ML20029C516

Technical Evaluation Rept Pump Valve IST Program Quad Cities Station Units 1 & 2.

ML20029C516
Person / Time
Site:	Quad Cities
Issue date:	08/31/1993
From:	Hartley R, Ransom C EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20029C517	List: ML20029C516
References
CON-FIN-L-2594 EGG-RTAP-10810, TAC-M85762, TAC-M85763, NUDOCS 9311150243
Download: ML20029C516 (37)

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ATTACHMENT 2 EGG-RTAP-10810 i

TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM QUAD CITIES STATION UNITS 1 AND 2 Docket Numbers 50-254 and 50-265 C. B. Ransom R. S. Hartley Published August 1993 Idaho Ma:ional Engineering Laboratory ,

D&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D. C. 20555 Under DOE Contract Number DE-AC07-761001570 FIN Number L2594, Task Order Number 5 TAC Numbers M85762 and M85763 i

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ABSTRACT This report presents the results of our evaluation of the Qumd Cities Station, Units 1 and 2, Inservice Testing program for safety-related pumps and valves.

PREFACE This report is part of the " Technical Assistance in Support of Operating Reactors Inservice Testing Relief Requests" program conducted for the  ;

U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation,  !

Mechanical Engineering Branch, by EG&G Idaho, Inc., Regulatory and Technical l Assistance Programs.

FIN No. L2594 B&R No. 920-19-05-02-0 Docket Nos. 50-254 and 50-265 TAC Nos. M85762 and M85763 ii

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. CONTENTS ABSTRACT ................................ 11 PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

1. INTRODUCTION ............................ I 1.1 IST Program Description . . . . . . . . . . . . . . . . . . . . I 1.2 IST Requirements ....................... I 1 1.3 Scope and Limits of the Review ................ 2 l

2. PUMP TESTING PROGRAM ........................ 3  !

2.1 General Pump Relief Requests ................. 3 1

2.1.1 Pump Vibration Measurement Program . . . . . . . . . . . 3 2.1.2 Bearing Temperature Measurements . . . . . . . . . . . . 5  !

I 2.2 Standby Liquid Control Pumps .................

6 2.2.1 Inlet and Differential Pressure Measurement ...... 6 l 2.3 High Pressure Coolant Injection Pumps . . . . . . . . . . . . . 7 2.3.1 Vibration Acceptance Criteria ............. 7

3. VALVE TESTING PROGRAM ....................... 10 1

3.1 Various Residual Heat Removal Service Water System ...... 10 i 3.1.1 Excess Fl ow Check Valves . . . . . . . . . . . . . . . . 10 3.1.2 Stroke Time Reference Values . . . . . . . . . . . . . . 11 I 3.1.3 Corrective Actions for Valves Tested at Cold Shutdowns . 14 3.2 Main Steam System . . . . . . . . . . . . . . . . . . . . . . . 15 3.2.1 Category A Valves ................... 15 3.2.2 Category B and B/C Valves ............... 16

' 3.2.3 Category B/C and C Valves ............... 19 3.3 Standby Liquid Control System . . . . . . . . . . . . . . . . . 21 3.3.1 Category A/C Valves .................. 21 3.4 High Pressure Coolant Injection System ............ 22 3.4.1 Category A and A/C Valves ............... 22 3.4.2 Category C Valves ................... 24 l

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. 3.5 Feedwater System ....................... 26 i

3.5.1 Category A and A/C Valves ............... 26 APPENDIX A - IST PROGRAM ANOMALIES ................... A-1 l

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I l l TECHNICAL EVALUATION REPORT

- PUMP AND VALVE INSERVICE TESTING PROGRAM i 00AD CITIES STATION UNITS 1 AND 2

1. INTRODUCTION

! This report provides the results of the technical evaluation of certain 1

relief. requests from the pump and valve inservice testing (IST) program for Quad Cities Station, Units 1 and 2, submitted by Commonwealth Edison Company.

! Section 2 presents Commonwealth Edison Company's bases for requesting

.i relief from the requirements for pumps followed by.an evaluation and

I conclusion. Saction 3 presents similar information for valves. The pumps and valves covered by the evaluations in this report are for both Quad Cities Station, Units 1 and 2, unless specifically identified otherwise.

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Appendix A lists program inconsistencies and omissions, and identifies needed program changes.

l 1.1 IST Proaram Descriotion l

Commonwealth Edison Company submitted Revision 4 of their IST program (j with a letter to the Nuclear Regulatory Comission (NRC) dated January 7, l

1992. The IST program is dated October 1, 1992, and covers the third ten-year 4

interval starting February 18, 1993, and ending February 17, 2003, for Unit 1 j and starting March 11, 1993, and ending March 10, 2003, for Unit 2. The l

! licensee's program is based on the requirements of the American Society of j Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),

, Section XI,1986 Edition and the Code of Federal Regulations (CFR),

j 10 CFR 50.55a.

1.2 IST Reauirements l The Code of Federal Regulations, 10 CFR 50.55a(f), states that IST of i certain ASME Code Class 1, 2, and 3 pumps and valves will be done according to

the ASME Code,Section XI, Subsections IWP and IWV, except where the j alternative is authorized :,r relief is granted by NRC in accordance with

.1 10 CFR 50.55a(a)(3)(1), (a)(3)(ii), or (f)(6)(i). Commonwealth Edison Company l requests relief from the ASME Code testing requirements for specific pumps and

! valves. Certain of these requests are evaluated in this Technical Evaluation

, Report (TER) using the acceptance criteria of the Standard Review Plan, i Section 3.9.6, NRC Generic Letter No. 89-04 (GL 89 04), "Guidaace on Developing Acceptable Inservice Testing Programs," and 10 CFR 50.55a. Other i requests.in the licensee's IST program that are not evaluated in this TER, may be granted by provisions of GL 89-04 or include non-Code Class 1,-2, or 3 components.

In rulemaking to 10 CFR 50.55a effective September 8,.1992, (See 57 i Federa7 Register 34666), the 1989 edition of ASME Section XI was incorporated in 10 CFR 50.55a(b). The 1989 edition provides that the rules for IST of pumps and valves shall meet' the requirements set forth in ASME/ ANSI Operations..

i and Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-J

Water Reactor Power Plants," and Part 10 (OM-10), " Inservice Testing of Valves i in Light-Water Reactor Power Plants." Pursuant to (f)(4)(iv), portions of j editions or addenda may be used provided that all related requirements of the

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i t respective editions or addenda are met, and subject to Comission approval.

Because the alternatives meet later editions of the Code, relief is not required for those inservice tests that are conducted in accordance with OH-6 and OH-10, or portions thereof, provided all related requirements are met.

The use of later editions or portions of later editions, is subject to i Comission approval. The TER recomends such approval for several relief requests. Whether all related requirements are met is subject to NRC inspection.

1.3 Scone and Limits of the Review '

The scope of this review includes, but is not limited to, the cold shutdown justifications and relief requests for safety-related Code Class 1, 2, and 3 pumps and valves submitted with the licensee's IST program. Other portions of the program, such as general discussions, pump and valve test tables, etc., are not necessarily reviewed. Endorsement of these aspects of the program by the reviewer is not stated or implied.

The Main Steam, Reactor Feedwater, and High Pressure Coolant Injection (HPCI) Systems were specifically reviewed for scope and completeness of the licensee's IST program. The system drawings were reviewed and many valves evaluated to determine if they perform a safety-related function. Although this review was more detailed than normally performed, it was a spot check and does not constitute a comprehensive system review or endorsement of the j licensee's scope. 1 The evaluations in this TER are applicable only to the components or groups of components identified by the submitted requests. Further, the evaluations and recomendations are limited to the requirement (s) and/or function (s) explicitly discussed in the applicable TER section. For example,  ;

the results of an evaluation of a request involving testing of the containment  !

isolation function of a valve cannot be extended to allow the test to satisfy I a requirement to verify the valve's pressure isolation function, unless that  ;

extension is explicitly stated. l i

Comonwealth Edison Company provided several cold shutdown justifications l for exercising Category A, B, and C valves during cold shutdowns and refueling j outages instead of quarterly. Valves identified to be tested during cold j shutdowns need not be tested if testing was performed within three months of i the cold shutdown in accordance with Paragraphs IWV-3412(a) and -3522. These i justifications were reviewed and appear to be acceptable except as noted in l Appendix' A. l i

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2. PUMP TESTING PROGRAM The following relief requests were evaluated against the requirements of the 1986 Edition of the ASME Code,Section XI, 10 CFR 50.55a, and applicable NRC positions and guidelines. A summary is presented for each relief request followed by the licensee's basis for relief and the evaluation with the reviewer's recommendations. The requests are grouped according to topic or system.

2.1 General Pumo Relief Reauests 2.1.1 Pumo Vibration Measurement Proaram 2.1.1.1 Relief Reauest. RP-00A requests relier from the pump vibration displacement measurement requirements of Section XI, Paragraph IWP-4510, for all pumps in the IST program. The licensee proposes a program similar to OH-6 to measure vibration velocity for pumps whose speed is 600 rpm or greater and to apply acceptance criteria based on multiples of the vibration reference value along with absolute maximum limits. The high pressure coolant injection (HPCI) pump vibration acceptance criteria portion of relief request RP-00A is evaluated separately in Section 2.3.1.1 of this report.

2.1.1.1.1 Licensee's Basis for Reouestino Relief--The following text is quoted from relief request RP-00A in Revision 4 of the Quad Cities IST j program:

l Low amplitude, high frequency vibration due to misalignment, imbalance, l or bearing wear is difficult to detect via vibration amplitude measurements when pump speed is greater than or equal to 600 RPM.

Vibration velocity measurements are much more sensitive to small changes that are indicative of developing mechanical problems. Vibration velocity is a far more informative reading because it accounts for both displacement and frequency range. A vibration monitoring program based on velocity is more comprehensive than that required by the Code.

Alternate Testino: Pump vibration measurements will be taken in vibration velocity (inches per second) if the pump speed is greater than or equal to 600 RPM. The allowable ranges of vibration velocity will be based on Table 1.

NOTE:

There are no safety related centrifugal pumps that operate at speeds < 600 RPM at Quad Cities. There are no safety related vertical line shaft pumps at Quad Cities.

Table 1 ALLOWABLE RANGES OF VIBRATION VELOCITY Acceptable Required Pump Type Range Alert Range Action Range Centrifugal with 1 2. 5 V, or > 2.5 V, and > 6.0 V, or speed > 600 RPM 1 0.325 ips 16.0 V, or > 0.700 ips (except HPCI) whichever is less > 0.325 ips and whichever is less i 5 0.700 ips j_ whichever is less 3

s Acceptable Required Pump Type Range Alert Range Action Range Centrifugal with 5 1. 5 V, or > 1.5 V, and > 2. 5 V, o r speed 2 600 RPM s 0.425 ips 5 2.5 V, or > 0.700 ips (HPCI) whichever is less > 0.425 ips and whichever is less 5 0.700 ips whichever is less Reciprocating s 2.5 V, > 2.5 V, and > 6.0 V, s 6.0 V, Gear s 2.5 V, > 2.5 V, and > 6.0 V, s 6.0 V, V,: vibration reference value ips: inches per second mils: thousandths of an inch (applies to low speed pumps only) 2.1.1.1.2 Evaluation--The Code requires measurement and analysis of pump vibration displacement quarterly. This helps to identify pump bearing degradation and assess operational readiness. The licensee proposes to measure pump vibration velocity for pumps whose speed is 600 rpm or greater and to apply acceptance criteria based on multiples of the vibration reference value along with absolute maximum limits. The proposed multiples and limits I

for the HPCI pumps are different than for all other centrifugal pumps. The HPCI pump vibration acceptance criteria portion of relief request RP-00A is evaluated separately in Section 2.3.1.1 of this report.

Section XI does not provide allowable ranges for vibration velocities and since the relationship between displacement and velocity is frequency dependent, a mathematical conversion of the Code displacement ranges is not appropriate. OM-6 provides a program for measuring and assessing pump vibration that incorporates vibration velocity for determining pump operational readiness. The licensee's proposed acceptance criteria appears to conform with the vibration acceptance criteria of OM-6, except for the proposed criteria for the HPCI pump.

In rulemaking to 10 CFR 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 10 CFR 50.55a(b). The 1989 Edition of Section XI provides that the rules for IST of pumps are as specified in OM-6. 10 CFR 50.55a(f)(4)(iv) provides that IST of pumps may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

OM-6, Paragraph 5.2, permits measuring pump bearing vibration velocity and Paragraph 6.1 provides vibration velocity acceptance criteria. The NRC staff imposed no limitations to OM-6 associated with vibration velocity measurements. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required. Therefore, we recommend that the alternative be approved pursuant 4

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l to 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related requirements, which include Paragraphs 4.6.1, 4.6.4, and 6.1 of OH-6. Whether all related requirements are met is subject to NRC inspection. I 2.1.2 Bearina Temoerature Measurements 1

2.1.2.1 Relief Reouest. RP-00B requests relief from the bearing i temperature measurement requirement of Section XI, Paragraph IWP-3100, for all pumps in the IST program. The licensee proposes to monitor pump vibration velocity in lieu of taking annual bearing temperature measurements. l l

2.1.2.1.1 Licensee's Basis for Reouestina Relief--The following '

text is quoted from relief request RP-00B in Revision 4 of the Quad Cities IST program:

Pump bearing vibration monitoring can be used to detect: worn bearings, misalignment of bearings, a change in the balance of rotating parts, a change in hydraulic forces, and general pump integrity. Quarterly pump bearing vibration measurements, combined with an observation of I lubricant level / pressure, are more sensitive than bearing temperature measurements to the types of problems that may be exhibited by increased I bearing temperature. Since bearing vibration monitoring is more sensitive and is performed more frequently, there is no need to measure i bearing temperature. I Given controlled environmental conditions, bearing temperature )

measurements may be capable of detecting pump degradation, but the following problems exist in a power plant setting: 1) Many bearings are lubricated by the pumped fluid; and the temperature of the pumped fluid will change depending on the season. 2) Long run times to stabilize I bearing temperature are not practical for the HPCI pump (during the  !

summer, the suppression pool temperature may approach the 95*F limit l

because the HPCI turbine exhaust is directed to the suppression pool). '

These environmental condition variables make it extremely difficult, if not impossible, to evaluate bearing temperature test results.

Bearing temperature measurements could potentially be misinterpreted and they do not provide any additional information concerning the pump's condition. This inservice test quantity is impractical to measure and evaluate.

Alternate Testino: In comparison to the other tests used to detect mechanical and hydraulic change, a bearing temperature test does not provide additional, meaningful information. Vibration velocity measurements are much more sensitive to pump degradation. No alternate testing is appropriate.

2.1.2.1.2 Evaluation--The Code requires annual measurement of pump bearing temperatures to aid in detection of bearing degradation.

However, it is widely recognized that pump bearing temperatures taken annually are unlikely to aid in the detection of bearing degradation. A temperature rise in a failing or severely degraded bearing usually occurs only just before 5

1 failure. This makes de'tecting impending bearing failure by annual bearing temperature measurement very unlikely. Bearing temperatures taken yearly .

1 provide little statistical basis for determining the incremental degradation 1 of a bearing. Measurements of pump bearing vibration velocity provides much better information for assessing pump bearing condition than annual measurement of bearing temperatures in accordance with Section XI.

OM-6 does not require measurement of pump bearing temperatures, but relies on the vibration measurement program to monitor for pump mechanical degradation. The licensee proposes to measure and assess pump vibration in lieu of bearing temperature. That proposal is consi. stent with the requirements of OH-6, and therefore, provides an acceptable level of quality and safety. Rulemaking to 10 CFR 50.55a effectin September 8,1992, allows use of portions of OM-6, provided that all related requirements are met.

There are no specific related requirements in OH-6 for the deletion of annual bearing temperature measurements.

Based on the rulemaking effective September 8, 1992, relief is no longer required from the requirement to measure pump bearing temperatures.

Therefore, we recommend that the alternative be approved pursuant to 10 CFR 50.55a(f)(4)(iv).

2.2 Standby Liouid Control Pumos 2.2.1 Inlet and Differential Pressure Measurements 2.2.1.1 Relief Reauest. RP-llA requests relief from the inlet and differential pressure measurement requirements of the Section XI, Paragraph IWP-3100, for the standby liquid control (SLC) pumps, 1102A and 1102B. The licensee proposes to use pump discharge pressure and flow rate to monitor pump hydraulic condition.

2.2.1.1.1 Licensee's Basis for Reauestina Relief--The following text is quoted from relief request RP-llA in Revision 4 of the Quad Cities IST program:

The SLC inservice te.it is conducted using the SLC test tank (1104 9 B-7), rather than the SLC tank (1103 9 A-10). The test tank is filled ,

at the start of the test (minimum water level 16"), and the test tank l level remains virtually constant throughout the inservice test. Inlet pressure instrumentation was not installed for the SLC pumps. Inlet prbssure before the test (P.) could be calculated based on test tank level, but this calculated hydrostatic pressure is meaningless once the pump starts. The SLC pumps are positive displacement pumps. The performance of the SLC pumps is not sensitive to changes in pump inlet pressure. SLC discharge pressure can be substituted for differential  !

pressure, and the ability to detect changes in hydraulic performance I will not be affected. OH-6 recognizes the validity of this approach and requires that outlet pressure be measured in lieu of differential pressure.

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. 1 4 Alternate Testina: Discharge pressure will be substituted for differential pressure in any test requirements or acceptance criteria for the SBLC pumps.

2.2.1.1.2 Evaluation--The Code requires measurement of pump inlet and differential pressures to help assess pump hydraulic condition and detect degradation.. These SLC pumps are positive displacement pumps. The hydraulic performance of these pumps is substantially different than the performance of '

centrifugal pumps. Inlet pressure does not affect the flow rate or discharge pressure of these pumps, as long as the NPSH requirements are met. The '

discharge pressure is determined solely by the backpressure of the flow path into which the pump is pumping. As long as-the pump is in its designed operating range, pump flow rate is not significantly affected by discharge pressure. For these pumps, differential pressure and flow rate are not dependant variables as they are for centrifugal pumps. Therefore, measuring or determining inlet and differential pressures would not contribute meaningful data to utilize in monitoring pump condition and detecting degradation. Further, OH-6 does not require measurement of pump inlet or differential pressures for positive displacement pumps.

The licensee's proposal to substitute pump discharge pressure for differential pressure in the test requirements and acceptance criteria for '

these positive displacement pumps appears to meet the requirements of OM-6 and .

provides sufficient information to adequately monitor pump condition.

Rulemaking to 10 CFR 50.55a allows use of portions of OM-6, provided that all related requirements are met. Therefore, the licensee may measure discharge pressure in lieu of inlet and differential pressure according to the program in OM-6 provided the discharge pressure-related requirements of Paragraphs ,

4.6.1, 4.6.2, and 6.1 are met.

Based on the rulemaking effective September 8,1992, relief is no longer  !

required, related to inlet and differential pressure measurements for positive -l displacement pumps. Therefore, we recommend that the alternative be approved  !

pursuant to 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related requirements of OM-6. Whether all related requirements are met is subject to NRC inspection.

2.3 Hiah Pressure Coolant Iniection Pumos 2.3.1 Vibration Accentance Criteria 2.3.1.1 Relief Reauest. RP-00A requests relief from the pump vibration acceptance criteria requirements of Section XI, Table IWP-3100-2, for the HPCI pumps, -2302. The licensee proposes to measure pump vibration velocity and to apply acceptance criteria with an Alert Range absolute limit of 0.425 in/sec.

The vibration velocity portion of relief request RP-00A is evaluated separately in Section 2.1.1.1 of this report.

2.3.1.1.1 Licensee's Basis For Reauestina Relief--The following text is quoted from relief request RP-00A in Revision 4 of the Quad Cities IST program:

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e The specific limit's assigned to the HPCI pumps are based on extensive experience with these pumps and the inherent high vibration levels associated with pumps of this design. The HPCI pump impellers have been modified to reduce vibration levels (-50%) yet absolute levels remain high. The turbine and pump rotating components have been re-balanced and extensive realignment work has been performed with little overall improvement in vibration levels. The station is confident that the existing vibration levels are not indicative of a degraded condition.

Should the station be successful in reducing the vibration levels consistently below 0.300 ips, this relief request will be withdrawn.

Alternate Testino: Refer to the alternate testing for RP-00A as previously described in Section 2.1.1.1.1 of this TER.

2.3.1.1.2 Evaluation--The vibration acceptance criteria are established so that. appropriate corrective actions are taken on pumps with significant degradation. RP-00A requests relief to measure vibration velocity in lieu of displacement. This is authorized pursuant to 10 CFR 50.55a(f)(4)(iv), provided- the licensee implenents all related requirements of OM-6 (See Section 2.1.1.1 of this report). The OM-6 vibration velocity acceptance criteria are given in Table 3a. The absolute limits of OH-6, Table 3a, are set at levels that indicate significant degradation for most pump installations, regardless of the reference vibration.value. The licensee proposes to extend the Alert Range absolute. limit from 0.325 in/sec to 0.425 in/sec.

This proposal was previously covered under Section XI, Paragraph IWP-3210, which states in-part: "If these ranges cannot be met, the Owner shall specify in the record of test (IWP-6000) the reduced range limits to allow the pump to fulfill its function, and those ranges shall be used in lieu of the ranges given in Table IWP-3100-2." However, OM-6 does not permit the owner to expand the Code allowable ranges without submitting and receiving approval in a relief request. The licensee has perfomed extensive analysis and maintenance of this pump installation to reduce the high vibration levels.

The HPCI pump impellers have been replaced, the turbine and pump have been re-balanced, and components have been re-aligned. The HPCI pump vibration levels have been reduced, however, they are still high and the vibration measurements still frequently exceed the Alert Range' absolute limit of OM-6, Table 3a. The licensee's analysis indicate that the high vibration levels are due to system configuration and design and that they do not indicate pump mechanical degradation or represent phenomena that could prevent the pump from performing its intended function. The licensee's proposed vibration acceptance criteria should result in corrective action being taken on a pump with significant degradation. Therefore, the proposal should provide an acceptable level of quality and safety.

The licensee propc,es to comply with the OH-6 Required Action Range absolute vibration limit. Compliance with the OH-6 Alert Range absolute limit could result in corrective actions being required for a pump that is in good operating condition. Increasing the test interval when the OM-G Alert Range absolute vibration limit is exceeded would result in additional testing of the pump, which could cause accelerated wear and tear. Increasing the test 8

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frequency for a pump that is operating acceptably would be an unusual hardship

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for the licensee and would not significantly increase the level of quality and  :

, safety. l

Based on the determination that compliance with the Code would be a l

. hardship without a commensurate increase in the level of quality and safety l l and considering the proposed testing, we recomend that the alternative be 7 authorized pursuant to 10 CFR 50.55a(a)(3)(ii).  !

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l- 3. VALVE TESTING PROGRAM The following relief requests were evaluated against the requirements of j the 1986 Edition of the ASME Code,Section XI, 10 CFR 50.55a, and applicable NRC positions and guidelines. A summary and the licensee's basis for each relief request is presented followed by an evaluation and reviewer's i recommendation. Relief requests are grouped according to system and Code Category.

3.1 Various Systems i 3.1.1 Excess Flow Check Valves 3.1.1.1 Relief Reauest. RV-00B requests relief from the test frequency 3 requirements of Section XI, Paragraph IWV-3521, for all of the excess flow I

check valves in the IST program. The licensee proposes to exercise these

" valves closed each refueling outage in accordance with plant Technical Specification (TS) 4.7.D.

3.1.1.1.1 Licensee's Basis For Reauestina Relief--The following

] text is quoted from relief request RV-008 in Revision 4 of the Quad Cities IST 4 program:

These valves are tested in accordance with the TS and Updated Final s Safety Analysis Report. It is impractical to perform a stroke test

during normal operation or Cold Shutdown because safety related

j. instrument channel (s) would have to be taken out-of-service to perform j the test.

1 f Alternate Testina: Excess flow check valves will be exercised closed I with the reactor vessel at normal operating pressure (1000 psi) at the 4

end of each reactor refueling outage, in accordance with TS 4.7.D (page l 3.7/4.7-32, the last paragraph) and Updated Final Safety Analysis Report

Section 5.2.2 (page 28).

3.1.1.1.2 Evaluation--The Code requires a' full-stroke exercise of safety-related check valves quarterly or during cold shutdowns if quarterly

testing is impractical. This testing is to demonstrate that the valves are j capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to exercise these valves closed 1

each reactor refueling outage utilizing the procedures and acceptance criteria l j outlined'in the plant TS.

These are excess flow check valves on instrument sensing lines which penetrate the primary containment. Their function is to provide containment

' isolation by closing to prevent excessive flow in case of a sensing line rupture. The testing specified in Quad Cities TS is a modified leak test which is performed once each reactor refueling outage. Performance of valve closure verification on a quarterly or cold shutdown basis is impractical since this would isolate various instruments and could result in loss of l control signals to vital instrumentation and subsequent reactor scram or j 3

initiation of automatic safety systems. Given these concerns, testing these l 10 l

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]1 valves each quarter or during cold shutdowns would be burdensome to the licensee, i

In rulemaking to 10 CFR 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 10 CFR 50.55a(b). The 1989 l Edition of Section XI provides that the rules for inservice testing of valves are as specified in OH-10. 10 CFR 50.55a(f)(4)(iv) provides that IST of

, valves may meet the requirements set forth in subsequent editions and addenda 3

that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

i 0M-10, Paragraph 4.3.2.2, permits deferral of full-stroke exercising i until refueling outages when this exercising is not practicable during plant i operation or cold shutdowns. The NRC staff imposed no limitations to OH-10 i associated with the test frequency requirements for check valves.

Accordingly, the licensee's proposed alternate testing is in compliance with i l the rulemaking effective September 8, 1992, and relief is not required. '

Therefore, we recommend that the alternative be approved pursuant to

, 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related requirements, whicF include Paragraphs 4.3.2.2(h) and 6.2 of OH-10. Whether all related requirements are met is subject to NRC inspection.

i 3.1.2 Stroke Time Reference Values 3.1.2.1 Relief Reauest. RV-000 requests relief from the stroke time

corrective action requirements of Section XI, Paragraph IWV-3417(a), for all

, of the power-operated valves in the IST program. The licensee proposes to

! base corrective action requirements on deviation from reference stroke times, i

established when the valves are known to be operating acceptably, in lieu of

comparing stroke times to the previous measurements.

I 3.1.2.1.1 Licensee's Basis For Reouestina Relief--The following i text is quoted from relief request RV-000 in Revision 4 of the Quad Cities IST 1 program:

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The Code requirement for more frequent testing is based on a comparison i between the current stroke time and the previous stroke time. This

approach allows the threshold for more frequent testing to slowly creep

! over time, if there are small changes between the current stroke time up'd an the previous stroke time. A variable limit based on the previous

( stroke time is difficult to administer because the limit is not a

permanent entry in the test procedure.

Conversely, a fixed limit based on a reference value stroke. time will yield a tighter band of acceptable stroke times and is easy to administer. It is more conservative because it is not subject to creep due to gradual degradation and requires the valve to be continually

assessed against limits established when the valve is performing l acceptability.

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Alternate Testina: Quad Cities Station will establish a reference value stroke time when the valve is known to be operating acceptably. When a reference value may have been affected by repair or routine servicing of the vaive, a new reference value will be determined or the previous-reference value will be reconfirmed.

The limiting value for full-stroke (T )m are established using multipliers and the r:!ference stroke time value (T,). - For power operated valves with a T, s 1s, T - 2s per relief request RV-00C. For power operated valves with a T, > ls, but s los, then T. - 2.0T,. For power operated valves with a T, > los, T. = 1.75s. In all cases, if a limiting value for full-stroke as defined by TS, FSAR, or design basis documents is less than the value calculated using the multipliers, then the limiting value will be used.

The following terms have been defined:

T,  : Reference value stroke. time T.,  : Full stroke time as measured during the exercise test T, : Maximum stroke time (limiting value for full-stroke as defined by Technical Specification, FSAR, Design Base Documents)

The test frequency will be increased to monthly if T., is in the Alert Range, and the valve will be declared inoperable if T,, is in the Required Action Range in accordance with Table 1.

This approach is consistent with NRC Generic Letter 89-04, Attachment 1, Position 5. Also, see the October 25, 1989, Minutes of Public Meetings on Generic Letter 89-04, response to Question 40, page 26.

Table 1 POWER OPERATED VALVE STROKE TIME LIMITS Ref. Acceptable Alert Req'd  !

Stroke Range . Range Action Time (seconds) (seconds) Range (secs) (seconds)

T, s 1 T, s 2.0 Not defined, see T., > 2.0

. Relief Request RV-00C T, > 1 0.5T,1 T,,1 1.5T, T,,< 0.5T, T , > 2. 0T, o r T.

and 1.5T, < Tu 5 2.0T, whichever is less T,s 10 T, > 10 0.75T,1 T,,1 1,25T, T,, < 0.75T, T., > 1. 75T, o r > Tm 1.25T, < T., s 1.75T, whichever is less 12

MSIV's ONLY Ref. Acceptable Alert Reg'd Stroke Range Range Action Time (seconds) (seconds) Range (secs) (seconds)

Any 3.0 s T,,< 5.0 Not defined T, > 5.0 or < 3.0 3.1.2.1.2 Evaluation--The Code requires stroke timing of power-operated valves quarterly, or during cold shutdowns if quarterly testing is impractical. This testing helps to identify valve degradation. Position 5 of GL 89-04 provides guidance for developing limiting v41aes of full-stroke times for power-operated valves. It states in part, "The limiting value of full-stroke time should be based on the valve reference or average stroke time of a valve when it is known to be in good condition and operating properly."

The licensee proposes to determine reference stroke times for valves when they are known to be operating acceptably. Stroke times measured during testing will be compared to those reference values and the acceptance criteria. Corrective action, as specified in Paragraph IWV-3417(a), will be taken if required. This is consistent with the recommendations of GL 89-04, Position 5, and is an improvement over the stroke time measurement requirements of Section XI because it does not permit extensive creeping of valve stroke times due to gradual degradation. Therefore, the licensee's proposal to use reference stroke times for comparison with test data should provide an acceptable level of qualitv and safety.

OH-10, Paragraph 4.2.1.8, provides acceptance criteria for valve stroke times based on stroke time reference values. The staff considers these criteria to be better than the Section XI criteria because they recognize differences in valve types and establish separate criteria for electric-motor-operated valves. Electric-motor-operated valves would likely fail catastrophically prior to reaching the acceptance criteria of Paragraph IWV-3417(a). Therefore, the OM-10 acceptance criteria are set lower for this valve type. In addition, OH-10, Paragraph 4.2.1.9, provides corrective actions that the staff considers to be preferable to those of Section XI.

When the measured stroke time exceeds the acceptance criteria of Paragraph 4.2.1.8, in lieu of monthly testing, the valve must be immediately declared inoperable or be retested. If the retest exceeds the criteria of Paragraph 4.2.1.8,'an analysis must be performed to verify that the new stroke time represents acceptable valve operation or the valve must be declared inoperable. Because of these improvements over Section XI, when using stroke time reference values, the staff requiras compliance with the related requirements of OM-10, which include Paragraphs 1.3, 3.1 through 3.6, and 4.2.1.3 through 4.2.1.9.

In rulemaking to 10 CFR 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 10 CFR 50.55a(b). The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OM-10. 10 CFR 50.55a(f)(4)(iv) provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to NRC approval. Portions 13

of editions or addenda'inay be used provided that all related requirements of the respective editions or addenda are met.

As described above, Part 10 allows the use of reference values to evaluate valve stroke time measurements. The staff imposed no limitations to OH-10 associated with the stroke time measurement requirements for power-operated valves. Accordingly, basing stroke time corrective actions on reference stroke times is in compliance with the rulemaking effective September 8,1992,' and relief is not required. Therefore, we recomend that J the alternative of using stroke time reference values be approved pursuant to i 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related  !

requirements, which include Paragraphs 1.3, 3.1 through 3.6, and 4.2.1.3 l through 4.2.1.9. Whether all related requirements are met is subject to NRC '

inspection.

3.1.3 Corrective Actions for Valves Tested at Cold Shutdowns 3.1.3.1 Relief Reauest. RV-00G requests relief from the corrective action requirements of Section XI, Paragraphs IWV-3417(b) and -3523, for l valves tested at cold shutdowns that require corrective actions due to stroke  !

I time measurements. The licensee proposes to determine system requirenients for operation from the TS requirements.

3.1.3.1.1 Licensee's Basis For Reauestina Relief--The following text is quoted from relief request RV-00G in Revision 4 of the Quad Cities IST program:

The Technical Specifications provide Limiting Conditions for operation which state the minimum conditions necessary for safe operation of the plant. The failure of an individual valve may not necessarily prevent a startup.

Alternate Testina: Quad Cities Station will evaluate the condition of each individual valve with respect to its safety function (s) and impact on system operability. Appropriate corrective actions would then be taken in accordance with the applicable Technical Specification -

Limiting Condition for Operation.

3.1.3.1.2 Evaluation--Paragraph IWV-3417(b) requires that if a valve fails a stroke time test, the action to repair the valve should start immediately. In addition, Paragraph IWV-3523 specifies that if a check valve fails to' exhibit the required change of disk position, the action to repair l the valve should be initiated immediately. If the valve is not or cannot be repaired within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the valve is considered inoperative. In addition, if the test failure occurs during cold shutdown, the repairs must be made prior to startup. The NRC provided guidelines in GL 89-04, Position 8, that as soon as it is recognized that the measured stroke time exceeds the limiting stroke time, the valve is to be declared inoperable.

The plant TS provide the minimum system, subsystem, and component operability requirements for safe operation and have been reviewed and approved by the staff. Compliance with the plant TS would provide an acceptable level of quality and safety provided the TS specifically address the valve or its associated system and permit plant startup when the valve is inoperable. Because some safety-related valves and their systems are not 14

specifically addressed in the plant TS, the effects of their inoperability may not be considered in an analysis. Therefore, plant operation with these components out of service may be unanalyzed and should not be permitted.

Based on the determination that ccmpliance with the plant TS operability requirements should provide an acceptable' level of quality and safety i regarding plant startup with inoperable valves, we recommend that the proposed )

alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i) with the j following provisions. The TS must specifically address the valve or its l associated system and permit plant startup when the valve is inoperable.

Additionally, if corrective action for a valve is deferred u.. der this relief request, prior to entering an operating mode where the valve is required to be operable, the valve should be repaired or replaced and successfully tested.

, 3.2 Main Steam System 3.2.1 Cateaory A Valves 3.2.1.1 Relief Reouest. RV-02A requests relief from the fail-safe l test frequency requirements of Section XI, Paragraph IWV-3415, for the main steam isolation valves (MSIVs), 0203-001A-A0 through -001D-A0. The licensee proposes to fail-safe test them during reactor refueling outages.

3.2.1.1.1 Licensee's Basis For Reouestino Relief--The following text is quoted from relief request RV-02A in Revision 4 of the Quad Cities IST program:

A true fail-safe test of these valves can only be performed by locally venting the HSIV accumulator and watching the valve change position.

Because these accumulators and valves are located in the drywell, which is inerted with nitrogen during power operation and cold shutdown, it is impractical to perform the fail-safe test except at reactor refueling.

Alternate Testino: Fail-safe testing of these valves will be performed at reactor refueling.

4 3.2.1.1.2 Evaluation--Paragraph IWV-3415 requires that valves with fail-safe actuators be tested by observing the operation of the valves upon loss of actuator power. This testing shall be performed once every three months or during each cold shutdown. The testing provides assurance that the i i

I valves are capable of exercising to their required fail-safe positions upon l loss of actuating electrical, pneumatic, and/or hydraulic supply. The  ;

4 licensee proposes to verify the fail-safe function of these valves during a refueling outages.

Paragraph IWV-3415 permits fail-safe testing to be deferred until cold shutdowns when it is impractical to test valves once every three months.

Section XI does not authorize the refueling outage frequency, but that frequency is authorized by ASME/ ANSI OMa-1988, Part 10. Part 10, Paragraph 4.2.1.6, specifies that fail-safe testing is to be performed in accordance with the exercising frequency of Paragraph 4.2.1.1. Paragraph 4.2.1.2 permits I

deferral of exercising until refueling outages when it is not practicable l during power operation or cold shutdowns. j 15 l

l

It is impracticable to fail-safe test the subject valves quarterly during power operations because the test requires isolating the control air to the MSIVs and venting off the accumulators. The MSIVs, their accumulator tanks, and the control air isolation and vent valves are located inside containment, which is required to be inerted during power operations.

Entering the oxygen deficient atmosphere poses a personnel safety hazard. The containment is maintained inerted during most cold shutdowns due to the large amount of nitrogen and the time required to re-establish the inerted atmosphere. De-inerting containment solely to fail-safe test these valves would be excessively burdensome to the licensee. Therefore, it is impracticable to enter containment to perform this testing during those cold shutdowns when the containment is not de-inerted for other reasons. During some cold shutdowns the Quad Cities containment will be de-inerted. During those cold shutdowns it would not be impractical to fail-safe test these valves. Therefore, consistent with the test frequency provisions of Part 10, Paragraph 4.2.1.2, the MSIVs should be fail-safe tested during cold shutdowns when the containment is de-inerted and during refueling outages.

In rulemaking to 10 CFR 50.55a effective September 8, 1992, .he 1989 EJition of ASME Section XI was incorporated in 10 CFR 50.55a(b). .he 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified .r. CM-10. 10 CFR 50.55a(f)(4)(iv) provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

As described above, Part 10 allows deferral of valve exercising, and fail-safe testing, until refueling outages when it is impracticable during power operation and cold shutdowns. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8, 1992, and relief is not required. Therefore, we recommend that the alternative be approved pursuant to 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related requirements, which include Paragraphs 4.2.1.2(h) and 6.2 of OH-10. Whether all related requirements are met is subject to NRC inspection.

NOTE: There are other safety-significant testing issues for MSIVs that are unrelated to test frequency. The NRC identified a potential problem with testing MSIVs in Information Notice (IN) 85-84, " Inadequate Inservice Testing of Main Steam Isolation Valves." This IN involves the use of nonsafety-related instrument air to help achieve MSIV closure. General Electric (GE) Service Information Letter (SIL) 477 described a related concern specific to boiling water reactors (BWRs). SIL 477 identified that excessive tightening of valve gland flanges can prevent MSIVs from closing using spring force alone. The licensee should review these documents and ensure that the MSIV testing at Quad Cities adequately addresses the identified concerns.

3.2.2 Catecorv 8 and B/C Valves 3.2.2.1 Relief Reouest. RV-30A requests relief from the test frequency and stroke time testing requirements of Section XI, Paragraphs IWV-3411 and -3417(a), for valves 0203-003A, dual function Target Rock 16

~

safety / relief valves, and 0203-003B, -003C, -003D, and -003E, electromatic relief valves. The licensee proposes to exercise them once every six months during plant operation without measuring and evaluating their stroke times.

I Note: Valves 0203-003A-50 are the solenoid valves that control the air supply to the Target Rock valve's diaphragm operator. These valves were included in the relief request, but are non-Code Class, and therefore are not evaluated with this relief request.

3.2.2.1.1 Licensee's Basis For Reauestina Relief--The following text is quoted from relief request RV-30A in Revision 4 of the Quad Cities IST program:

These valves can only be tested with primary system pressure greater than 150 psig. The test sequence requires an operator to:

a. Open at least one turbine bypass valve and discharge main steam directly to the condenser,

b. Actuate the relief valve and observe the corresponding closure of 1 the turbine bypass valve (pressure control on the turbine bypass !

valve is fairly quick to respond, 1-1/2 seconds),

c. Close the relief valve and observe the corresponding opening of the turbine bypass valve. ,

l Each relief valve actuation produces hydrodynamic loads which are l l transmitted to the Suppression pool (torus). The Quad Cities Mark I Containment, Plant Unique Analysis Report (PUAR) fatigue evaluation is based on 300 relief valve actuations with normal operating conditions (i.e., 300 actuations for testing purposes). Quarterly testing of the

! subject valves would result in 4 (quarters) x 40 (years) x 5 (valves)

- 800 test actuations, which would exceed the approved design basis.

Finally, the failure of any relief valve to close would cause an l uncontrolled rapid depressurization of the primary system (stuck open l relief valve transient). The resulting severe thermal gradients in the l reactor vessel are not desirable, and should be minimized. These valves I cannot be tested at cold shutdown or roactor refueling since the primary system pressure must be greater than 150 psig to actuate these valves.

The subject valves are fast acting valves (normally exercise in less than 2 seconds) and they do not have stem / disk position indicators.

Stroke timing of these valves is performed indirectly via turbine bypass valve position and relief valve discharge line temperature and acoustic alarms.

Alternate Testing: The subject valves will be exercised (open and closed) once every six (6) months during plant operation. Relief l request RV-00F contains additional alternate testing information for 0203-003A-SO. Relief request RV-00C contains additional alternate testing information for 0203-003A through -003E. Stroke times will not be measured, and incraased test frequency based on change in stroke time will not be implemented. As described in the basis for relief, Quad Cities will verify the operability of the subject valves.

3.2.2.1.2 fyaluation--The Target Rock ADS valves, 0203-003A, act both as power-operated valves, in response to an automatic control signal and 17

4 as safety relief valves' . As a result, these valves should be tested to both the Category B and C requirements. The electromatic ADS valves, 0203-003B,

-003C, -0030, and -003E, act only as power-operated relief valves. These valves are connected to the main steam lines upstream of the MSIVs and discharge to the torus. Full-stroke exercising them quarterly during power .

operations is inadvisable as this may result in a loss-of-coolant accident and l an increase in suppression pool temperature. Quarterly testing over the life of the plant would also result in exceeding the allowed number of valve I opening cycles on the torus. Reactor steam pressure is necessary to full-stroke exercise these valves, therefore, exercising is not practical ,

during cold shutdowns or refueling outages when the reactor pressure is low. I NUREG-0626 " Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in GE-Designed Operating Plants and Near Tem Operating License Applications" recommends reduction of challenges to relief valves to lessen the risk of a small break LOCA (see also NUREG-0737,Section II.K 3.16).

Valve or system redesign would be necessary to permit testing these valves at the Code specified frequency. Making these modifications would be difficult for the licensee. The licensee proposes to exercise these valves once every six months with the reactor at power, by passing reactor steam through them. The valves will be verified to open by monitoring the turbine bypass valve position and relief valve discharge line temperature and acoustic alarms. ASME/ ANSI OMa-1988, Part 10, Paragraph 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during power operation or cold shutdowns. Therefore, this frequency is appropriate and we recommend that the alternative be approved pursuant to 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related requirements. Whether all related requirements are met is subject to NRC inspection.

l Regarding the proposed test method; these safety / relief valves operate l rapidly, on the order of 100 milliseconds, and are not equipped with direct sensing position indication. Further, their stroke times vary with changes in system operational parameters, such as steam pressure. Therefore, trending

, the stroke times for these valves may not be meaningful since test-personnel ,

l response times and variations in system parameters can change the measured l l stroke times and could mask changes in valve condition. However, not '

monitoring for degradation of these valves is unacceptable.

The licensee should develop a method to obtain repeatable stroke times l for thes8 valves or propose some other method to adequately monitor for valve l degradation. It may be possible to demonstrate that enhanced maintenance l

l procedures during the periodic refurbishment of these valves provides adequate I assurance that the valves are not degraded. If stroke time measurements are l used to monitor for valve degradation, the licensee should assign a maximum l stroke time limit to these valves that is based on test data and verify that {

they stroke within that limit during testing. The measured stroke times need '

not be trended or compared to previous values, but if the maximum limit is exceeded, the valve should be declared inoperable and corrective action taken in accordance with Paragraph IWV-3417(b). An interim period of one year or until the next refueling outage, whichever is longer, should be provided to allow the licensee time to develop a method to monitor for valve degradation.

l The licensee's proposed exercise test should provide an acceptable level of quality and safety during this interim period.

IC l

Based on the determination that the proposed testing method provides an acceptable level of quality and safety during the interim period, we recommend that the proposed alternative be authorized pursuant to 10 CFR 50.55a(a)(3)(i) for one year or until the next refueling outage, whichever is longer. At the end of the interim period, the licensee should implement a method of stroke timing these valves, as discussed above, or propose some other method to adequately monitor for valve degradation.

3.2.3 Cateaory B/C and C Valves 3.2.3.1 Relief Reauest. RV-30B requests relief from the sample expansion requirements of ASME/ ANSI OM-1, Paragraph 1.3.3.1.e, for safety / relief valves 0203-003A, and safety valves 0203-004A through -004H.

The licensee proposes to test, rebuild and reset valve 0203-003A and four of the safety valves each reactor refueling outage according to plant Technical Specifications. If only one valve fails its setpoint test, additional safety valves will not be tested. If more than one safety valve fails, the sample expansion criteria of OM-1, Paragraph 1.3.3.1.e, will be implemented for every additional failed valve.

3.2.3.1.1 Licensee's Basis For Reauestina Relief--The following text is quoted from relief request RV-30B in Revision 4 of the Quad Cities IST program:

In accordance with Technical Specification 4.6.E'(Basis) and FSAR 4.4.8, at least half of the subject valves are tested and rebuilt during each refueling outage. This accelerated maintenance schedule provides a high level of assurance that these safety valves will perform their safety function.

Quad Cities does not have the facilities required to perform setpoint-tests on large relief and safety valves. These valves are unbolted from their mounting flanges, decontaminated, and shipped to an off-site test facility. Because of the lengthy period required for removal, transportation, testing and reinstallation, the removal and testing of additional valves due to sample expansion would delay unit start-up from refueling outages by at least several days. This represents a significant hardship.

The sample expansion requirements of O&M-1 would require two additional valves be tested if one valve failed its setpoint test. Since the dual function safety / relief valve is tested'each outage, and no less than four of the remaining valves are tested during each outage, the valves already being tested represent an increased sample expansion.

Therefore, based on the sample expansion requirements already being met for one valve, and the hardship associated with pulling additional valves, no additional valves will be tested if only one valve fails the setpoint test.

Alternate Testina: The dual function safety / relief valve, and at least half of the eight (8) safety valva will be tested, rebuilt and reset in accordance with Technical Specit.:ation 4.6.E'during each reactor refueling outage. If only one of the eight (8) safety valves fails its setpoint test, additional safety valves will not be tested. If more 19

i 4

1

!' than one safety valve fails, the sample expansion criteria of O&M-1,

Section 1.3.3.1.5 will be implemented for every additional failed valva.

4 l 3.2.3.1.2 Evaluation--0M-1 Paragraph 1.3.3.1, requires that all valves be tested within 5 years and tliaS a minimum of 20% of the subject i valves be tested within any 24 months. For valves that fail the set pressure

test, additional valves must be tested on the basis of two additional valves i

for each valve failure. The licensee proposes to test, rebuild, and retest

, the Target Rock safety / relief and at least 4 of their 8 safety valves each I refueling outage, which is nominally every 18 months. The minimum number of valves that the licensee proposes to test exceeds the number of valves that

! must be tested per the Code requirements (the Code requires 20% X 8 valves =

1.6 [or 2] valves) each 24 months. In fact, the licensee's sample equals the i number of valves that would be required to be tested-if one valve (in the

required sample size of 2 valves) failed the test. The licensee proposes that t l if only one valve fails the test the sample size will not be increased, but if a second valve fails, the sample size will be expanded as required by 1.3.3.1.e. The licensee's proposal will test the subject valves at an equal or higher rate than required by the Code. The large sample size will provide

added assurance of operational readiness. Therefore, the licensee's proposal-is essentially equivalent to the Code requirements.

l Based on the determination that the licensee's proposal is equivalent to i the Code requirements, we recommend that relief be granted from the Code i requirement pursuant to 10 CFR 50.55a(a)(3)(i).

l j 3.2.3.2 Relief Reouest.- RV-30E requests relief from the "as-found" j setpoint acceptance criteria requirements of OM-1, Paragraph 1.3.3.1.e, for

safety / relief valves 0203-003A, and safety valves 0203-004A through -004H.

The licensee proposes to expand the sample size consistent with their relief j request 30A (See section 3.2.3.1 of this report) if the "as-found" setpoint is j outside 3% of the design set pressure.

i 3.2.3.2.1 Licensee's Basis For Reauestina Relief--The following j text is quoted from relief request RV-30E in Revision 4 of the Quad Cities IST

program

For main steam safety valve setpoint testing (as-found setpoint testing), the O&M code provides a setpoint acceptance criteria of three

percent (3%) greater than the design set pressure. Experience with

, sa,fety valves currently used in nuclear power plants indicates that normal expected setpoint drift is within plus or minus three peretnt (3%). Setpoint drift outside of this range is generally indicative of j mechanical or human error problems that need to be addressed. Since

O&M-1 does not provide guidance for sample expansion when the as-found i setpoint pressure test results are found to be lower than the design set

] pressure, a lower limit of minus (-)3% is considered appropriate.

Alternate Testina: For main steam safety valve setpoint testing 4 (as-found setpoint testing), additional valves will be tested if the

! as-found setpoint is outside 3% of the design set pressure. Sample

~

expansion of the safety valves will be consistent witn relief request RV-30B. In accordance with the current Technical Specifications, the i setpoint of the main steam safety valves will be 1% of the design set pressure prior to installation.

20

N d

3.2.3.2.2 Evaluation--0M-1 specifies that valves whose "as-found" setting is 3% greater than the stamped set pressure fail the test. OH-1 does not specify acceptance criteria for "as-found" settings below the stamped set point. Quad Cities requests to specify a lower acceptance criteria limit for the "as-found" settings of -3%. Thus, their acceptance criteria for "as-found" setting is 3%. The licensee's proposal is conservative and essentially equivalent to the Code requirements.

Based on the determination that the licensee's proposal is equivalent to the Code requirements, we recommend that relief be granted from the Code requirenmnt pursuant to 10 CFR 50.55a(a)(3)(i).

3.3 Standby Liauid Control System 3.3.1 Cateaory A/C Valves 3.3.1.1 Relief Reauest. RV-11A requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for the SLC injection header check valves, 1101-015 and -016. The licensee proposes to part-stroke exercise these valves open during cold shutdowns and to full-stroke them open and closed at refueling outages.

3.3.1.1.1 Licensee's Basis For 'questina Relief--The following text is quoted from relief request RV-11A in Revision 4 of the Quad Cities IST program:

Any exercise test of these valves is complicated because they are isolated from the main part of the SLC system by explosive actuated valves (1106A and 11068). The explosive actuated valves maintain a leak tight physical barrier between the poison in the SLC system and reactor water. An exercise test to the open position (using demineralized water) cannot be performed during normal operation because the resulting cold water injection would produce undesirable thermal stresses in the complex SLC piping inside the reactor vessel. The test connection downstream of the explosive actuated valves can be used during cold shutdown to part stroke open the subject valves. The test connection is not large enough for a full flow test; a full stroke test can only be performed during reactor refueling using the SLC pumps. l These simple check valves do not have position indication, and valve l 1101-015 is inside the drywell so it is normally inaccessible. These ,

valves cannot be tested to the close position without performing some '

type of reverse flow / leak test, which is impractical to perform during normal operation or cold shutdown.

Alternate Testina: These valves will be exercised partially open during ,

cold shutdown. These valves will be full stroke exercised closed and I open during reactor refueling. These valves will be exercised open during the SLC reactor vessel injection surveillance. After the explosive actuated valves are detonated, the SLC pumps will be aligned to pump demineralized water from the SLC test tank to the reactor vessel. The flow rate during this special test will exceed 40 gpm, the maximum required accident flow rate.

21

3 3.3.1.1.2 Evaluation--Paragraph IWV-3521 requires a full-stroke exercise of safety-related check valves quarterly or during cold shutdowns if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to exercise these valves open and closed by passing flow through them and performing Appendix J leak rate testing each refueling outage.

These check valves are in the common SLC injection line to the reactor vessel, downstream from the explosive ly actuated squib valves. It is impractical to full-stroke exercise these valves open with flow, either quarterly during power operation or at cold shutdowns. Initiation of system flow requires the firing of at least one squib valve, which destroys the valve. Further, the system contains highly borated water that would be introduced into the reactor coolant system (RCS) and cause a reactor shutdown if the testing were performed during power operation. Extensive flushing must be performed on the system to remove all traces of the boron solution prior to initiating flow for exercising these valves. Performance of this testing during cold shutdowns would be burdensome to the licensee since this testing could result in an extension of the shutdown.

In rulemaking to 10 CFR 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 10 CFR 50.55s(b). The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in 0M-10. 10 CFR 50.55a(f)(4)(iv) provides that IST of valves may meet the requirements set forth in subsequent editions and addenda i that are incorporated by reference in 10 CFR 50.55a(b), subject to the '

limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of  !

the respective editions or addenda are met. '

OM-10, Paragraph 4.3.2.2, permits deferral of full-stroke exercising l until refueling outages when this exercising is not practicable during plant 1 operation or cold shutdowns. The NRC staff imposed no limitations to 0M-10 associated with the test frequency requirements for check valves.

Accordingly, the licensee's proposed alternate testing is in compliance with

, the rulemaking effective September 8,1992, and relief is not required.

Therefore, we recommend that the alternative be approved pursuant to 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related requirements, which include Paragraphs 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are met is subject to NRC inspection.

3.4 Hiah Pressure Coolant In.iection System 3.4.1 Cateaory A/C and C Valves 3.4.1.1 Relief Reauest. RV-23A requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for the HPCI drain <

pot to torus CIVs, 2301-034, and the HPCI turbine exhaust line check valves, 2301-045. The licensee proposes to exercise these valves open quarterly and verify their closure during refueling outages.

3.4.1.1.1 Licensee's Basis For Reauestino Relief--The following text is quoted from relief request RV-23A in Revision 4 of the Quad Cities IST program:

22

-j The HPCI valves w'ill be exercised open quarterly during the HPCI system pump test. There are no position indicators on.these valves and there is no conclusive, indirect means of determining that these valves were {

' exercised closed during the quarterly pump test. These valves have -1 probably closed since the discharge line pressure returns to atmospheric -l pressure at the conclusion of the test. An elevated pressure would  ;

indicate that the line was flooded when the vacuum created by condensing steam sucked torus water into the line (which is at a lower elevation than the connection to the torus).

It would be impractical to unlock and close stop check valves 2301-071 and 2301-074 for the purpose of pressurizing the volume between the stop check valves and the subject check valves-te verify valve closure. If this test were performed during normal plant operation, the system would have to be declared inoperable for the sole purpose of confirming a valve-position. It is impractical to perform such complicated tests during cold shutdown.

Alternate T*Jiling: The subject check valves will be eu rcised closed during each reactor refueling outage.

3.4.1.1.2 Evaluation--Paragraph IWV-3521 requires a full-stroke exercise of safety-related check valves quarterly'or during cobi shutdowns if quarterly testing is impractical. This testing is to demonstca.?.e that the valves are capable of moving to their safety function position 7;) to assess their operational readiness. The licensee proposes to full-stroke exercise these valves open quarterly and verify their closure each refueling outage.

These are simple check valves without local or remote position I

indication to permit direct verification of valve closure. To verify these  !

valves closed using pressure or flow it require 2 removing the HPCI system from '

operation, closing the downstream stop check valves, and_ pressurizing the header between the stop check valves and the subject valves. The downstream stop check valves are located in the overhead and are difficult to access for  !

testing. It is impractical to remove this system from operable status during )

, power operations, unlock and close the downstream stop check valves, and j pressurize the piping to verify check valve closure because this would l decrease the availability of this safety system-and could result in safety l- hazards to test personnel. It is impractical to verify closure of these valves during cold shutdowns because it involves leak testing the valves or using a non-intrusive technique and both are complex procedures and may result in a delay in returning the plant to power operation.

i In rulemaking to 10 CFR 50.55a effective September 8, 1992, the 1989 j Edition of ASME Section XI was incorporated in 10 CFR 50.55a(b). The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OH-10 10 CFR 50.55a(f)(4)(iv) provides that IST of_ '

valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the >

limitations and modifications listed, and subject to NRC approval. Portions l of editions or addenda may be used provided that all related requirements of g the respective editions or addenda are met.

OM-10, Paragraph 4.3.2.2, permits deferral of full-stroke exercising l until refueling outages when this exercising is not practicable during plant l 23 a

l operation or cold shutdowns. The NRC staff imposed no limitations to OH-10 associated with the test frequency requirements for check valves.

Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required.

Therefore, we recommend that the alternative be approved pursuant to 10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related requirements, which include Paragraphs 4.3.2.2(h) and 6.2 of OH-10. Whether l all related requirements are met is subject to NRC inspection.

3.4.2 Cateoory C Valves 3.4.2.1 Relief Reauest. CS-23B is submitted in the IST program as a cold shutdown justification, however, the licensee's basis for not testing quarterly is that, due to the inherent system reliability, quarterly testing would be a hardship without a compensating increase in the level of quality and safety. Paragraph IWV-3522 permits check valve testing at cold shutdowns when quarterly testing is impractical, however, cases where quarterly testing is a hardship without a compensating increase in the level of quality and safety are not covered by the Code and relief must be requested and approved from the test frequency requirements of Section XI. CS-238 is for the vacuum breakers on the HPCI turbine steam exhaust line, 2301-064, -065, -066, and

-067 (see Figure 1). Relief from the Code test frequency requirements, as justified by CS-23B, is evaluated below.

Note: The Quad Cities HPCI system P&ID (Quad Cities Station, Unit 2, Drawing No. M-87, Rev. AR, dated 11/19/92), IST program valve tables, and Figure 1 (following) show the subject valves as 2399-064, -065, -066, and -067 rather than 2301-064, -065, etc., as indicated in the relief request (see Anomaly no. 5).

3.4.2.1.1 Licensee's Basis For Reauestina Relief--The following text is quoted from relief request CS-238 in Revision 4 of the Quad Cities IST program:

Any three out of the four valves in combination must close in order for this valve arrangement to fulfill its intended safety function. A minimum of two valves would have to fail open in order for the valve arrangement to fail. The redundancy inherent in the design of the valve arrangement prevents a single active va:n failure from resulting in failure of the whole valve arrangement. The testing of these check valves on a quarterly frequency vice a cold shutdown frequency will not re'sult in a corresponding increase in safety.

Alternate Testina: The subject check valves will be exercised duriag each cold shutdown.

3.4.2.1.2 Evaluation--Paragraph IWV-3521 requires a full-stroke exercise of safety-related check valves quarterly or during cold shutdowns if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to exercise each of these valves each cold shutdown.

These are simple check valves without local or remote position indication to permit direct verification of valve operation. To verify these 24

valves in either the open or closed positions using pressure or flow requires removing the HPCI system from operation, closing vacuum breaker line valves, and pressurizing the header upstream or downstream of the subject valves (see Figure 1). The test is time consuming and difficult to perform, even though the system has adequate testing provisim outside of containment. Other plants contain similar systems with less extensive testing provisions. This makes it difficult for those plants to achieve a high level of confidence in the reliability of individual components in this system.

s[eam M N U 2399-71 JL 2 67 2 9M 65 2 41 to 2 66 2 9 @ 64 2399-62 239b 72 U2399-7o

{2399-73 Test Test Tesi T

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&5%?$

M 'wTo"Ne l

Figure 1 l Based on Quad Cities Drawing No. M-87, Rev. AR The licensee's test provisions allow individual testing of these 4-inch l check valves. This provides a high level of assurance of the system's redundant and highly reliable design. The licensee indicates that the

difference in reliability gained from testing these valves individually quarterly, rather than at each cold shutdown, does not offset the hardship of performing the test quarterly, particularly considering the fact that at least two valves must fail to render the system inoperable. The difference in the level of safety achieved is the difference between the safety achieved by testing at the required test frequency (quarterly) verses the level of safety achieved by testing each cold shutdown. Though the difference is not quantified, it should be small due to the large number of success paths for the subject valve arrangement and the small probability for any two valves to fail simultaneously. Therefore, the licensee's pre;nsal to test these valves each cold shutdown rather than quarterly should h.ve only a minimal negative impact on system quality and safety. The hardship of 1.ne quarterly test would not be offset by the increase in safety. Additionally, testing these valves renders the HPCI system unavailable during the test.

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I Based on the determination that compliance with the Code test frequency requirements would constitute a hardship on the licensee that would not be i offset by a compensating increase in the level of quality and safety, we i recomend that the alternative to test these valves each cold shutdown be authorized pursuant to 10 CFR 50.55a(a)(3)(ii).

3.5 Feedwater System l

j 3.5.1 Cateaory A/C and C Valves i

I 3.5.1.1 Relief Reauest. RV-32A requests relief from the test frequency requirements of Section XI, Paragraph IWV-3521, for the main feedwater header check valves, 0220-058A, -058B, -0598, -062A and -0628. The licensee proposes

to exercise these valves closed during refueling outages.

3.5.1.1.1 Licensee's Basis For Reauestino Relief--The following 1 text is quoted from relief request RV-32A in Revision 4 of the Quad Cities IST i program:

i These valves cannot be tested closed during normal (power) operation a because the feedwater system is required to maintain reactor j vessel / primacy coolant level. A scram on low water level would occur if

one of the subject valves was closed to perform an exercise test.

Valves 0220-058A and 0220-062A cannot be tested closed during cold 3 shutdown because the reactor water clean-up (RWCU) system is required to be operable during cold shutdown to maintain reactor water chemistry and minimize therma 1' stratification in the reactor vessel. All of these j valves would be extremely difficult to test during cold shutdown (even if RWCU was isolated).

1 l Demineralized water service connections are not available in the X-Area, I which is a special extension of secondary containment. Demineralized l j water would be required to perform some type of reverse flow test while i

, the rest of the feedwater header was drained. It is impractical to

perform such complicated tests during cold shutdown.

Alternate Testina: The subject valves will be exercised closed during 3 each reactor refueling outage.

' 3.5.1.1.2 Evaluation--Paragraph IWV-3521 requires a full-stroke

. exercise'of safety-related check valves quarterly or during cold shutdowns if

quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to verify closure of these normally open valvas each refueling outage.

l It is impracticable to exercise these valves closed quarterly during

power operatica because normal feedwater flow passes through them into the l reactor vessel and interrupting this flow would cause disturbances in vessel level control and possibly result in a plant trip. Additionally, to perform i

this testing requires entry into the drywell whose atmosphere is inerted 2

(oxygen deficient) during power operation, making entry impractical due to personnel safety hazards. The drywell atmosptere is maintained inerted during many cold shutdowns. Deinerting the drywell and subsequently restoring it to

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

the required inert condition requires large amounts of nitrogen gas and time.

This testing also requires installation and removal of temporary equipment and would take a significant amount of time to perform. Requiring the licensee to deinert the drywell atmosphere, install the special test equipment, perform the leak test, restore the system to operation, and reestablish the required drywell atmosphere conditions each cold shutdown could cause a delay in returning the plant to operation and would be unduly burdensome.

In rulemaking to 10 CFR 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 10 CFR 50.55a(b). The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OM-10. 10 CFR 50.55a(f)(4)(iv) provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of th! respective editions or addenda are met.

OH-10, Paragraph 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or cold shutdowns. The NRC staff imposed no limitations to OH-10 associated with the test frequency requirements for check valves.

Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required. l Therefore, we recommend that the alternative be approved pursuant to ,

10 CFR 50.55a(f)(4)(iv), provided the licensee implements all related l requirements, which include Paragraphs-4.3.2.2(h) and 6.2 of 0M-10. Whether i all related requirements are met is subject to NRC inspection.  !

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IST PROGRAM AN0MALIES l

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APPENDIX A l IST PROGRAM ANOMALIES l Anomalies or inconsistencies foun4 during the evaluation are given below. These anomalies summarize concerns with the IST program that require-additional actions by the licensee for resolution. The licensee should resolve these items as indicated.

1. The IST program does not include a description of how the components were selected and how testing requirements were identified for each component. The review performed for this Safety Evaluation (SE)/TER did not include verification that all pumps.and valves within the scope of 10 CFR 50.55a and Section XI are contained in the IST program, and did not ensure that all applicable testing requirements have been j identified. Therefore, the licensee is requested to include this  ;

information in the IST program. The program should describe the I development process, such as a listing of.the documents used, the method of determining the selection of components, the basis for the testing required, the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59,

2. Several of the licensee's relief requests (RV-00A, -00C, -00E, -00F, and

-03A) are approved by GL 89-04.and are not evaluated in this TER._ The licensee indicated compliance with GL 89-04, but did not specifically address all aspects of the Generic Letter provisions in the requests.

In these cases, it is assumed that the licensee is complying with all of the requirements of the applicable GL 89-04 positions. Relief is not granted for the above relief requests for testing that deviates from that prescribed in GL 89-04. Whether the licensee complies with the provisions of GL 89-04 is subject to NRC inspection. If the licensee intends to deviate from a GL 89-04 position, a revised relief request specifically stating the deviation from GL 89-04 guidance must be submitted for review and approval prior to implementing the testing.

3. Valve relief requests RV-00E and -00F are for check valves that may not be practically verified closed using system pressure or flow or full-stroke exercised open with flow per GL 89-04, Position 1. The licensee proposes to full-stroke exercise these valves by sample disassembly, inspection, and a manual exercise. The NRC considers valve disassembly anB inspection to be a maintenance procedure and not a test equivalent to the exercising produced by fluid flow. This procedure has some risk, which make its routine use as a substitute for testing undesirable when some method of testing is possible. Disassembly and inspection, to verify the full-stroke open or closure capability of _ check valves is an  ;

option only where exercising cannot be practically performed by system pressure, flow, or other positive means. Check valve disassembly is a valuable maintenance tool that can provide much information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and' service.

Some test method may be feasible to full-stroke exercise these valves.

The licensee should consider methods such as using non-intrusive A-2

i techniques (e.g., acoustics, ultrasonics, magnetics, radiography, and

- themography) to verify a full-stoke exercise of the subject check valves. This testing may only be practical at cold shutdowns or j~ refueling outages. The licensee should perform their investigation and l if a test method is found to be practicable, the IST requirements of the

, applicable valves should be satisfied by testing instead of disassembly

. and inspection. If testing is not practicable and disassembly and 1

inspection is used, it must be performed in accordance with GL 89-04, j Position 2. The licensee should respond to this concern.

} 4. Paragraphs IWV-3417(b) and -3523 require that if a valve fails a test,

the action to repair the valve should start immediately. In addition, j if the test failure occurs during cold shutdown, the repairs must be l made prior to startup. The plant TS provide the minimum system, a subsystem, and component operability requirements for safe operation and  ;

j have been reviewed and approved by the staff. Compliance with the plant

TS would provide an acceptable level of quality-and safety provided the

! TS specifically address the valve or its associated system and permit i plant startup when the valve is inoperable. Because some safety-related

! valves and their systems'are not specifically addressed in the plant TS, ,

1 the effec 6s of their inoperability may not be considered in an analysis. l l Therefore, plant operation with these components out of service may be l j unanalyzed and should not be pemitted. Additionally, if corrective l i action for a valve is deferred under this relief request, prior to j

! entering an operating mode where the valve is required to be operable,

! the valve should be repaired or replaced and successfully tested. I J (Refer to Section 3.1.3.1 of this report)

5. CS-23B requests relief for the vacuum breakers on the HPCI turbine steam exhaust line. The request identifies the valves as 2301-064, -065, l l -066, and -067. However, the HPCI system P&ID (Quad Cities Station, i Unit 2, Drawing No. M-87, Rev. AR, dated 11/19/92) and the IST program J valve tables show the subject valves as 2399-064, -065, -066,-and -067 i

rather than 2301-064, -065, etc., as indicated in the relief request.

l In addition, valves 2399-064, -065, -066, and -067 are not shown on the Unit 1 HPCI system P&ID (Quad Cities Station, Unit 1, Drawing No. M-46,

Rev. AZ, dated 3/20/9E) as indicated in the IST program. The licensee

should resolve these inconsistencies in a future program update.

! 6. A statement in the Quad Cities submittal letter appears to conflict with l a ttatement in their IST program. On page 1-2, in Section 1.0,

Introduction and Plan Description, the licensee states that the IST 2

" program will be effective for ten years beginning: Unit 1 - February 1

18, 1993, and Unit 2 - March 10, 1993." Page 2 of the cover letter

! dated January 7,1992 (sic) from John L. Schrage to Dr. Thomas E. Murley i states the " actual start date for the third ten-year interval ISI/IST

Program (February 18, 1993 for both Unit I and Unit 2)." The licensee i should identify the correct interval dates in the IST program and make  ;

any needed program changes. If the intent is to establish concurrent I intervals for both units, an exemption from 10 CFR 50.55a is required l and should be requested.

l l 7. CS-238 is submitted in the IST program as a cold shutdown justification, i

however, the licensee's basis for not testing quarterly is that, due to the inherent system reliability, quarterly testing would be a hardship i A-3

without a compensating increase in the level of quality and safety.

Paragraph IWV-3522 permits check valve testing at cold shutdowns when quarterly testing is impractical, however, cases where quarterly testing is a hardship without a compensating increase in the level of quality and safety are not covered by the Code and relief must be requested and approved from the test frequency requirements of Section XI. CS-23B covers the vacuum breakers on the HPCI turbine steam exhaust line, 2301-064, -065, -066, and -067, and is evaluated in Section 3.4.2.1 of the TER. CS-23B should be withdrawn or it should be modified to adequately demonstrate the impracticality of exercising these valves quarterly. If CS-238 is not modified as discussed above and these valves are exercised at cold shutdowns, a relief request should be submitted for the test frequency of these valves. l l 8. The check valve (0203-3AD) in the supply line to the air accumulator l tank for the Target Rock relief valve and the vacuum breaker check

! valves (0220-81A through -81E and 0220-105A through -105E) on the-i discharge lines from the Target Rock and Electromatic relief valves are not included in the licensee's IST program. Valves that perform these functions at similar facilities are generally included in the facility IST programs. The licensee should review the function of these valves to determine if they should be included in the IST program.

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