling outage.

12.1.1.1, Code Requirement. Refer-to. Appendix-A.

.12.1.1.2 Licensee's Basis for Requesting Relief. Due to plant

- design it is not practical to verify by any positive means, neither directly nor. indirectly, the. operability of this normally open check valve per the requirements of. IWV-3520. Valve closure will be verified during the performance-of the. valve leak rate test which shall be conducted at the

' same frequency as reactor refueling outages per the plant Technical Specifications.

12.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel'that relief should be granted from the. exercising requirements of Section XI for Category A/C valve V075. The licensee has demonstrated that, due to-plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test connections are located inside contai t..ent.

12.1.1.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate

- testing at refueling outages should demonstrate proper valve operability.

. Based on the considerations discussed above we conclude that the alternate 94

t

._ testing proposed above will give reasonable.assu'rance of valve operability Lintended by the~ Code and that the' relief thus granted will not endanger life ~or property' or the' comon defense and security' of the public.

a' ,

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I 95

13. COMPONENT COOLING WATER 13.1 Category A/C Valves

. 13.1.1! Relief Request The licensee has requested specific relief from exercising

Category.A/C valve V083, reactor coolant pump component cooling water supply check, in accordance with the r'equirements of Section XI and

. proposed to verify valve closure (its safety-related position) during each refueling outage.

13.1.1.1! Code Requirement. Refer to Appendix A.

13.1.1.2 Licensee's Basis for Requesting Relief. Due to plant design it is not practical to verify by any positive means, neither directly nor indirectly, the operability of this normally open check valve per-the requirements of IWV-3520.

Valve closure will be verified during the performance of the valve 1eak rate test which shall be conducted-at the same frequency as reactor refueling outages per the plant Technical Specifications.

13.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising

. requirements of Section XI for Category A/C valve V083. The licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related position) is leak testing. This valve is

'not equipped with valve position indication and some of the required test connections are located inside containment. ,

13.1.1.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at !

refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing 96

t

--proposed.above will give reasonable assurance of valve operability intended by the Code and that.the relief thus granted will not endanger life or property or the common defense and security of the public.

13.1'.2 -Relief Request The licensee has requested spezific relief from exercising Category A/C valve V159, excess letdown heat exchanger component cooling

~

water supply check, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety-related position) during each refueling outage.

13.1.2.1 Code Requirement. -Refer to Appendix A.

13.1.2.2 Licensee's Basis for Requesting Relief. Due to plant _ design it is not practical to verify by any positive means, neither directly nor

-indirectly, the-operability of this normally open check valve per the requirements of IWV-3520.

Valve closure will be verified during the performance of the valve leak rate test which shall be conducted at the same frequency as reactor refueling outages per the plant Technical Specifications.

13.1.2.3 Evaluation. We agree with the licensee's basis and, there-fore, feel-that relief should be granted from the exercisino requirements of Section XI for Category A/C valve V159. The licensee has demonstrated that, due' to plant design, the only method available to verify valve closure ~ (its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the required test connections are located inside containment.

13.1.2.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at

, refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing 97

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I g:i

-t-_.

j. . proposed aboy'e-will give~ reasonable assurance o'f valve operability intended 1 j by the Code 'and-that the relief thus granted will -not. endanger life or l-L property or the common defense'and security of the'public.

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,,r , . _v - - - - , - - , . - - .--w.-....~-- . . - - - - ,..-.re -------r- ---m--=-- m.--- .- --r---- er--- +- iv--- ---. - + --- - - . - - - . - --- - * - - - -

14. SERVICE AIR SYSTEM 14.1 Category A Valves

14.1.1 Relief Request

-+.. The licensee has requested specific relief from exercising Category A valves V001, V002, V004, and V005, pipe penetration rooms and containment ~

service air supply isolations, in accordance with the requirements of Section XI.

14.1.1.1 Code Requirement. Refer to Appendix A.

14.1.1.2 Licensee's Basis for Requesting Relief. The operability testing (full or partial stroke) during normal operation or cold shutdown of these valves provides no assurance of an increase in safety. The valves are containment isolation valves which are normally closed and passive.

The valves' closcd positions will be verified during the performance of the leak rate tests at each refueling outage.

14.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising requirements of Section XI for Category A valves V001, V002, V004, and V005. These valves are manual 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. Therefore, the operability of 7

these valves is inconsequential with regard to the safety function which l they perform.

14.1.1.4 Conclusion. We conclude that the quarterly stroke and l stroke time measurements are meaningless for manual, passive valves. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger i life or property or the common defense and securit; of the public.

99

3

15. INSTRUMENT AIR SYSTEM 15.1 Category A Valves

'15.1.1 Relief Request The licensee has requested specific relief from exercising and stroke -

timing Category A valve HV2228, pressurizer PORVs backup air supply, in accordance with tht? requirements of Section XI.

15.1.1.1 Code Requirement. Refer to-Appendix A.

15.1.1.2 Licensee's Basis for Requesting Relief. The operability testing (full or partial stroke) .during normal operation or cold shutdow'n of this valve provides_no assurance of an increase in safety. This valve

-is a containment isolation valve which is normally closed and passive.

.The valve's closed position will be verified during the performance of the leak rate tests at each refueling cutage.

15.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising and

~ stroke timing requirements of Section XI for Category A valve HV2228. This valve is a passive valve, in its safety-related position, and is not required to open or close to mitigate the consequences of an accident or Lsafely shut down the plant. Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs.

15;1.1.4 _ Conclusion. We conclude that the quarterly stroke and

. stroke time measurements are meaningless for passive valves. Based on the . l considerations discussed above we conclude that the alternate testing prooosed above will give reasonable assurance of valve operability intended

- by the Code and that the relief thus granted will not enoanger life or property or the common defense and security of the public.

i.

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d' 15.2 Category A/C Valves 15.2.1 Relief Request

The licensee has requested specific relief.from exercising Category A/C valve V004, pressurizer PORVs. backup air supply check, in

accordance with the requirements of Section XI and proposed to verify valve closure .(its safety related position) during each refueling outage

'15.2.1.1 Co'de Requirement. Refer to Appendix A.

15.2.1.2 ~' Licensee's Basis for Requesting Relief. The operability testing (full or partial stroke) during normal operation or cold shutdown of this valve provides no assurance of an increase in safety. This valve is a containment isolction valve which is normally closed and passive.

'The valve's closed position will be verified during the performance of the leak rate tests at each refueling outage.

o 15.2.1.3 Evaluation. We agree with the licensee's basis and, there-fore, feel that relief should be granted from the exercising requirements of Section XI for Category A/C valve-V004. This valve is a passive check valve, in its safety-related position, and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant.

Additionally, the licensee has demonstrated that, due to plant design, the only method available to verify valve closure (its safety-related position) is. leak testing. This valve is not-equipped with valve position indication and some of the required test connections are located inside containment.

15.2.1.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of vcive operability intended by the Code and that the relief thus granted will not endanger life or property.or the common defense and security of the public.

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l 15.2.2 Relief Request-The licensee has requested specific relief from exercising 1 Category A/C valve-V002, containment instrument air supply check, in accordance'with the requirements of Section XI and proposed to verify valve

-closure (its safety-related position) during each refueling outage.

y

'15.2.2.11 Code Requirement. Refer to Appendix A.

15.2.2.2 Licensee's Basis for Requesting Relief. Due to plant design Eit is not-practical to verify by any_ positive means, neither directly nor indirectly, the operability of this normally open check valve per the requirements of IWV-3520.

Valve closure will be verified during the performance of the valve leak rate test which shall be conducted at the same frequency as reactor-

refueling outages per the plant Technical Specifications.

15.2.2.3 Evaluation. We agree with the licensee's basis and, there-fore, feel that relief should be granted from the exercising requi-ements of Section XI for Category A/C valve V002. The licensee has demonstrated that,' due to plant design, the only method available to verify valve closure'(its safety-related position) is leak testing. This valve is not equipped with valve position indication and some of the requi- st connections are located inside' containment.

15.2.2.4 Conclusion. We conclude that the proposed alternate testing of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability. Based on the-considerations discussed above we conclude that the alternate testing ,

proposed-above will give reasonable assurance of valve operability intended

.by the Cede and that the relief thus 9.ented will not endanger life or property or the common defense and security of the public.

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16. CONTAINMENT COOLING AND PURGE SYSTEM 16.1 Category A Valves

~ 16.1 - 1 Relief Request

'r . The licensee has' requested specific relief from exercising and stroke timing Category'A valves V002A and V002B, containment leak rate test isolations, in-accordance with the requirements of Section XI.

16.1.1.1 Code Requirement. Refer to Appendix A.

- 16.1.1.2 Licensee's Basis for Requesting Relief. The operability testing (full or partial stroke) during normal operation or caid shutdown of these valves provides no assurance of an increase in safety. The valves are containment. isolation valves which are normally closed and passive.

-The valves' closed positions will be verified during the performance of the leak rate' tests'at each refueling outage.

16.1.1.3 Evaluation. We agree with the licensee's basis and, therefore, feel that relief should be granted from the exercising and' stroke timing requirements-of Section XI for_ Category A valves V002A and V002B. -These valves are passive valves, in their safety-related positior.,

Land are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. f 16.1.1.4 Conclusion. We conclude that the quarterly stroke and ;

stroke time measurements are meaningless for passive valves. Based on the considerations discussed above we-conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended

~

by the_ Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.

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O APPENDIX A e

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APPENDIX A

1. CODE. REQUIREMENT--VALVES Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code

-(which discusses full stroke and partial stroke requirements) requires that 41 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

~ Category C' valves be_ exercised once every three months, with exceptions as defined in.IWV-3520(b). 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 position required to fulfill their function or to the partial position dur'ng power operation.

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

Subsection IWV-3410(c) requires all Category A and B power-operated valves to be stroke-time tested to the nearest second or 10% of the maximum allowable ownar-specified time.

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2. CODE REQUIREMENTS--PUMPS

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. .' An inservice test shall. be conducted on .all safety related pumps, l nominally once'each month'during normal plant operation. Each inservice itest/shall' include the measurement, observation, and recording of all quantities in. Table IWP-3100-1, except bearing temperature, which shall be

-. measured during at laast one inservice test each year.

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APPENDIX B

1. SER SUPPLEMENT FOR J. M. FARLEY UNIT 2 1.1; Testing of: Valves which Perform a Pressure Isolation Function ar. This SER. supplement addresses all pressure boundary isolation valves

'and their classification at the Joseph M. Farley Nuclear Plant Unit 2.

Reference:

J. P. Knight memorandum to R. L. Tedesco, October 17, 1980.

. PERIODIC LEAK TESTING 0F PRESSURE ISOLATION VALVES There are several safety systems connected to the reactor coolant pressure boundary'that have design pressure below the rated reactor coolant

-system (RCS pressure). .There are also some systems which are rated at full

-reactor pressure on the discharge side of pumps but have pump suction below RCS_ pressure. In order to protect these systems from RCS pressure, two or more isolation valves are placed in series to form the interface between the high pressure RCS-and the low pressure systems. The leak tight integrity of these valves must be ensured by periodic leak testing-to prevent exceeding the design pressure of the low pressure systems thus causing an inter-system LOCA. Periodic leak testing of pressure isolation valves shall be performed after all disturbances to the valve are complete. .The pressure isolation valves to be tested are listed in the technical specifications.

The applicant has agreed to categorize their pressure isolation valves for the safety injection, residual heat removal, and boron injection systems as Category A or AC. These categorizations meet our requirements and we find them acceptable. Pressure isolation valves are required to be Category A or AC and to meet the appropriate valve leak rate test requirements of IWV-3420 of Section XI of the ASME Code except as discussed below. .The allowable leakage rate shall not exceed 1.0 gallon per minute (GPM) for each valve as stated in the technical specifications.

111

The_ applicant-has committed to' test all pressure isolation valves to

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L . the -1.0. GPM_ leak rate criteria.

APCO will leak test the residual heat removal (RHR). suction and low head safety injection (LHSI) to the cold legs pressure isolation valves once per refueling but not after seat disturbances due to flow. Because of L the-system configuration, leak testing of these-valves would be required at -

low pressures at which time both trains of RHR are required to be operable due to technical' specification requirements. :To perform leak testing, one train'of RHR would have to be shut down, placing the plant in a degraded condition. In order to minimize placing the plant in a degraded conditon, APC0 has proposed leak testing on the refueling outage cycle. So as to reduce the: probabilities of an intersystem LOCA occurring in the LHSI to the cold legs,'the applicant has also proposed to. leak test a third check valve:in each line-(prior to leaving the containment). We find this acceptable provided the applicant leak test these valves once each refueling and as described above. It should be noted that the leakage rate measured at a pressure less_than full operating pressure is required to be extrapolated to full pressure using the procedure of IWV-3420 of the ASME Boiler'and Pressure Vessel Code,Section XI. The extrapolated leak rate should be less than 1 GPM.

'APC0 has proposed to-test the RHR pressure isolation valves once per refueling'as described above. The staff finds this acceptable for the following reasons: (1) Full closure of these valves is verified in the control room by direct monitoring position indicators, (2) inadvertant opening 'of these valves is prevented through interlocks which require the plant to be'below RHR operating pressure prior to opening, and (3) gross leakages'due to valve failure would be detected by increasing levels in the pressurizer relief tank. Therefore, full closure of these valves is ,

assured after opening, inadvertant opening is prevented and gross RCS leakages can be readily detected.

Limiting Conditions for Operation (LCO) will be added to the technical specifications which will require corrective action i.e., shutdown or system isolation when the leakage limits are not met. Also surveillance 112

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. requirements, which will. state the acceptable leak' rate testing frequency, 1will.be provided in the technical-specifications.

We conclude that APCO's commitments to periodic leak testing of

. pressure isolation valves between the reactor coolant system and low pressure.. systems will provide reasonable assurance that the design pressure o2 :of the' low' pressure systems will not be exceeded, and thus reduce the probability of an occurrence of an inter-system LOCA. Criterion 14 and 55

~*

,- of the General Design Criteria of Appendix A of 10 CFR 50 partially consider this matter.

(End of .cupplement)

Technical Specification Table 3.4-1 identifies all valves that perform a pressure isolation function. Those valves are:

Q2E11V016A Q2E21V062A

~ Q2E11V001A- Q2E21V062B Q2E11V016B Q2E21V062C Q2E11V001B Q2E21V066A Q2E21V066B Q2E11V051A 02E21V066C ,

Q2E11V051B Q2E21V077C Q2E11V051C Q2E21V078A 02E11V021A 02E21V0788 Q2E11V021B 02E21V078C Q2E11V021C 02E21V079A 02E11V042A Q2E21V079B l

- Q2E11V042B Q2E21V079C l

02E21V077A* Q2E21V032A*

Q2E21V077B* Q2E21V032B*

Q2E21V076A* Q2E21V032C*

Q2E21V076B* Q2E21V037A*

Q2E21V037B*

Q2E21V037C*

113

e

.i0urreview:hasverifiedthatthesevalveshavebeenincludedinthe x

E ISTl program and categorized properly, 1.e., two of.three valves in series t- :

have been= categorized A or AC between the high-pressure system and the

' piping class change il 1The following conditions (a, .b, or c) specify-the leakage test

. frequency.of the valves identified in' Table 3.4-1 and were taken from the a

. Technical Specifications.

r a; -Every refueling outage during startup.

s

'b; Prior.to returning the valve to service following maintenance, repair or replacement work on the valve affecting the seating

~

capability of the valve.

-c. ;Following valve actuation due to automatic or manual action or iflow through the' valve for valves identified in Table 3.4-1 by an asterisk.

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ATTACHMENT-1

. During the course of our review of the Joseph M. Farley Unit 2 IST program we found the following valves that we feel should be. reviewed by the NRC to determine if these valves meet the Appendix J criterion for containment isolation. If any of these valves are determined to be 0 Appendix.J valves then they should be included in the IST program and categorized A,'A/C, or A/E as app 1' cable.

Containment S' pray: V002A and-V0028 V005A and V0058 Service Water: -V010A, V0108, V010C, and V010D V043A, V043B, V043C, and V0430 e

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ATTACHMENT 2

.The1following are Category A, B, and C valves that meet the exercising requirements of the ASME Code,Section XI, and are not.fullzstroke

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 Idaho 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 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.

1. VALVES EXERCISED DURING COLD SHUT 00WNS AND REFUELING 1.1 Relief Request The' licensee has requested specific relief for all valves that can be exercised only during cold shutdowns or refueling outages from the requirements of Section XI,'IWV-3410(g) and IWV-3520(c), and proposed to utilize plant Technical Specifications to determine the conditions for plant startup.

1.1.1 Code Requirement l

IWV-3410(g) and IWV-3520(c) state that when corrective action is

. required as a result of tests made during cold shutdown, the condition shall be corrected before startup. A retest snowing acceptable operation '

shall be run following any required corrective action before the valve is ,

returned to service.

1.1.2 Licensee's Basis for Requesting Relief The plant Technical Specifications provide the requirements and plant conditions necessary for plant startup. The test requirement will be 116

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satisfied before the valve is required for plant operability as defined in the plant Technical-Specifications.

1.1.3 Evaluation We agree.with the licensee's basis and, therefore, feel that relief o should be granted from the requirements of Section XI, IWV-3410(g) and IWV-3520(c), for all valves that can be exercised only during cold shutdowns or' refueling outages. The Joseph M. Farley Unit 2 Technical Specifications have been previously reviewed and approved by the NRC.

1.1.4 _ Conclusion.

We conclude that using plant Technical Specifications to establish limiting conditions for operation meets the intent of the requirements of Section XI and should assure system operability. Based on the considerations discussed above we conclude that the alternate testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense'and security of the public.

1.2 Relief Request The licensee has requested specific relief for all valves that require stroke timing and can be exercised only during cold shutdowns or refueling outages from the requirements of Section XI, IWV-3410(c), and proposed to test these valves once each cold shutdown, not to exceed once each month, if this testing frequency is' required by IWV-3410(c).

e 1.2.1 Code Requirement. I IWV-3410(c) states that if an increase in stroke time of 25% or more from the previous test for valves with stroke times greater than ten seconds or 50% or more for valves with stroke times less than or equal to ten seconds is observed, test frequency shall be increased to once each month until corrective action is taken.

117

. 1.2.2 . Licensee's Basis for Requesting Relief

-~ iValves that:are normally tested during cold shutdown or. refueling cannot-be-tested once each month. Stroking these valves during power operation may. place the plant in an unsafe condition.

~

The test frequency'shall be increased to once each cold shutdown, not e

to exceed once each month.

1.2.3 -Evaluation.

We agree with the licensee's basis and, therefore, feel that relief

~

should be granted from the requirements of Section XI, IWV-3410(c) for all valves that require stroke timing and can be exercised only during cold shutdowns or refueling outages. The licensee has provided the specific technical basis why each of these valves cannot be exercised during power operation.

1;2.4 Conclusion We conclude that the proposed alternate testing frequency of exercising these valves once each cold shutdown, not to exceed once each month if required by IWV-3410(c), meets the intent of Section XI and should-provide sufficient information to determine any valve _ degradation. Based on the considerations discussed above we conclude that the alternate

' testing proposed above will give reasonable assurance of valve operability intended by the Code and that the relief thus granted v!ill not endanger life or property or the common defense and security of the public.

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2. RESIDUAL HEAT REMOVAL / LOW HEAD SAFETY INJECTION 2.1 Category A Valves Category A valves V001A, V001B, V016A and V016B, RHR pump suction from Jreact'or coolant system, cannot be exercised during power operation. These o . valves are~. interlocked shut when RCS pressure is greater than 402.5 psig to prevent overpressurizing the RHR system. Also, the valves are not designed for' partial stroke exercising. These valves will.be full stroke exercised during each cold shutdown.

2.2 . Category B Valves Category B valve V044, RHR heat exchanger discharge to RCS hot leg, cannot always be exercised during power operation. The operability testing (full or partial stroke) of this valve during normal operation could subject the RHR system to pressure in excess of its design. pressure (600 psig). It is assumed for the purpose of the cycling test that the upstrean check valves have failed. Venting of the upstream pressure cannot be accomplished under any conditions because of the radiation hazard to plant personnel.

Once each three (3) months the upstream pressure will be measured. If the pressure is less than or equal to 550 psig, then the valve will be full stroke exercised. If the pressure is greater than 550 psig, the valve will not be exercised that quarter. If the upstream pressure prohibits quarterly testing, the valve will be full stroked at cold shutdowns.

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'3. CONTAINMENT ISOLATION SYSTEM 3.1 ' Category A Valves

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Category A valves V002', H13657, and HV3658, containment air sample

' isolations, cannot be exercised during power operation. The operability testing._(full- stroke) of these valves during normal operation could cause a e

' loss of-system function. 'A. failure while-cycling in a nonconservative

~

position'would cause a loss of the CTMT radiation monitoring system. The valve design does not facilitate a partial stroke test.

-The valves will be full stroke tested for operability at each cold shutdown.

Category A valves V003 and V004, containment differential pressure detector isolations, cannot be exercised during power operation. The

. operability testing (full . stroke) of these valves during normal operation could cause a loss of system function. A failure while cycling in a

.nonconservative position _would cause a loss of the CTMT Pressure Instrument

-System. The valve design does not facilitate a partial stroke test.

'The valves will be full stroke tested for operability at each cold shutdown.

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4. HIGH HEAD SAFETY. INJECTION / CHEMICAL AND VOLUME CONTROL' 4.1' Category A Valves Category A valves V249A and'V249B, reactor coolant pump seal water return isolations,-cannot be exercised during power operation. The a operability testing (full stroke)'of these valves during normal operation

'could cause a loss of system function. .The failure of these valves in a nonconservative position during a cycling test would cause the loss of the RCP seal water cooling function resulting in possible RCP seal damage and possible reactor trip. The design of the valve will not facilitate a partial stroke test. The valves will be full stroke tested for operability at each cold shutdown.

' Category A valves V254, CVCS letdown isolation, and V257 and V258, charging pump containment isolations, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation could jeopardize the charging function of the CVCS.

Failure in a nonconservative position would eliminate the volume control tank as a source of RCS charging water resulting in a loss of pressurizer level. control and possible reactor trip. The design of the valves will not facilitate a partial stroke test. The valves will be full stroke tested for operability at each cold shutdown.

Category A. valves V253A,.V253B, and V253C, regenerative heat exchangrr shell side discharge, cannot be exercised during power operation. Cycling of these valves will cause pressure surges.in the letdown line which can cause Letdown Orifice Relief Valve 8117 to lift. The valves will be full 8

stroke tested for operability at each cold shutdown.

4.2 Category B Valves Category B valve V015, boron recirculation pump discharge to Boron

,. Injection Tank, cannot be exercised during power operation. The operability testing (full stroke) of this valve during normal operation 121 L'

could cause a loss of system function. A failure while cycling in a

.nonconservative (closed) position would render the boron injection system inoperable. The volume of the BIT could not be assured. Valva design does not facilitate a partial stroke test. ,

The valve will be full st-oke tested for cperability at each cold shutdown.

Category B valves V056A and V0568, Boron Injection Tank recirculation, cannot be exercised during power operatior.. The operability testing (full stroke) of these valves during normal operation could cause a loss of system function. A failure while cycling in a nonconservative (closed) position would render the boron injection system inoperable. The volume of the BIT could not be assured. Valve design does not facilitate a partial stroke test.

The valves will be full stroke tested for operability at each cold shutdown.

Category B valve V063, HHSI pump cold leg injection, cannot be exercised during power operation. The operability testing (full stroke) of this valve during normal operation could put the plant in an unsafe condition. The normally closed valve provides back-up safety injection into the RCS bypassing the BIT. Failure during cycling in a nonconservative position would jeopardize the normal safety injection function. The valve design does not facilitate a partial stroke test.

The valve will be full stroke tested for operability at each cold shutdown.

Category B valves V068 and V072, HHSI pump hot leg injection, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation could put the plant in an unsafe condi-tion. These normally closed valves provide back-up safety injection into l the RCS bypassing the BIT. Failure during cycling in a nonconservative l

122 t

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position-would jeopardize'the normal,sa'fety injection function. The valve

'~, odesign;does'not facilitate a partial stroke test.

The. valves'will be full stroke tested for operability at each cold shutdoit

o'; :-Category B valves V376A> and V3768, -Volume C mtrol Tank charging pump

' . suctions,:cannot be exercised during~ power operation. The operability

'" testing (full' stroke) of.these valves-during normal operation could Vjeopardize.the charging function of the CVCS. Failure in a nonconservative

position would eliminate the VCT as a source of RCS charging water causing

-a loss of pressurizer level-control and possible reactor trip. The design of the valves will not: facilitate a partial stroke test. The valves will be full stroke tested for operability at each cold shutdown.

~

- Category B valves.V016A and V0168, HHSI pump discharge to Boron

Injection Tank, cannot be exercised during power operation. The 4 operability testing of these valves during normal operation could put the (plant in an-unsafe condition. Stroking these valves during power operation will lower:the boron concentration of the BIT unless the valves-are isolated from the operating charging pump. The charging pumps are isolated

- by the discharge header isolation valves which could result in the loss of the safety injection function as discussed in Relief Request 3.1.48.

Relief Request 3.1.48 explains; "If a safety injection were to occur during testing of these valves and a particular charging pump were to fail to start, the ability to inject water into the RCS could be lost."

The ' valves will be full stroke' tested for operability at. each cold shutdown.

L.

' Category B valves V259A, V259B, and V259C, charging pumps A, B, and C

~ ~ ~

.. minimum flow cannot be exercised during power operation. The operability testing of these valves during normal operation could cause damage to the charging pumps. If problems occur with the pressurizer level centrol or

, FCV-122, normal charging would isolate. This would result in inadequate cooling and subsequent damage to the charging pumps if the mini-flow valve 123

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for the' pump wa's closed. 'In addition, cycling of the common mini-flow valve (Q2E21V265) causes pressure transients in the reactor coolant pump-

~ seal water return line which.can affect reactor coolant pump seal performance. The valves will be. full stroke tested for operability at each ,

-cold shutdown.

. Category B valve V265, charging ~ pumps common minimum flow, cannot be e

-exercised during power operation. The operability testing of this valve during normal operation could cause damage to the charging pumps. If ~

problems: occur with the. pressurizer level control or FCV-122 normal charging would isolate. This.would result.in inadequate cooling and subsequent. damage to the charging pumps if the mini-flow valve for the pump was closed. In addition, cycling of the common mini-flow valve (Q2E21V265) causes pressure transients in the reactor coolant-pump seal water return line which can affect reactor coolant pump seal performance. The valve

' will be full stroke tested for operability at each cold shutdown.

Category B valves V326A, V326B,.V327A, and V3278, charging pump.

' discharge, cannot be exercised during power operation. The operability testing of these valves during normal operation could cause a loss of system function and-put the plant in an unsafe condition. If a safety injection were to occur during. testing of these valves and a particular

-charging pump'were to fail to start, the ability to inject water into the RCS could be lost. The valves will be full stroke tested for operability at each cold shutdown.

Category B valves V336A and V336B, charging pumps RWST suction, cannot be exercised during power operation. Cycling of these valves causes 2000 ppm borated water to be injected into the RCS from the refueling water storage tank while the valve is being cycled. This results in small baron .

transients in the RCS. The valves will be full stroke tested for operability at each cold shutdown.

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5. MAIN STEAM 5.1 Category B Valves

~

Category B. valves V001A, V001B, V001C, V002A,- V002B, and V002C, main steam isolation ~ valves,~ cannot be full stroke exercised during power

,4 loperation. The operability testing (fcl1 stroke) of the main steam .

Jsolation valves during normal plant _ operation would cause an interruption

~

i in the main steam flow and initiate a' turbine trip. In addition, these

. valves are designed for only'one closure at plant operating conditions, after which maintenance is performed on these valves.

The valves will be partial stroke exercised during plant operation and full stroke exercised every cold shutdown.

Category B valves V003A, V0038, V003C, V003D, V003E, and V003F, main steam isolation valve bypasses, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation is not possible. The bypass valves are interlocked with

.the MSIVs such that when the MSIVs are open, the bypass valves are closed.

The design of the valves will not facilitate a partial stroke test.

The valves will be full stroke tested for operability at each cold shutdown.

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6. CONDENSATE AND FEEDWATER SYSTEM 6.1 Category B Valves

. Category.B valves FCV478, FCV488, and FCV498, main feedwater regulators, cannot'be~ exercised during power operation. .The operability testing (full stroke) of.these valves during normal operation would cause a .

reactor trip because of the interruption of feedwater to the Steam Generators and, in addition, testing would introduce un- eranted transients -

to -the primary as well. as . secondary systems. The design of the valves will not facilitate a partial stroke test.

i

'The valves will be; full stroke tested for operability at each cold

. shutdown.

Category'B valves FCV479, FCV489, and FCV499, main feedwater regulator bypasses, cannot be exercised during power operation. The operability

~

testing-(ftl1 stroke) of these valves during normal operation would cause a reactor. trip because of the interruption of.feedwater to the Steam Generators and, in addition, testing would introduce unwarranted transients to the primary as well as the secondary systems. - The design of the valves will.not facilitate a partial stroke test.

The valves will be full stroke tested for operability at each cold

. shutdown.

6.2 Category B/C Valves Category' B/C valves V001A, V001B, and V001C, main feedwater checks, cannot be exercised during power operation. The operability testing (full stroke) of these valves during normal operation would cause a reactor trip because of the interruption of feedwo:er to the Steam Generators and, in addition, testing would introduce unwarranted transients to the primary as well as the secondary systems. The design of the valves will not facilitate a partial stroke test.

i- 126 r

The valves'will be full stroke tested for operability at each cold shutdown.

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127

V:

7. AUXILIARY FEEDWATER SYSTEM

m. -

7.1 Category.C Valves

. Category C valves'V002A, V002B, V002C, V002E,-and V002G, motor driven auxiliary feedwater pump discharge header checks, cannot be exercised during power operation. The only positive means of exercising these e,

normally closed valves is by directing AFW flow into the Steam Generators.

The initiation of AFW during power operation will result in unnecessary '

thermal shock to the Auxiliary Feedwater-to-Main Feedwater- connection. An tintroduction' of cold water into the secondary system will also cause power transients.

AFW flow will be directed 'through the valves at the design flow rate of the.AFW system at cold shutdown. Verification of this flow through the valves in conjunction with verification that the control valve position is the same for ~each test will- provide assurance that' the valves have opened sufficiently to. perform their function.

Category C valves'V011A, V0118, and V011C, steam generator auxiliary

--feedwater supply checks,'cannot be exercised during power operation. The only positive lmeans of~ exercising these normally closed valves is by

. directing AFW flow into the Steam Generators. The initiation of AFW during power operation 'will result .in unnecessary thermal shock- to the Auxiliary

~

Feedwater-to-Main Feedwater connection. An introduction of cold water into the ~ secondary system will also cause power transients.

AFW ' flow ~ will.-be directed through the valves at the design flow rate

of the AFW system at cold shutdown. Verification of this flow through the '

valves in' conjunction with verification that the control valve position is .

.the'same'for each test will provide assurance that the valves have opened sufficiently to perform their1 function.

Category C valves V002D, V002F, V002H, and V003, turbine driven auxiliary-feedwater pump discharge header checks, cannot be exercised l

128

~during power operation. The only positise means of exercising (full or partial stroke) of these normally closed valves is by directing AFW flow into the Steam Generators. The initiation of AFW during power operation wi11 result in' unnecessary thermal shock to the Auxiliary Feedwater-to-Main

.Feedwater connection. An introduction of cold water into the secondary

-system will also cause power transients. The operation of the Turbine

-o Driven AFW pump during cold shutdown is not possible because Turbine Drive Steam is not available.

c AFW flow will be directed through the valves at the design flow of the AFW system during a mode of operation approaching cold shutdown or leaving cold shutdown in which steam is available. Verification of this flow through the valves in conjunction with verification that the control valve position is the same for each test will provide assurance that the valves have opened sufficiently to perform the.ir function.

Category.C valve V006,. turbine driven auxiliary feedwater pump suction check, cannot be full stroke exercised during power operation. The only positive means ,of demonstrating operability is by verification of flow such that the valve moves to perform its function. A partial stroke test will be accomplished during the quarterly testing of the TDAFW pump. Acceptance of the pump test will provide assurance that the valve has partially

-opened. A full stroke test will be accomplished by providing AFW system design flow into the Steam Generators during a mode of operation approaching or leaving cold shutdown in which steam is available.

. Verification of this flow in conjuction with verification that the control valve position is the same for each test will provide assurance that the valve has opened sufficiently to perform its function.

c Category'C valves V007A and V0078, motor driven auxiliary feedwater

. pump-suction checks, cannot be full stroke exercised during power operation. No instrumentation is provided for the determination of differential pressure across the valves.

A partial stroke test will be accomplished during the quarterly testing of the MDAFW pumps. Acceptance of the pump test will provide 129

py p.

. assurance'.that the valves have partially opened.

A' full stroke test will

[.

.4be accomplished by providing.MDAFW pump design flow to.the Steam Generators.

~

during. cold shutdown. .: Verification that design flow =1s reached provides p- . . .. ,

assurance that the valves have. opened in order to perform their function.

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v-

8. CONTAINMENT PURGE SYSTEM 8.1 : Category A Valves Category A valves V281 and.V282, containment purge supply, and V283

.and V284,~ containment purge exhaust, cannot be exercised during power

=~ ~ operation. .The Technical Specifications require that these containment-

~

purge supply and exhaust valves be closed during' modes 1 through 4.

_ Consequently, no exercising of these valves can occur unless the -plant is

.in mode 5 (cold shutdown) or mode 6'(refueling).

~

These. valves will'be full stroke tested for operability at each cold shutdown.

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131

9. SERVICE WATER SYSTEM 9.1 Category A Valves Ca'tegory A valves V071, reactor coolant pump motor service water supply, and.V072 and V081, reactor coolant pump motor service water return, cannot be exercised.durinp power operation. The operability testing of

these valves during normal operation could cause a loss of system function. The failure of one of_these valves in'a nonconservative (closed)

. position would cause overheating of the RCP motors and would require the shutdown of RC Pumps and of the Reactor. Valve design does not facilitate partial stroke testing.

The valves will be full stroke tested for operability at each cold

. shutdown.

9.2- Category B Valves Category B valves V010A, V0108, V010C, and V0100, containment coolers service water supply, and V043A, V0438, V043C, and V043D, contaiment coolers service water return, cannot be exercised during power operation.

Cycling-of these-valvos can cause a pressure surge in the Service Water System which results in automatically isolating service water to the Turbine Building. The valves will be full stroke tested for operability at

-each cold shutdown.

Category B valves V207A, V2078, V207C, and V2070, containment coolers service water discharge, cannot be exercised during power operation.

Cycling of these valves can cause a pressure surge in the Service Water '

System which results in service water automatically isolating to the -

Turbine Building. The valves will be full stroke tested for operability at each cold shutdown.

Category B valves V514 and V515, turbine building service water supply, train B and A respectively, cannot be exercised during power 132

m

' ~

operation. Cycling these valv s can result in the automatic isolation of

.all~ service water to the turbine building on a high flow signal. With the unit at rated load,-this could cause the. turbine'to trip and/or damage.

', '. major: components of the secondary systems. TF,a valves will be full stroke

testedifor operability at each cold shutdown.

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133

10. COMPONENT COOLING WATER SYSTEM e

, 10.1- Category A Valves Category A valves V082, reactor coolant pump component cooling water I~

supply, V097 and V099, reactor coolant pump bearing component cooling water return, and HV3045 and HV3184,' reactor coolant pump-thermal' barrier

component cooling water return, cannot be exercised during power operation. - The operability testing (full ' stroke) of these varves during normal operation would jeopardize the RCP cooling function. Cycling of the valves would interrupt the CCW supply to the reactor coolant pumps. Also the failure of the valves in a nonconservative position during the cycling test.would result in a loss of the.systemLfunction. This would require stopping the reactor coolant pumps to prevent overheating and damage and

.would: result in'a reactor shutdown. The design of the motor-operated

-valves will not facilitate a partial stroke test.

The valves will be full stroke tested for operability at each cold shutdown.

Category A valves HV3095, excess letdown-heat exchanger CCW supply, and HV3067 and HV3443, excess' letdown heat exchanger CCW return, cannot be exercised during power operation. Cycling these valves causes pressure and flow variations in the CCW system which result in the automatic isolation of CCW to reactor coolant pump's thermal barriers and oil coolers. If flow to the RCP's thermal barriers and oil coolers is not quickly re-established ithe reactor would trip because the RCP's would have to be shutdown to

. prevent damage to the bearings and/or seals. The valves will be full 3

stroke tested for operability at each cold shutdown.

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11. INSTRUMENT AIR SYSTEM 11.1 Category A Valves Category A valve HV3611, containment instrument air supply, cannot be exercised during power operation. The operability testing (full stroke) of a this valve during normal operation would cause an interruption of instrument air supply to instruments and equipment associated with the RCS. Also, a failure in a nonconservative position during a cycling test would cause a complete loss of instrument air supply to the containment resulting in a loss of RCS control which could cause a reactor trip. The design of the valve will not facilitate a partial stroke test.

The valve will be full stroke tested for operability at each cold shutdown.

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h_

~ ATTACHMENT 3

The P& ids listed.below were.used during the course of this review.

-System P&ID' Revision

. Component Cooling. Water 205002 Sh. 1 3 e Sh. 2 4 Service Wate'r- 205003 Sh. 1 6

/ .

Sh. 2 8

-Radioactive Drains and Vents 205004 Sh. I 10 Auxiliary Feedwater System 205007 8

Sampling' System 205009 Sh. 1~ 11 Sh. 2 10

. Containment Cooling and Purge' 205010 Sh. 1 4 Sh. 2 6 River-Water, Service Water, and 200013 Sh. 3 3 Circulating Water- Sh. 8 7 Combustible Gas Control 205019 7 Penetration Filtration 205022 5 Main.and Auxiliary Steam 205033 Sh. 1 7 Sh. 2 9 Instrument Air'. 205034 Sh. 2 2 Sh. 4 1

. Service Air 205035 Sh. 1 4

' Reactor Coolant' 205037 Sh. 2 9

,- . Safety Injection 205038 Sh. 1 7 Sh. 2 5 Sh. 3 6 Chemical and Volume Control 205039 Sh. 1 .10 .

Sh. 2 8 Y Residual Heat Removal 205041 6

. Waste Processing 205042 Sh. 1 8

=.

' Spent Fuel Pool Cooling 205043 11 Demineralized Water 205047 11 Main Feedwater 205073 5 136.

ATTACHMENT-4

~

Item 1. concerns valves that are never full stroke exercised or have a

. testing interval-greater than each refueling outage.

t-Item 2 concerns relief requests containing insufficient technical 0,. information where relief is not recommended.

11.1 Relief. Request 3.1.31, Valve Testing Program, V014 partial-stroke exercise only.

1.2 -Relief Request 3.1.15, Valve Testing Program, V032A, V0328, and V032C partial-stroke exercise only.

1.3 Relief Request 3.1.34, Valve-Testing Program, V037A, V037B, and V037C partial stroke exercise only.

2.1 Relief Request ~3.1.23, Valve Testing Program, V025A and V0258 remote position indication. (3.1.2) 2.2 Relief Request 3.1.23,LValve Testing Program, V003A and V003B remote

-. position indication. (4.1.2) c e

137

r ATTACHMENT 5 The following items were discussed via telephone with the licensee's representative'(John Churchwell) on July 12, 1982, and may appear as differences between this report and their IST program. The licensee agreed to modify their IST program to reflect these changes.

a '

l'. Residual Heat Removal valve V044, RHR heat exchanger discharge to RCS hot leg, will remain Category B in the-IST program. This '

does not agree with the minutes of the working session.

Technical Specification Table 3.4-1, REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVES, incorrectly identified V044 as a pressure boundary isolation valve and was utilized as c reference at the working' session. A corrected page, Table 3.4-1, has been submitted to and approved by the NRC.

= 2. Service water valves QV206A-D, containment cooler service water supply checks,'will not be included in the IST program. The licensee stated that these valves are always open and passive because service water flow is always maintained through the

. containment coolers. The containment coolers are placed in service and secured by starting or stopping the associated cooling fan. Additionally, the proper service water flow rate is verified through the coolers per Technical Specifications every 31 days.

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ML20028B498

Text

Title:

Reference:

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