ML20029D691
| ML20029D691 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/03/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20029C517 | List: |
| References | |
| GL-89-04, GL-89-4, NUDOCS 9405090289 | |
| Download: ML20029D691 (19) | |
Text
ENCLOSURE
/p ucg[t UNITED STATES
[.' f ' j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C, 20555-0001
%...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM RE0 VESTS FOR RELIEF COMMONWEALTH EDISON COMPANY OVAD CITIES STATION. UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265
1.0 INTRODUCTION
The Code of Federal Regulations,10 CFR 50.55a, requires that inservice testing (IST) of certain American Society of Mechanical Engineers (ASME) Code l
Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(i),
(a)(3)(ii), or (f)(6)(1) of 10 CFR 50.55a.
In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for its facility. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provides alternatives to the Code requirements determined to be acceptable to the staff.
Section 10 CFR 50.55a authorizes the Commission to approve alternatives and to grant relief from ASME Code requirements upon making the necessary findings.
The NRC staff's findings with respect to authorizing alternatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (SE).
Furthermore, in rulemaking to 10 CFR 50.55a effective September 8, 1992, (see 57 Federal 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 j
Operations and Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10 (OM-10), " Inservice l
Testing of Valves in Light-Water Reactor Power Plants." Pursuant to 10 CFR j
l 50.55a(f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and subject to Commission approval.
Because the alternatives meet later editions of the Code, upon Commission approval, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof, provided all related requirements are met.
Whether all related requirements are met is subject to NRC inspection.
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9405090289 940503 PDR ADOCK 05000254
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PDR p
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' 2.0 INSERVICE TEST PROGRAM INTERVAL The IST program evaluated in this SE covers the third 10-year IST interval for Quad Cities Station, Units 1 and 2.
The interval began February 18, 1983, for both units.
The first two intervals were based on interval start dates of February 18 for Unit I and March 10 for Unit 2.
However, for the third interval, the licensee elected to begin concurrent intervals for both units and has shifted the Unit 2 start date to the earlier date of Unit 1.
Though an exemption from 10 CFR 50.55a would be required in most shifts of the start j
dates to make concurrent intervals, because the shift for Unit 2 is less than one month, the change is acceptable within the one-year allowance of Code to change interval dates. Therefore, no exemption is required.
In a telephone conference with the NRC on November 24, 1992, the licensee informed the staff that the requirements of the updated IST program would become effective at the end of the Unit 2 refueling outage Q2R12 which was scheduled to begin March 1993 and which actually ended May 1993.
Note the discrepancy identified in Anomaly 6 in Appendix A of the attached Technical Evaluation Report (TER)
(Attachment 2).
The third 10-year interval IST program is based on the requirements of the 1986 Edition of the ASME Section XI Code.
3.0 EVALUATION The Nuclear Regulatory Commission (NRC) staff, with technical assistance from j
Idaho National Engineering Laboratory (INEL), has reviewed the information concerning IST program requests for relief submitted for Quad Cities, Units 1 and 2, in Commonwealth Edison's letter of January 7,1993. The staff adopts the evaluations and recommendations for granting relief or authorizing alternatives contained in the attached TER prepared by INEL, except as discussed below.
Table 1 lists each relief request and the status of approval.
Evaluation of a revision submitted in the licensee's letter of October 28, 1993, is provided below.
Relief is granted from, or alternatives are authorized to, the testing l
requirements which have been determined to be impractical to perform, where compliance would result in a hardship without a compensating increase in safety, or where the proposed alternative testing provides an acceptable level of quality and safety.
Certain relief requests have been approved pursuant to 10 CFR 50.55a(f)(4)(iv) where it has been determined that the proposed alternative is in accordance with the requirements of the 1989 Edition of ASME Section XI, and therefore, relief from Code requirements is not required.
When an alternative is approved pursuant to (f)(4)(iv), any applicable related requirements, as listed in the TER, must be implemented, and such implementation is subject to NRC inspection.
The IST program relief requests which are granted, authorized, or approved are acceptable for implementation provided the action items identified in Appendix A of the TER are addressed within one year of the date of the SE or by the end of the next refueling outage, whichever is later, unless another l
L l
l t
4
- schedule is indicated.
Additionally, the granting of relief is based !pon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed.
Program changes involving new or revised relief requests should not be implemented prior to approval by the NRC except as authorized by GL 89-04.
4 New or revised relief requests that meet the positions in GL 89-04,, should be submitted to the NRC but may be implemented provided the guidance in GL 89-04, Section D, is followed.
Program changes that add or 1
delete components from the IST program should also be periodically provided to i
the NRC.
3.1 Relief Reauest RP-00A. Addendum. Hiah-Pressure Coolant In.iection Pumos In Section 2.3.1 of the TER, the portion of Relief Request RP-00A concerning the alert limits for vibration monitoring of the high-pressure coolant injection (HPCI) pumps is evaluated.
The staff agrees with the evaluation and conclusion that the imposition of the alert limit of OM-6 is a hardship based on the recent operating history of the HPCI pumps and the licensee's efforts to reduce the vibration levels.
However, because the higher alert limit could be indicative of degrading conditions or operational problems with the pump, long-term relief is not acceptable.
In the licensee's letter of October 28, 3
1993, an addendum to Relief Request RP-00A was submitted.
RP-00A was modified to exclude the discussion about the HPCI pumps. The evaluation in Section 2.1.1.1 of the TER remains acceptable for approval of RP-00A and is also applicable for the HPCI pump as it relates to using velocity measurements versus displacement measurements.
The evaluation in Section 2.3.1.1 of the TER is modified below. The addendum to RP-00A is applicable to the Code Class 2 HPCI Pump 2-2302 which performs a safety-function to inject water into the reactor vessel in the event of a loss-of-cooling accident which does not result in a rapid depressurization of the vessel. The relief requested is to increase the alert action limit from 0.325 inches per second to 0.425 inches per second.
3.1.1 Licensee's Basis for Relief The licensee states:
l Interim relief is requested to assign an extended Alert Range vibration limits (sic) to the Unit 2 HPCI pump.
This interim relief is based on the consistently high vibration level history experienced with the inboard (Bearing 3) of the main pump on [the] Unit 2 HPCI [ pump].
Since 1988, the station has made gradual progress in reducing the vibration amplitudes on bearing 3.
From January 1988 until June 1988, the vibrations on Bearing 3 ranged from 0.500 inches per second to 0.750 ips in the horizontal direction and 0.344 ips to 0.489 ips in the vertical direction.
The Acceptable Range at that time was 0 - 0.900 ips which was from the 2nd Ten Year 4
0 r-.
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Interval IST Program Relief Request PR-1.
This limit was based on ASME Technical Paper #78-WA/NE-5, Table 2.
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j Although the vibrations were considered at that time to be in the acceptable range, the station realized that there was a need to reduce the vibration levels.
In June 1988, the station installed a five vane split impeller into the j
HPCI booster pump. This vendor-recommended change was implemented to eliminate.a vane passage frequency which was resonating the crossover'-
piping from the booster pump to the main pump.
The resonating crossover i
l piping induced a high horizontal vibration on the inboard bearing
' bracket of the main pump (Bearing 3).
The impeller change and an alignment of the turbine to the main pump resulted in a reduction in horizontal vibration to 0.494 ips and vertical vibration to 0.344 ips.
l l
In May 1992, the station made another attempt to reduce vibrations by i
l balancing the HPCI Turbine rotor and performing another alignment. This work resulted in a reduction in horizontal vibration in Bearing 3 to 0.189 ips. However, the vertical vibration in Bearing 3 increased to j
0.614 ips.
During this time the station revised the IST Program to reflect the more conservative vibration limits specified in ANSI /ASME OM-6.
This placed the Unit 2 HPCI in the ALERT range and 45-day increased frequency testing commenced.
The station also decided to try j
l specialized alignment equipment called Permalign to measure and track i
the thermal and dynamic movements of the HPCI train. The resulting l
Parmalign information was intended to provide insight into how to align L
the HPCI train so that the thermal and dynamic movements would allow the l
train to grow into alignment while running. The station has'previously used the.Permalign equipment on such constant running pumps as the l
Reactor Feed and Condensate pumps.
However, since this was.[the] first time the Permalign process-was used on HPCI, the information gathered was considered to be for information only.
The Permalign equipment is designed to identify thermal and dynamic movement in rotating assemblies.
It is normally used on constantly running equipment.
Standard practice is to zero out the Permalign lasers when the equipment is in the " cold" condition. The test is then l
initiated in conjunction with starting up the rotating equipment. The rotating equipment is then allowed to reach its normal operating parameters and target values are obtained with the Permalign lasers.
This data is then used at a later date when the rotating equipment is re-aligned in the'" cold" condition.
During thic re-alignment process, the rotating equipment is purposely offset in accordance with the previously obtained target values so that the equipment thermally and dynamically " grows" into alignment.
In the case of the HPCI Permalign test, the HPCI was run for approximately twenty minutes.
The data gathered by the Permalign l
equipment was in relation to the thermal and dynamic changes identified
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' for the first twenty minutes of run time. The station believes that the twenty minute run time was insufficient for the HPCI to reach its full thermal and dynamic growth.
In August 1992, the station took a Limiting Condition of Operation (LCO) to perform alignments using the Permalign data obtained in May 1992.
Seme limited moves were conducted using this data and the resulting viocations on bearing 3 ranged from 0.305 to 0.369 ips in the horizontal j
a.d 0.225 to 0.529 ips in the vertical direction. Using all of the Permalign data to the fullest extent would have entailed performing modific4tions such as the shaving of the pump footings and the cutting and redesign of the pump's discharge piping supports. The station was reluctant to perform these tasks because of the cost involved in designing and performing these modifications and the level of uncertainty in the interpretation of the Permalign data.
This uncertainty was based on the fact that the data was taken after only a twenty minute run time, which was insufficient for the HPCI to reach its full thermal and dynamic growth.
As part of an effort to improve the HPCI system performance, the station plans to perform some significant maintenance activities on the Unit 2 HPCI during the Fall 1993 maintenance outage.
Five Exempt changes j
(minor modifications) are scheduled which will replace all of the oil pressure switches, upgrade the level switches, and upgrade the' flow and pressure transmitters. Additionally, nine Corrective Maintenance work requests are scheduled which include valve' repairs, local valve control stations and control switch repairs, replacement of temperature recorders, and the diassembly of the motor gear unit.
4 As part of this work, the station will make adjustments to the HPCI motor speed changer and motor gear unit to adjust the pump flow characteristics to better meet the pump curve.
The station sill also take alignment readings of the HPCI turbine / pump train in the cald condition using the station's regular alignment equipment to establish a L
baseline for future Permalign tests.
The pump's vendor has also l
recently recommended a modification intended to reduce another vane passage frequency which was resonating the crossover piping from the booster pump to the main pump.
It is believed that the resonating crossover piping is inducing a high vibration on the inboard bearing bracket of the main pump (Bearing 3). The recommendation is to disassemble the booster pump and cut the volute lips to increase the l
" Gap B" clearance. The station plans on performing the Gap "B" l
[C]learance Modification during the Q2R13 Refuel Outage in September 1994. Since an investigation into the Permalign process revealed that the actual permalign data would be affected by the higher flow rates of the system and the gap "B" clearance, the station plans on completing these modifications and maintenance actions prior to retaking the Permalign data.
Once the listed modifications and maintenance actions are complete, the station plans to enlist the assistance of the Permalign technical representative to incorporate a new improved set up process for this device.
The assistance is intended to allow the station to gain the most effective use of the Permalign and eliminate the uncertainties in the previously collected Permalign data.
Preliminary discussions indicate that an improyed set [-]up process may be required which will entail the fabrication of new brackets to support the Permaliga device components. The station plans to be ready to retest b:ing the Permalign device at the end of Q2R13 (December 1994) and evaluating the results with technical experts thereafter. Actual alignment moves based on the new Permalign data would then be scheduled to be performed during the following refueling outage, Q2R14 (Spring 1996).
Spectral Analysis of the current vibration data indicates no evidence of bearing degradation on any of the Unit 2 HPCI pump bearings.
The pump vendor considers the current vibration level of 0.374 ips on bearing 3 to be "relatively moderate" and only recommended to continue monitoring for any sudden increases in vibration amplitude until the Gap "B" clearance Modification is performed during the Q2R13 [ refueling outage].
Spectral Analysis is routinely performed on all of the bearings on the Unit 2 HPCI [ pump] during the quarterly IST surveillance.
Based on the i
spectral analysis and the vibration improvements already achieved, the station is confident that the existing vibration levels are not indicative of a degraded condition.
If the planned maintenance and modifications prove to be successful in reducing the vibration levels consistently below 0.300 ips, this interim relief request will be 4
withdrawn and the provisions of RP-00A will be followed for the Unit 2 HPCI.
3.1.2 Alternative Testina f
The licensee proposes:
4 The allowable ranges of vibration velocity for Unit 2 HPCI [ pump] will be based on Table 2.
The purpose of the increased Alert Range limit of 0.425 ips is to relieve the station of having to test the Unit 2 HPCI
[ pump] on an increased frequency which would cause additional normal wear of the pump. Since the increased frequency test is to monitor
[for] a degraded condition and no degradation has been detected, then there is no benefit to running the HPCI pump on an increased frequency.
However, 0.425 ips is also relatively close enough to the highest measured vibration data, so that if any additional pump degradation occurs, the pump would still be placed in the Alert Range and on an increased monitoring frequency.
r
- Table 2 ALLOWABLE RANGES OF VIBRATION VELOCITY Acceptable Required Ptanp Type Range Alert Range Action Range Centrifugal with speed 5 1.5 V, or
> 1.5 v, and
> 2.5 V, or
> 600 RPM 5 0.425 ips 5 2.5 V, or
> 0.700 ips (U2 HPCI ONLY) whichever is less
> 0.425 ips whichever is less and 5 0.700 ips whichever is less V,:
vibration reference value ips:
inches per second i
Applicable Time Period:
Interim relief is requested for until the end of Q2R14 (June 1996) or until the station is successful in reducing the vibration levels consistently below 0.300 ips, whichever is sooner.
3.1.3 Evaluation The licensee has made a number of attempts to reduce the vibration levels, with some success; however, the levels have not been reduced to the point where they will be consistently below an alert limit of that required by OM-6 (0.325 ips).
Consequently, without relief to raise the alert limit for the HPCI pump, testing would be conducted twice as frequently as required for pumps operating within the acceptable limits (i.e., once every 6 weeks).
Although the condition of the pump indicates that phenomena continue to occur, resulting in the current vibration levels, the pump is not operating at a level that indicates imminent failure. According to various standards for monitoring vibration, levels in the range of 0.425 ips are in the " rough" range. A range that requires action would be consistent with the " required action limit" of OM-6 (0.700 ips). The licensee has not proposed to raise the limit which requires declaring the pump inoperable and performing corrective action.
The " alert range" exists so that a pump which has indicated an increase in vibration levels will be monitored more closely to ensure that if any further increases above the " required action" limit occur, the condition will be identified at one-half the normal test interval. Most often, action is taken to correct the apparent condition prior to exceeding the " required action" limit.
In the specific case of the HPCI pump, the current levels do not represent an increase.
In fact, the levels have been reduced from previous levels. Thereforr, the intent of the " alert range" can be met for the HPCI pump at a higher level, and continues to have an alert range to monitor for increases prior to exceeding the " required action" limit.
Requiring the licensee to continue to test the pump at twice the frequency constitutes a hardship, and because the intent of OM-6 to monitor for increasing levels above a reference value will be met, there would be no compensating increase in the level of quality and safecy by imposing the requirements of 0.325 ips as the alert limit. Because the licensee has ;nvestigated the condition and
l
- l it appears that additional action may reduce the levels even further, thereby improving the operation of the pump for the long-term, relief for an interim period is appropriate.
In the interim period, the licensee should determine I
if the levels can be reduced further, as described in the basis for relief, or l
obtain certification from the pump vendor that operating the pumps with the l
current levels is acceptable for long-term conditions.
1 3.1.4 Conclusion l
The proposed alternative to use an alert value of 0.425 ips in lieu of 0.325 l
ips for the Unit 2 HPCI pump is authorized for an interim period pursuant to 10 CFR 50.55a(a)(3)(ii) based on the hardship that would ensue if the regiiirements are continued to be imposed, in the interim, without a compensating increase in the level of quality and safety.
The interim period i
extends until the refueling outage scheduled for 1996 (Q2R14).
The licensee has indicated that this relief request will be withdrawn if the current vibration levels are lowered prior to Q2R14.
3.2 Anomalies from Previous 10-Year Interval Proaram SE In NRC's SE fo-the second 10-year interval program, dated December 2,1991, a number of anomalies were identified.
The revised program included actions taken to address these anomalies. Attachment 1 of the SE gives a summary of the items, the action taken, and the current status as addressed in the revised program or through Code changes applicable to the 1986 Edition of Section XI.
4.0 CONCLUSION
The licensee's IST program requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance from INEL.
INEL's evaluation (TER) of the licensee's IST program relief requests is provided as Attachment 2.
The staff has reviewed the TER and concurs with the evaluations and recommendations for granting relief or authorizing alternatives, except as discussed in Section 3.1 above.
A summary of the l
relief request determinations is presented in Table 1.
The authorizing of alternatives or granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed.
The implementation of IST program is subject to l
inspection by the NRC.
The NRC has identified a number of generic deficiencies that affect plant safety and have frequently appeared as IST programmatic weaknesses.
These are addressed by Generic Letter 89-04.
In that letter, the staff delineated positions that describe deficiencies and explained alternatives to the ASME Code that the staff considers acceptable.
If alternatives are implemented in accordance with the relevant position in the generic letter, the staff has determined that relief should be granted pursuant to 10 CFR 50.55a(f)(6)(i) on the grounds that it is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest.
i
-g-In making this determination, the staff has considered the burden on the licensee that would result if the requirements were imposed.
For any relief granted pursuant to Generic Letter 89-04 the staff, with technical assistance from INEL, has reviewed the information submitted by the licensee to determine whether the proposed alternative follows-the relevant position in the genetic letter.
If an alternative conforms to a position of the generic letter, it is listed as having been approved pursuant to Generic Letter 89-04 in Table 1 of the safety evaluation. Any anomalies in the relief request are addressed in the TER and identified in Table 1.
Relief requests which are in accordance with the 1989 Edition of ASME Section 1
XI (which incorporated OM-6 and OM-10) have been approved pursuant to 10 CFR 50.55a(f)(4)(iv) as listed in Table 1.
A portion of Relief Request RV-30A is authorized for an interim period.
Relief requests applicable to only non-Code components are not evaluated, as these components are not within the scope of 10 CFR 50.55a.
The licensee should refer to the TER, Appendix A, for a discussion of IST program anomalies identified during the review. The licensee should resolve all items in accordance with the guidance therein.
The IST program relief requests acceptable for implementation provided the action items identified in Appendix A of the TER are addressed within one year of the date of this SE or by the end of the next refueling outage, whichever is later.
The licensee should respond to the NRC within one year of the date of this SE describing actions taken, actions in progress, or actions to be taken, to address each of these items.
The staff concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions.
The staff has determined that granting relief pursuant to 10 CFR 50.55a(f)(6)(i),
authorizing alternatives pursuant to 10 CFR 50.55a(a)(3)(i) and (a)(3)(ii),
and approving alternatives pursuant to 10 CFR 50.55a(f)(4)(iv) is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.
In making this determination, the staff has considered the impracticality of performing the required testing and the burden on the licensee if the requirements were i
imposed.
l Principal Contributor:
Patricia Campbell, DE/EMEB Dated: May 3, 1993
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1 QUAD CITIES STATION UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS 1
1 l
l Relief TER Section XI Equiprnent Proposed Alternate NRC Action l
Request Section Requircuent Identification Method of Testing Number l
Pump 2.1.1.1 IWP-4510:
All pumps in the IST Measure pump vibration Alternate approved i
RP-00A Measure pump program velocity and use the allowable pursuant to Part i vibration ranges of OM-6 except for the 10 CFR 50.55a displacement high pressure coolant injection (f)(4)(iv), provided all (HPCI) pumps.
related requirements are met.
Pump 2.3.1.1 Table IWP-3100-2:
HPCI pumps:
Measure pump vibration Altemate authorized RP-00A Allowable ranges 2302 velocity and use the allowable pursuant to (a)(3)(ii)
Part 2 of test quantities ranges specified in the relief for interim period j
l (Addend.)
request.
(see SE Section 3.1).
Pump 2.1.2.1 IWP-3100:
All pumps in the IST Measure pump vibration Alternate approved RP-00B Measure pump program velocity.
pursuant to (f)(4)(iv),
bearing provided all related I
temperature requirements are met.
Pump 2.2.1.1 IWP-3100:
Standby liquid Measure pump discharge Alternate approved l
RP-11 A Measure inlet and control (SLC) pressure and flow rate.
pursuant to (f)(4)(iv),
differential pumps:
provided all related l
pressure 1102A and 1102B requirements are met.
j Pump N.A.
IWP-3100:
Diesel fuel oil Measure pump discharge Non-Code Class RP-52A Measure inlet and transfer pumps:
pressure.
components, request differential 5203 and 5203-1/2 not evaluated in pressure SE/TER Valve N.A.
IWV-3421 through All containment Leak rate test all CIVs in Approved by RV-00A
-3425 and 3427(b):
isolation valves accordance with Appendix J GL 89-04, Leak rate testing (CIVs),
and IWV-3426 and -3427(a).
Position 10, request requirements and not evaluated in corrective actions SE/TER.
Valve 3.1.1.1 IWV-3521:
All excess flow Exercise closed at the end of Alternate approved RV-00B Test frequency check valves, each refueling outage in pursuant to (f)(4)(iv),
accordance with plant technical provided all related specification (TS) 4.7.D.
requirements are met.
Valve N.A.
IWV-3417(a):
All power operated Assign a maximum stroke time Approved by RV-00C Stroke time valves with reference of two seconds for these valves GL 89-04, Position 6, measurement stroke times of one and declare them inoperable request not evaluated corrective actions second or less.
when it is exceeded.
in SETTER.
Valve 3.1.2.1 IWV-3417(a):
All power-operated Base the corrective action Alternate approved l
RV-00D Stroke time valves in the IST requirements on deviations pursuant to (f)(4)(iv),
corrective action program.
from reference stroke times.
provided all related requirements requirements are met.
1
QUAD CITIES STATION UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS l Relief TER Section XI Equipment Proposed Alternate NRC Action Request Section Requirement Identification Method of Testing Number Valve N.A.
IWV-3521 and The check valves Sample disassemble and inspect Approved by RV-00E
-3522:
listed in the relief during refueling outages GL 89-04, Position 2, Test frequency and request.
according to GL 89-04, request not evaluated method Position 2, to verify their full-in SEfrER.
stroke open capability.
Valve N.A.
1WV-3521 and The check valves Sample disassemble and inspect Approved by RV-00F
-3522:
listed in the relief during refueling outages GL 89-04, Position 2 Test frequency and request.
according to GL 89-04, request not evaluated method Position 2, to verify their in SE/TER.
closure capability.
Valve 3.1.3.1 IWV-3417(b) and All valves in the IST Evaluate each valve and take Alternate authorized RV-000
-3523:
program.
actions according to plant TS.
with provision Corrective action pursuant to (a)(3)(i).
requirements for valves tested at cold shutdowns Valve 3.2.1.1 IWV-3415:
The main steam Fail-safe test the MSIVs during Alternate approved RV-02A Fail-safe test isolation valves reactor refueling outages.
pursuant to (f)(4)(iv),
frequency (MSIVs):
provided all related 0203-001A-A0 requirements are met.
through -001D-A0 Valve N.A.
IWV-3411, -3521, The scram discharge Test valves at the frequency Approved by RV-03A and -3417(a):
for control rod scram tessag GL 89-04, Position 7, i
Test frequency and 0305-114 specified by plant Technics, request not evaluated
{
method and the scram inlet Specifications (TS). Indirectly in SEfrER.
and outlet valves:
measure stroke time.s by 0305-126 and -127.
measuring control rod scram Also the non-Code times and ensuring that they class valves:
are within TS limits.
0305-117 and -118 Valve N.A.
Transversing in-core Exercise valves closed during Non-Code Class RV-07A Test frequency probe nitrogen line each refueling outage.
components, request CIVs:
not evaluated in 0743 SEfrER Valve 3.3.1.1 IWV-3521:
SLC injection check Part-stroke exercise open Alternate approved RV-II A Test frequency valves:
during cold shutdowns and full-pursuant to (f)(4)(iv),
1101-015 and -016 stroke exercise open and closed provided all related at refueling outages, requirements are met.
2
QUAD CITIES STATION u.ITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS l
Relief TER Section XI Equipment Proposed Alternate NRC Action Request Section Requirement Identification Method of Testing Number Valve N.A.
IWV-3521:
Reactor core Exercise valves closed during Non-Code Class RV-13 A Test frequency isolation cooling each refueling outage.
, omponents, request (RCIC) vacuum not evaluated in pump discharge and SE/TER turbine exhaust line CIV chxk valves:
1301-040 and -04I Valve N.A.
IWV-3426:
The drywell vacuum Perform a combined leak rate Non-Code Class RV-16A Analysis of leakage breaker check valves:
test in accordance with plant components, request rates 1601-032A through F TS 4.7. A.4.6.4.
not evaluated in and SE/TER 1601-033A through F Valve 3.4.1.1 IWV-3521:
HPCI drain pot to Exercise open quarterly and Alternate approved RV-23A Test frequency torus CIVs:
verify their closure during pursuant to (f)(4)(iv),
2301-034, and HPCI refueling outages.
provided all related turbine exhaust line requirements are met, check valves:
2301 045 Valve N.A.
IWV-3521:
Containment Exercise valves closed during Non-Code Class RV-24A Test frequency atmosphere each refueling outage.
components, request monitoring system not evaluated in return line CIV SE/TER check valves:
)
2499-022A and
-022B Valve N.A.
IWV-3521:
Atmospheric Exercise valves closed during Non-Code Class RV-25A Test frequency containment each refueling outage.
components, request atmosphere 61ution not evaluated in supply line CIV SETTER check valves:
2599-023 A, -023 B,
-024A, and -024B 3
b QUAD CITIES STATION UNITS 1 AND 2 SAFETY EVALUATION TABLE 1 SUl! MARY OF RELIEF REQUESTS Relief TER Section XI Equiprnent Proposed Alternate NRC Action Request Section Requirement Identification Method of Testing Number Valve 3.2.2.t IWV-3411 and Safety / relief valves:
Exercise valves once every six Alternate frequency
)
RV-30A
-3417(a):
0203-003 A, and months during plant operation approved pursuant to Test frequency electromatic relief without measuring and (f)(4)(iv), provided and stroke time valves:
evaluating their stroke times.
related requirements testing 0203-003B, -003C, are met. Alternate
-003D, and -003E for stroke times
)
authorized pursuant to j
(a)(3)(i) for an i
interim period of one year or until the next refueling outage.
Valve 3.2.3.1 OM-1 Paragraph Safety / relief valves:
Test, rebuild, and reset valve Alternate authorized RV-30B 1.3.3.1.e:
0203-003 A, and 0203-003A and four safety pursuant to (a)(3)(i)
Relief valve safety valves:
valves each refueling outage.
corrective action 0203-004A through lf only one valve fails,
-004H additional valves will not be tested. If more than one valve fails, the sample expansion criteria of OM-1,1 1.3.3.1.e.
will be implemented.
Valve N.A.
IWV-3521:
Main steam Manually exercise valves open Non-Code Class RV-30C Test frequency safety / relief and inspect them to verify components, request discharge line closure during each refueling not evaluated in vacuum breaker outage.
SETTER check valves:
0220-081 A through E 0220-105A through E Valve N.A.
IWV-3411:
The main steam Exercise air operated valves by Non-Code Class RV-30D Test frequency isolation valve simulating a loss of instrument components, request (MSIV) air and air during cold shutdowns for not evaluated in solenoid-operated outboard MSIVs and during SE/TER control valves listed refueling outages for inboard in the request.
MSIVs. Exercise solenoid valves by pulling control power fuses during refueling outages.
Valve 3.2.3.2 OM-1 1 1.3.3.1.e:
Safety / relief valves:
Expand the sample size Alternate authorized RV-30E Relief valve 0203-003A, and consistent with relief request pursuant to (a)(3)(i) corrective action safety valves:
RV-30A if the "as-found" 0203-004A through setpoint is outside i3 % of the
-004H design set pressure.
4
QUAD CITIES STATION UNITS 1 AND 2 SAFETY EVALUATION TABLE 1 i
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Proposed Alternate NRC Action Request Section Requirement Identification Method of Testing Number Valve 3.5.1.1 IWV-3521:
Wa feedwater Exercise the-i alves closed Alternate approved RV-32A Test frequency Ia.ler check valves:
during refw..ag outages.
pursuant to (f)(4)(iv),
0220-058A, -058B, provided all related
-059B, -062A, and requirements are met.
-062B Valve N.A.
IWV-3521:
Reactor building Exercise valves closed during Non-Code Class RV-37A Test frequency closed cooling water each refueling outage.
components, request (RBCCW) to drywell not evaluated in CIV check valves:
SE/TER 3799-031 Valve N.A.
IWV-3521:
Clean condensate Exercise valves closed during Non-Code Class RV-43A Test frequency supply to the drywell each refueling outage, components, request CIV check valves:
not evaluated in l
4399-046 SETTER Valve N.A.
IWV-3417(a):
Diesel generator air Measure diesel generator start Non-Code Class l
RV-46A Stroke time start solenoid valves:
times and ensure that the diesel components, request corrective actions 4699-226 and starts within 10 seeor.ds during not evaluated in
-226-1/2 diesel surveillance testing.
SEfrER Valve N.A.
IWV-3521:
Service air supply to Exercise valves closed during Non-Code Class RV-46B Test frequency the drywell CIV each refueling outage.
components, request check valves:
not evaluated in 4699-047 SE/TER Valve N.A.
IWV-3521:
Air actuator Verify valves closed by Non-Code Class RV-47A Test frequency accumulator check performing a special components, request valves for the MSIV accumulator pressure test not evaluated in and SRV during each refueling outage.
SE/TER accumulators:
0220-084A through D and 4799-281 A l
Valve N.A.
IWV-3521:
Instrument air supply Exercise valves closed during Non-Code Class RV-47B Test frequency to the drywell CIV each refueling outage, components, request check valves:
not evaluated in 4799-155,-156, SEfrER
-158, and -159
)
Valve N.A.
IWV-3417:
Diesel fuel oil verify valve operation by Non-Code Class RV-52A Stroke time transfer line solenoid verifying re-fill of the day tank components, request corrective actions valves:
following each diesel not evaluated in 5201-SO and -SO-1/2 operability test.
SETTER i
5
QUAD CITIES STATION UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS Relief TER Section XI Equipment Proposed Alternate NRC Action Request Section Requirement Identification Method of Testing Number Valve 3.4.2.1 IWV-3521:
HPCI turbine exhaust Exercise valves during cold Alternate authorized CS-23B Test frequency line vacuum breaker shutdowns.
pursuant to (a)(3)(ii) check valves:
2301-064,-065,
-066, and -067 i
i i
6 l.
1
ATTACHMENT 1 I
Suunnary of Staff Findings on Coussonwealth Edison Company i
Quad Cities Units 1 and 2 e
Response to NRC IST Safety Evaluation Docket Number 50-254 and 265 Dearripties of Artiene Takaa h ofleem Amenely Number Descripelem oflease to NRC SE In the Jammary 7,1993, Ilesponse and (Rdier Reaguest No.)
Desed December 2,1991 to Addrums SE Iessee Reassiming Artiam i
Anornely No. I De licemese bee est jossified eluumme* ion J the whomon ebentene liaise for the CECO bas revised RPMA (se part of the shird ten-year Redeed RP@A is evaluesed (RP40A)
HPCI and RHRSW pompe. De preposeJ lianies for cesariesgel possys M senerval IST Ptw) so provide addsesonal suppost in the August 1993 TER, e
be applied so these punips se well. AdditomeNy, she licenses should eamere thes which desnessarsees ibet sa *eccepeeble level of apselity Section 2.1.1.1, for using nu of the elenienee of vibreason W in 0844,1988, are incheded in the and eefety'is snaisemined for die HPCIpompe. De vibreasce velocisy l
Quad Cities peograni. A specific relief request addreening she Unit 2 HPCI sepersee RHRSW discussion wee reanowed aisce these sneesurennewsin accordance l
pump could le sebasesed,if the licemmes ceajunify that she vibreasos levels pumpe are capable of sneeneg time vibressoa accepeance wish 0h44.His ehernative is j
being experienced on this pussy io not adversely effect +.-
! readiness of criteria requeseed in this relief. De revision so RP40A approved purumore so j
die peng.
also requeme absolute vibrahon lismise for the HPCI 10 CFR 50.55e(fx4)(iv) pumps, recher alien eliasiention of she lineite.
provided all re:M
+
requirenicsee are met. TER Section 2.3.1.1 evaluesee the proposed ehernese afkmeble reages l' r eine HPCI penge o
and the ehermose is authorund
{
Purmese to 10 CFR 50.55e(eX3)(ii).
l i
i
?
1 1
l 1
l l
1 i
l i
(
Descriptise of Arename Takes Staeus of leem Amesmaly Nussber Descrip6am of hasm im NRC SE In she Jammary 7,1993 Rampasse and (Reaief Regmane N.)
Desed Decemeber2,1991 to Address SE home Ramesumeg Aceism Anomaly W. 2 The licensee's basis for'RP-00C appears to mailiae IWP-3210, " Allowable CECO hee delseed Relief Request RP-00C froan the third General reliefis no longer
{
j (RP-00C)
Ranges of laservice test Quessities.* es en argunnese against establishing new ten-year ireerval IST Program W froan the seimand l
seferesve values. k eypeers shot RP40C would mIlow the liceasse to cd-Code requiremanese W to reif w a pusar which hee desnaastreesd obvious degradation by perfornusig Auther action is requered t
en opersbelity emelysis and expending the eBowable reswee. This course of l
action is inc wish the inness of ASME Secesom XI which is to identify degsh of cease is as efleet to emmere 4 readiness of jl pesaye end velves. Deviations doescase are symyeoms of changes end.
depending upon abe degree of dem endicees need for Asriher teste or correcerve action. 8:,
__ of she alloweble rences per IWP-3210 is to l
provide ownere a - of "
. pumps wie low reases and anevow niergame asch shot monmal opermosom is dessommersend wishin eccepenble, examented
- lisnies,
-t to enow e=& of to reases en onceswees devemances of manchemical or hydraube '
- id"hAed during inservice testing. The r-sned to eenabhsti mew reference values following me, " _-, analysis is to ellow other seguirennessa of IWP to be must wishie te new reage of operassag 4
c=d a-which have been deseramend accerembas by the emnlyss Refesence
[
veh.ee are Emed values for.,
' '2, isr-I
. Immervice sessing. The
{
Iicensee is commoned in using RP-00C under she oppsevel provemose of GL 3944. If a degraded pump has W devisesens wiein she required action range of Table IWP-3100-2. it is to be declared '
.. and not rensraad so service useet eine cause of the deviseman has been desernumed and she condiosos corrected. If correction is by emelyme, new reference values should be estabhahed is enter to set new requesed actice resse values rusher them espondseg she required action resse. To use lose c -
._. reases per IWP-3210, abe Owner shall show shot she everall pusup r '
e hoe not i
degraded noen its iseended Asocesos. This would be diflicult to % if a pung is sheedy r- '-. beyond requead action limine. Reliance ce RP-OOC does not preclude she liceasse tous mesessag to renommag regismammans of IWP for immervice ensning. Ammetson Anommely N. 3 The licensee should ensure that the regunemaans of IWV-3426 and CECO bee included ebenimee limies for valve leakage in The sevised RV40A tests (RV40A)
IWV-3427(e) for emelysis ofleakage sense and cerveceeve action will c-so specine leek rese procedines, as well es currective CIVe in accontence wiik be nies, se reysered by GL 3944, y-10.
actions for valves exceedig the respective Bismise.
GL 99-04. Pbeeson 10. This eheressive is approved by the Gemenc laaer med no Amritmer action is required.
i 1
2 I
Description of Actions Taken Status of item Amassaly Narntwe Description ofItam im NRC SE In the January 7,1993 Response and (Relief Request Nej Dated Decesaber 2,1991 se Addrisa SE Items Resmaining Action Annmaly No. 4 he licenace is to assigdlimiting values of stroke times, as applicable per their CECO has revised Relief Request RV-00D (as part of The revised RV40D is (RV40D) technical apprunch and position 1V40A, armi assign a lower limiting value of 3 the third ten-year irmerval IST Program) to enhance the evaluated in TER Section seconds and an upper limiting value of $ seconds for MSIVe per TS basis with a discussion of the conservaiism achieved by 3.1.2.1 and the shernative is requirements.
this relief request. De revision also added additional approved pursuant to text in the %uposed Ahernate Testing acetion to define 10 CFR 50.55a(f)(4)(iv),
the Quad Cities Station's methodology for establishment provided all related of full-stroke and reference arnke time values.
requiremerne are met.
Anomaly No. 5 ne licenace should explicitly state that all valves within each grouping will be CECO has revised Relief Request RV-00E (as part of ne revised Rv40E performe (RV40E) disassembled and inyected at least once every six years. Without this the third ten-year interval IST Program) to strengthen check valve disassembly and clanfication, extension of the interval beyond six years snust be jumified.
and clarify the justification provided in the relief inspection in accosilance with Additionally, the valves should be partial stroke exercised quarterly, et cold request.
GL 89 04 Position 2. This shutdown, or following reassembly, if possible. He licenace is encouraged to ahernative is appruved by the pursue other positive means for verification of flall-stroking of these check Generic letter and is also valves, such as non-irerusive techniques.
addressed in the TER, Appendix A, item 3.
Anornaly No. 6 he licensee ahmid determine a means of verifying valve closure arber than CECO has revised Relief Request RV40F (as part of The revised RV40F performa (RV40F) employing
- disassembly and inspection program. If no other means, including the third ten-year interval IST 5% gram) m strengthen il eck valve disassembly armi non intrusive, can be utilized, specific relief for each individual va*ve, or group and clarify the justification provided in the relief ingection in accordance with of sinular valves, will be required describing the reasons why no other means request.
GL 8944. Pbsition 2. nie are available.
ahernative is approved by the Generic leser amiis also addressed in the TER.
Appendix A, hem 3.
Anomaly No. 7 he licennec indicates that the *as-found* eetpoirs testing done at the test CECO has revised Relief Request RV-308 (as part of Revised RV-30B is evaluated (RV.308) facihty is not necessarily representative of a valve's coralition when it =se the third ten year interval IST Program) to incorporate in TER Section 3.2.3.1. De inmalled in the plant. The 1980 Edition of Section XI with addenda through the requiremersa of ASMFJANSI O&M i, and to submit proposed ahernative provides the 1980 Wirmer Addendum, the Code applicable to the current iederval Quad an ahernate plan for marryle expansion of relief valve an equivalers level of quality Cities IST Program, requires safety and relief valve setpoints be tested in setpoint testing.
and safety as the related accordance with ASME I'TC 25.3 - 1976. Sectson 3.09 of the l'TC requires requiremeras of OM-l and is that no adjustmers to the valve shall be made during the test. De TS authorued pursuant to requiremeras for testing these valves are written to ennsre that at least one4alf 10 CFR 50.55a(s)(3)(i).
of the nine safety valves are property set prior to startup from a refueling outage. De purpose of ASME Code,Section XI, innervice teming is to monitor the conddion of punpa and valves to provide assursace of operational readiness of the congonerna. One aspect of the inservice testing per IWV-3513 not covered by TS requiremeses is that when a degraded condition on one valve is identified, additional valves are tested to assess if other corryonerna could also be ofTected. Applying this relief could result in a situation where all of the tested valves fail wnh no further testing of the remaining valves.
3
__mm.
.... =, - _.~..-. -.--...- - -.~.- _._ __-=._..__
__m--
--. _ ~
I Descripelse of Artisms Tehen Shahms of leem Amassely Na L. '.
aflesem im NRC SE In she Jemmary 7,1993. Respamme and (Relief Roguest No.)
Desse December 2,1991 ee Addrues SE lemme h - l=Img Acelen Amomely No. 8 Technical Approach and Pbenson Summmary TV40C and TV-16A selsse to CECO hee sevised Relief Roguest RV 16A (as poet of Revised RV-16A levolves L
(N. A.)
testing --
-h welves or ",.. "'-__d vacuum benekere in the thisd see-year iseerval IST Ptogress) to incorperuse only someCode Cinee i
groupe recher than ' ~ ^ ",. Generesy, saliefie regnered for test Technical Appecach and W TV40C and -16A.
ce dans sequestis configuressame which do set amessaar welwee * *. " ",. The hcemene shamed not evenmaned in ene SE/TER.
i comender sulumsuses these W as selief sequesse If may valves in she groupsage can be sessed '_
",, the smeenseed indmenal leakage sense steamste be subasected tema die leakage snee measserad for she geoup.
Annesaly No. 9 Regnedsag Technical Appseech med Passesse Summmary TV-00F. For antasy and CECO hee incospesseed the guidelisse of ASME/ ANSI Safety and relief velves ese (N. A.)
nelief welves, Frc-25.319M (met FTC-25.2-19M)is to be medsand for W OaM-1 imeo the shied een-year Isserval IST Progresa.
eened ie acceedence wish the per the 1980 Edsesom of Seselse XI. The.
of Seceae 3.0, Gusemig requeensense of OM-l.19sI Principale, se well se the,
- seedsmoso nessing requeroameses of as specified in IWV-35 t l of Section 4.09 are to be sust.
she 1986 Edseson of Sectim XI. No Amriber action is sogared Amosmaly No.10 The fuequency for sencear refW indicense shot no deressam in days le CECO bee revised the Tee Fregenency Abbrewh (as The necessary progvem (N. A.)
applicable becesses in Jose sat have e sepoemswo deresson, The hcommne M post of the ibied nen-year isnerwal IST Ptograms) to changes have been sende, descensine e san =h duressas for a *seAmeling* nequency such he if as incorpermes respective duressame sharefase, no nestber action ie essended shundown occare,immervice nessing for e ammber of valves -
requered to be sessed derisig :=Ameling cuences wesad be sessed de% she essended shundown,if poemshie GenereEy, die asah dureesee for a seAmehas nequency is beesd on iIne Asel cycle for a pInsa, up to 24 smondie. The frequency wiu impact ignem for check velwes lecteded in the hcommee's desmenemedy and :__, _ % which M be serucessed on e --
schedule of 6 yeere unione se ensnans heedshqp is jmssened, es deaevibed in OL 3944, Femason 2.
i e
4
.