ML20052B831

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Safety Evaluation Rept,Pumps & Valves Inservice Testing Program,Nine Mile Point Nuclear Station,Unit 1.
ML20052B831
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 02/28/1982
From: Rockhold H
EG&G, INC.
To: Page J
Office of Nuclear Reactor Regulation
References
CON-FIN-A-6258 0567A, 567A, EGG-EA-5767, NUDOCS 8205040020
Download: ML20052B831 (24)
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Text

EGG-EA-5767 FEBRUARY 1982 A)k0 feSearekaad co WCAnsca$ kFurikurce j R/J' n

SAFETY EVALUATION EPORT, PUMPS AND VALVES l/Ok INSERVICE TESTING PROGRAM, NINE MILE POINT A)SId NUCLEAR STATION, UNIT 1

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aw ;L This is an informal report intended for use as a preliminary or working document Prepared for the U.S. Nuclear Regulatory Commission Under DOE Contract No. DE-AC07-761001570 g FIN No. A6258 pg 66EGio no 82050400% . ._ ____

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FORM EG4G 396 f,ev 1189 INTERIM REPORT Accession No.

Report No. _ EGG-EA-5767 Contract Program or Project

Title:

Systems Engineering Support

. Subject of this Document:

Safety Evaluation Report, Pumps and Valve: Inservice Testing Program, Nine Mile Point Nuclear Station, Unit 1 Type of Document:

Safety Evaluation Report Author (s):

H. C. Rockhold Date of Document:

February 1982 Responsible NRC/ DOE Individual and NRCIDOE Office or Division:

J. D. Page, Division of Engineering, NRC This document was prepared primarily for preliminary or internat use. it has not received full review and approval Since there may be substantive changes,this document should not be considered final.

EG&G Idaho, Inc.

Idaho Falls, Idaho 83415

  • Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.

- Under DOE Contract No. DE-AC07-761D01570 NRC FIN No. A6258 INTERIM REPORT

l 0567J SAFETY EVALUATION REPORT--PUMPS AND VALVES INSERVICE TESTING PROGRAM, NINE MILE POINT NUCLEAR STATION, UNIT 1 4

February 1982 0

H. C. Rockhold

, Reliability and Statistics Branch Engineering Analysis Division EG&G Idaho, Inc.

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ABSTRACT This EGE Idaho, Inc. report presents the results of our . evaluation of the Nine Mile Point Nuclear Station, Unit 1, Inservice Testing Program for safety-related pisnps and valves.

FOREWORD This report is supplied as part of the " Systems Engineering Support" being conducted for the U.S. Nuclear Regulatory Comission, Office of Nuclear Reactor Regulation, Division of Engineering, by EGM Idaho, Inc.,

Reliability and Statistics Branch.

The d.S. Nuclear Regulatory Comission funded the work t'nder tne authorization B&R 20 19 01 09, F IN No . A 6258.

e 11

CONTENTS I. INTRODUCTION .................................................. 1 II. PUMP TESTING PROGRAM .......................'................... 2

1. Safety-Related Pumps ..................................... 2

, 1.1 Relief Reauest ....................................... 2 III. VALVE TESTING PROGRAM EVALUATION .............................. 3

1. General Considerations .................................... 3 1.1 Testing of Valves which Perform a Pressure I s ol a t ion F un ct io n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.2 Stroke Testing of Check Valves ....................... 4 1.3 Test Freauency of Check Valves Tested at Cold Shutdowns ....................................... 4 1.4 Licensee Reauest for Relief to Test Valves at Cold Shutdowns .................................... 5 1.5 Technical Specification Changes . . . . . . . . . . . . . . . . . . . . . . 5 1.6 Safety-Related Valves ................................ 6 1.7 Valve Tes ti ng at Cold Shutdowns . . . . . . . . . . . . . . . . . . . . . . 6 1.8 Category A Valve Leak Check Reauirements for Cont ainment Isolation Valves (CIVs) . . . . . . . . . . . . .. 6 1.9 Application of Appendix J Testing to the IST Program .......................................... 7
2. Generic Relief Requests ................................... 7 2.1 Category A, A/C and A/E Val ves . . . . . . . . . . . . . . . . . . . . . . . 7
3. Main Steam System ......................................... 9 3.1 C a teg o ry A V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 t

3.2 Category B/C Valves .................................. 10

4. L i a u i d P o i so n Sy s t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l 4.1 C ate g ory A/C Val ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
5. Cont ainment Spray and R aw Water Systems . . . . . . . . . . . . . . . . . . . 11 l 5.1 Category C Valves .................................... 11

! 6. CRD Hydraulics Systems .................................... 12

. 6.1 Ca te go ry B an d C Val ves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

7. F e ed w a t e r Sys t em . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 l

t 7.1 Category A/C Valves .................................. 12 iii l

i l

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-8. Reactor Water Cleanup System .............................. 13 8.1 C a teg o ry A /C V a l ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

9. Drywel l an d Torus System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 9.1 C a teg o ry A /C V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
10. E me rg ency Cool i ng System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 10.1 C a teg o ry C V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 IV. APPENDIX A .................................................... 15 .

C ode R eq ui r emen t--V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 1.

V. AT T A CH ME NT I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 17 VI. ATTACHMENT II .................................................

1. E me rg en cy Cool i ng Sys tem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 18 VII. ATTACHMENT III ................................................

iv

I. INTPCDUCTION Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by the Niagara Mohawk Company for its Nine Mile Point Unit 1 Nuclear Station. The working session with Nine Mile Point Unit i representatives was conducted on October 7 and 8,1980. The licensee resubmittal was issued on August 7,1981, and reviewed by EG&G Idaho, Inc.,

to verify compliance of proposed tests of safety-related Class 1, 2, and 3 pumps and valves with requirements of the ASME Boiler and Pressure Vessel Code,Section XI,1974 Edition, through the Summer of 1975 Addenda. Nine Mile Point Unit 1 has also requested relief from the ASME Code from testing specified pumps and valves because of practical reasons. These requests

. have been evaluated individually to determine whether they have significant risk implications and whether the tests, as required, are indeed imprac-tical.

The evaluation of the pump testing program and associated relief requests is contained in Section II; the evaluation of the valve testing program and associated relief requests is contained in Section III. All evaluations for Sections II and III are the recommendations of EG&G Idaho, Inc.

A sunnary of valve-testing requirements is provided in Appendix A.

Appendix J exenption requests for Category A valves currently being reveiwed by the NRC are contained in Attachment I.

Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not exercised every three nonths are contained in Attachment II.

A listing of P& ids used for this review are contained in Attach-ment III.

e 1

l II. PUMP TESTING PROGRAM The IST program submitted by Nine Mile Point Unit 1 was examined to verify that Class 1, 2, and 3 safety-related pumps were included in the program and that those pumps are subjected to the periodic tests as reouired by the ASME Code,Section XI. Our review found that all Class 1, 2, and 3 safety-related pumps were included in the IST program and, except for those pumps identified below for which specific relief from testing has been requested, the pump tests and freauency of testing comply with the

  • code. Each Nine Mile Point Unit 1 basis for requesting specific relief and the EG&G evaluation of that request is summarized below.
1. Safety-Related Pumps
  • 1.1 Relief Request Relief is requested from the monthly pump testing requirements of Section XI for the following safety-related pumps.

Core Spray Injection Pumps lil , 112, 121, 122 Core Spray Topping Pumps lil, 112, 121, 122 Containment Spray Pumps 111, 112, 121, 122 Control Rod Drive Pumps 11, 12 Containment Spray Raw Water Pumps lil , 112, 121, 122 1.1.1 Code Requirement. IWP-3400 states the following:

(a) An inservice test shall be run on each pump, nominally each month during normal plant operation. It is recomended that this test frequency be maintained during shutdown periods where this can reasonably be accomplished, although this in not mandatory. If it is not tested during plant shutdown, the pump shall be tested within one week af ter plant is returned to normal operation.

(b) Pumps that are operated more frequently than every month need not be run or stopped for a special test, provided the plant log shows each such pump was operated at least once every month at the reference conditions and the quantities specified were mea-sured, observed, recorded, and analyzed.

1.1.2 Licensee's Basis for Requesting Relief. The past record at NMP-1 indicates the reliability of the pumps would not improve by monthly cycling. Monthly cycling would promote excess stress and strain on pump / motor design life. As an alternate, testing will be scheduled auarterly to ensure continued operability.

1.1.3 Evaluation. The licensee has stated that the past record of pump testing at NMP-1 indicates monthly pump tes+1ng would promote excess stress and strain on the pump / motor design life but has failed to provide ,

the data to support this determination. Therefore, we feel relief should not be granted from the Section XI reauirements to perform monthly pump tests until the licensee provides the supporting data that led to these conclusions.

2

III. VALVE TESTING PROGRAM EVALUATION The IST program submitted by Nine Mile Point Unit I was examined to verify that Class 1, 2, and 3 safety-related valves were included in the program and tnat those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and guidelines. Our review found that all Class 1. 2, and 3 safety-related valves were included in the IST program and, except for those valves identified below for which

  • specific relief from testing has been requested, the valve tests and fre-auency of testing comply with the code requirements and the NRC positions and guidelines listed in Section 1. Also included in Section 1 is the NRC position and valve listings for the leak testing of valves that perform a
  • pressure isolation function and a procedure for the licenee's use to incor-porate these valves into the IST progr=. Each Nine Mile Point Unit 1 basis for requesting relief from testing valves and the EG&G evaluation of that request is summarized below and grouped according to system.
1. General Considerations 1.1 Testing of Valves which Perform a Pressure Isolation Function Several safety systems connected to the reactor coolant pressure boun-dary have design pressures below the reactor coolant system operating pres-sure. Redundant isolation valves within the Class I boundary forming the interface between these high- and low-pressure systems isolate low-pressure systems from pressures which exceed their design limit. In this role, the valves perform a pressure isolation function.

The NRC considers the redundant isolation provided by these valves to be important. The NRC considers it necessary to assure that the condition of each of these valves is adequate to maintain this redundant isolation and system integrity. For these reasons, the NRC believes that some method, such as pressure monitoring, leak testing, radiography, or ultrasonic test-ing, should be used to assure that the condition of each valve is satisfac-tory in maintaining this pressure isolation function.

If leak testing is selected as the appropriate method for achieving this objective, the NRC and EG&G Idaho, Inc., believe that the following valves should be categorized as A or AC and leak tested according to IWV-3420 of Section XI of the applicable edition of the ASME Code. These valves are:

34-01 Reactor Head Spray Isolation Valve 34-02 Reactor Head Spray Isolation Valve 37-01 Reactor Vent Line Isolation Valve 37-02 Reactor Vent Line Isolation Valve 37-06 Reactor Vent Line Isolation Valve 31-01 Reactor Feedwater Header Check Valve 3

31-02 Reactor Feedwater Header Check Valve 38-12 Shutdown Cooling to Reactor Isolation 38-13 Shutdown Cooling to Reactor Check Valve

. 38-01 Shutdown Cooling from Reactor Isolation 38-02 Shutdown Cooling from Reactor Isolation ,

40-01 Core Spray to Reactor Isolation Valve 40-03 Core Spray to Reactor Check Valve 40-09 Core Spray to Reactor Isolation Valve 40-10 Core Spray to Reactor Isolation Valve 40-11 Core Spray to Reactor Isolation Valve 40-13 Core Spray to Reactor Check Valve 40-05 Core Spray to Reactor Isolation Valve 40-06 Core Spray to Reactor Isolation Valve The NRC and EG&G Idaho, Inc., have discussed this matter with the licensee and identified the valves listed above. The licensee agreed to consider testing and categorizing each of these valves with the appropriate designation, depending on the testing method selected. Whatever method the licensee selects for determining the condition of each valve, the licensee will provide to the NRC, for evaluation, the details of the testing method which clearly demonstrates the condition of each valve.

1.2 Stroke Testing of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full stroked. If only limited operation is possible (and it has been demonstrated by the licensee and agreed to by the NRC), the check valve shall be partial stroked. Since disc position is not always observable, the NRC staff stated that verification of the plant's safety analysis design flow rate through the check valve would be an adequate demonstration of the full stroke requirement. Any flow rate less than design will be considered part stroke exercising unless it can be shown that the check valve's disk position at the lower flow rate would be equivalent to or greater than the design flow rate through the valve. The .

licensee agreed to conduct flow tests to satisfy the above position.

1.3 Test Frequency of Check Valves Tested at Cold Shutdowns ,

The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every three months for Cate-gory A and B valves and once every nine months for Category C valves. It 4

7 is the NRC's position that the Code is inconsistent and that Category C valves should be tested on the same schedule as Category A and B valves.

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

1.4 Licensee Request for Relief to Test Valves at Cold Shutdowns The Code permits valves to be tested at cold shutdowns, and the condi-tions under which this is permitted is noted in Appendix A. These valves are specifically identified by the licensee and are full stroke exercised during cold shutdowns; therefore, the licensee is meeting the requirements of the ASME Code. Since the licensee is meeting the requirements of the ASME Code, it will not be necessary to grant relief. However, during our review of the licensee's IST program, we have verified that it was not practical to exercise these valves during power operation and that we agree with the licensee's basis.

It should be noted that the NRC differentiates, for valve testing purposes, between the cold-shutdown mode and the refueling mode. That is, for testing purposes, the refueling mode is not considered as a cold shut-down.

1.5 Technical Specification Changes In a November 197E letter to the licensee, the NRC provided an attach-ment entitled, "NRC Guidelines for Excluding Exercising (Cycling) Tests of Certain Valves During Plant Operation." The attachment stated that, when one train of a redundant system such as in the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not be cycled if their f ailure in a non-safe position would cause a loss of total system function. For example, during power operation in some plants, there are stated minimum requirements for systems which allow certain limit-ing conditions for operation to exist at any one time and, if the system is not restored to meet the requirements within the time period specified in a l plant's Technical Specifications (T.S.), the reactor is required to be put in some other mode. Furthermore, prior to initiating repairs, all valves and interlocks in the system that provide a duplicate function are required to be tested to demonstrate operability immediately and periodically there-after during power operation. For some plants, this situation could be contrary to the NRC guideline as stated in the document mentioned above.

It should be noted that a reduction in redundancy is not a basis for a T.S.

change nor is it by itself a basis for relief from exercising in accordance

. with Section XI.

The licensee has agreed to review the plant's T.S. and to consider the need to propose T.S. changes which would have the effect of precluding such testing.

After making this review, if the licensee determines that the T.S.

Should be changed because the guidelines are applicable, the licensee will submit to the NRC, in conjuction with the proposed T.S. change, the inoper-l able condition for each system that is affected which demonstrates that the l 5

valve's failure would cause a loss of system function or if the licensee determines that the T.S. should not be changed because the guidelines are not applicable or cannot be followed, the licensee will submit the reasons that led to their determination for each potentially affected section of the T.S.

1.6 Safety-Related Valves This review was limited to safety-related val /es. Safety-rel ated

  • valves are defined as those valves that are needed to mitigate the conse-quences of an accident and/or to shut down the reactor and to maintain the reactor in a shutdown condition. Valves in this category would typically include certain ASME Code Class 1, 2, and 3 valves and could include soma non-code class valves.

It should be noted that the licensee may have included non-safety-related valves in their IST program as a decision on the licensee's part to expand the scope of their program.

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

1. It is understood that the licensee is to comence testing as soon as the cold-shutdown condition is achieved but not later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after shutdown, and continue until complete or the plant is ready to return to power. Completion of all valve testing is not a prerequisite to return to power.
2. Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refuel-ing to meet the code-specified testing frequency.
3. For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold-shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.

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

All CIVs shall be classified as Category A valves. The Category A valve-leak rate test requrements of IWV-3420(a-e) have been superseded by Appendix J requirements for CIVs. The NRC has concluded that the applicable leak-test procedures and requirements for CIVs are determined by 10 CFR 50, l Appendix J. Relief from Paragraph IWV-3420(a-e) for CIVs presents no safety .

problem since the intent of IWV-3420(a-e) is met by Appendix J requirements.

l The licensee shall comply with IWV-3420 (f and g) until relief is ,

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

6

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

the public.

1.9 Application of Appendix J Testing to the IST Program

. The Appendix J review for this plant is a completely separate review from the IST program review. However, the determinations made by that review are directly applicable to the IST program. Our review has deter-mined that the current IST program, as submitted by the licensee correctly reflects the NRC's interpretation of Section XI vis-a-vis Appendix J. The licensee has agreed that, should the A;;pendix J program be amended, they will amend their IST program accordingly.

2. Generic Relief Requests 2.1 Category A, A/C and A/E Valves 2.1.1 Relief Recuest. Relief is requested from the exercising requirements of Section XI for the folicaing passive valves:

80-40 Containment Spray Header Vent Isolation 80-41 Containment Spray Header Vent Isolation 80-43 Containment Spray Header Vent Isolation 80-44 Containment Spray Header Vent Isolation 80-45 Containment Spray Heade: lent Isolation 201-07 Suppression Chamber Air Vent and Purge Iso.

201-08 Suppression Chamber Air Vent and Purge Iso.

201-09 Drywell Vent & Purge Isolation 201-10 Drywell Vent & Purge Isolation 201-16 Suppression Chamber N2 Vent and Purge Iso.

201-17 Suppression Chamber N2 Vent and Purge Iso.

201-31 Drywell N2 Vent and Fill Isolation 201-32 Drywell N2 Vent and Fill Isolation 201.2-02 Drywe!1 N2 Vent and Fill Isolation 201.2-03 Drywell N2 Vent and Fill Isolation 7

1 201.2-06 N2 Make-up and Bleed to Suppression Chamber 201.2-33 N2 Make-up and Bleed to Suppression Chamber 34- 01 Reactor l lead Spray Isolation Valve 34-02 Reactor Head Spray Check Valve 58.l-01 Core Spray Torus Makeup Isolation Valve ,

38-01 RCS to Shutdown Cooling Isolation Valve 38-02 RCS to Shutdown Cooling Isolation Valve 38-12 Shutdown Cooling to RCS Check Valve 38-13 Shutdown Cooling to RCS Isolation Valve 2.1.1.1 Code Recuirement. Refer tn Appendix A.

2.1.1.2 Licensee's Basis for Recuesting Relief. These valves are not required to change position to fulfill their safety functions due to their passive nature.

2.1.1.3 Evaluation. These valtes are in their safety-related postion and are not required to open or close to mitigate the consecuences of an accident or safely shutdown the plant. Therefore, tk- operability of these valves is inconsequential with regard to the safety function which they perform. We feel relief should be granted from the exercising require-ments of Section XI for these passive valves.

2.1.2 Relief Recuest. Relief is requested from the stroke timing and trend analysis requirements of Section XI for the following valves:

05-01 Emergency Condenser Vent to Main Steam Iso.

05-02 Emergency Condenser Vent to Main Steam Iso.

05-03 Emergency Condenser Vent to Main Steam Iso.

05-04 Emergency Condenser Vent to Main Steam Iso.

39-11 Emergency Condenser Vent to Main Steam Iso.

39-12 Emergency Condenser Vent to Main Steam Iso.

39-13 Emergency Condenser Vent to Main Steam Iso.

39-14 Emergency Condenser Vent to Main Steam Iso. ,

68-08 Drywell/ Torus Vacuum Relief Iso. Valve 68-09 Drywell/ Torus Vacuum Relief Iso. Valve 8

- _ _ - _________ _ _ _ _ ______________J_____________n

68-10 Drywell/ Torus Vacuum Relief Iso. Valve 201.7-08 Containment Air Monitor Isolation Valve 201.7-09 Containment Air Monitor Isolation Valve 201.7-10 Containment Air Monitor Isolation Valve 201.7-11 Containment Air Monitor Isolation Valve 2.1.2.1 Code Reautrement. IWV-3410(c)(2) and (3) states:

(3) If an increase in stroke time of 25% or more from the previous test for valves with stroke times greater than ten seconds or 50%

or more for valves with stroke times less than or equal to ten seconds is observed, test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed. In any case, any abnormality or erratic action shall be reported.

2.1.2.2 Licensee's Basis for Reauesting Relief. Trend analysis of fast acting valves is inconclusive of valve operation due to the speed at which these valves operate. As an alternate, corrective action will be taken if the stroke time exceeds 5 seconds.

2.1.2.3 Evaluation. The licensee has demonstrated that . stroke timing of rapid-acting, solenoid-controlled, and air-operated valves whose stroke times are less than 5 seconds, would produce no meaningful data since these stroke times are extremely rapid and subject to considerable variation. Therefore, we feel relief should be granted from the stroke timing requirements of Section XI for these valves. We feel the licensee's proposed alternate test of verification of stroke times less than the 5-second maximum will adequately verify proper valve operation.

3. Main Steam System 3.1 Category A Valves 3.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves 01-01, 01-02, 01-03, and 01-04, main steam blocking valves.

3.1.1.1 Code Recuirement. Refer to Appendix A.

3.1.1. 2 Licensee's Basis for Requesting Relief. Full stroke testing at full power would cause a reactor scram on high pressure and subject the plant to undue thermal cycling stresses. Reduction in power to 40% should limit the adverse effects of testing. During rod swapping and other times when power is reduced to the 40% level, testing shall commence 9

_\

(not'to exceed once per quarter). Full stroke testing and stroke time verification will be performed during each refueling outage.

3.1.1.3 Evaluation. The licensee has demonstrated that full stecke exercising these valves during full power operation wculd cause a reactor scramland induce thermal cycle stresses on the reactor vessel and related components. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licen-see's prcoosed alterrate test of partial stroke exercising during power ,

operation (below 40% power) and full stroke exercising and stroke timing daring refueling outages will adequatley demonstrate proper valve oper-ability 3.2 Category B/C Valves 3.2.1 Relief Reauest. Relief is requested frcm the exercising 1

-. requirements of Section XI for valves NR-108A through F, Electromatic relief valves.

3.2.1.1 Code Reauirement. Refer to Appendix A.

3.2.1.2 Licensee's Basis for Requesting Relief. Full stroke testing of the electromatic relief valves on a quarterly basis would cause undue, thermal stresses on the suppression chamber. As an alternate, these .

valves 'will be tested at the beginning of every refueling outage.

3,2.1.3 Evaluation. The licensee has denonstrated that exe'rcis-ing these valves duFing power operation would cause thermal transients on the suppression chamber. During cold shutdown these valves cannot be exer-cised since steam must be available to exercise the valves. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of full stroke exercising these valves on a refueling outage frequency will ade-quately demonstrate proper valve operability.

-4 Liquid Poison System 4.1 Category A/C Valves

' , 4.1.1, Relief Request. Relief is requested from the exercising requirements of Section XI for valves 42.1-02 and 42.1-03, liquid poison to rcactor vessel check valves.

4.1.1.1 Code Recuirement. Refer to Appendix A.

.- -4.1.1.2 Licensee's Basis for: Requesting Relief. These valves do a not have an attached position indTdating device (local or remote), nor does e the system have adequate sensing devices to give secondary indications of the s alve position. These valves will be' full stroke exercised during .

refuejing outages when the liquid poison. system is tested.

4.1.1.3 Evaluation. The licensee has demonstrated that the only method to exercise these valves is via flow into the RCS. During power 10 *

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I operation this would inject borated water into the reactor and cause a reac-tor shutdown. Additionally, during cold shutdown, injecting this borated water would require operating the explosive valves and injection of the borated water would cause extensive radwaste generation since the boron would have to be flushed from the RCS prior to startup. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of full stroke exercising these valves during refueling outages will adequately demonstrate proper valve operability.

5. Containment Spray and Raw Water Systems

, 5.1 Category C Valves 5.1.1 Relief Reauest. Relief is requested from the exercising requirements of Section XI for the following check valves:

80-17 Containment Spray Header Check Velve 80-18 Containment Spray Header Check Valve 80-37 Containment Spray Header Check Valve 80-38 Containment Spray Header Check Valve 80-19 Containment Spray Header Check Valve 80-65 Containment Spray Header Check Valve 80-66 Containment Spray Header Check Valve 80-67 Containment Spray Header Check Valve 80-68 Containment Spray Header Check Valve 80-39 Containment Spray Header Check Valve 5.1.1.1 Code Requirement Refer to Appendix A.

5.1.1.2 Licensee's Basis for Requesting Relief. These valves do not have an attached position indicating device (local or remote), nor does the system have adequate sensing devices to give secondary indications of the valve position. Testing would require pressurization of the drywell, necessitating shutdown quarterly. During the Appendix J type A test, which is conducted every refueling outage, each valve is stroked to the open position.

5.1.1.3 Evaluation. Exercising these valves with normal system flow would spray the drywell and torus with contaiminated water resulting in damage to lagging, electrical equipment, etc. in the drywell and torus.

Therefore, we feel relief should be granted from the exercising require-ments of Section XI for these valves. We feel the licensec's proposed alternate test of full stroke exercising these valves during refueling 11

outages when the Appendix J Type A test is performed will adequately l demonstrate proper valve operability.

6. CRD Hydraulics System 6.1 Category B and C Valves 6.1.1 Relief Recuest. Relief is requested from the exercising requirements of Section XI for tha following valves: ,

CV-126 Low Side Scram Control Valve (129 Valves)

CV-127 High Side Scram Control Valve (129 Valves) 138 Cooling Water Header Check Valve (129 Valves) 6.1.1.1 Code Reauirement. Refer to Ar <endix r A.

6.1.1.2 Licensee's Basis for Requesting Relief. Exercising these valves quarterly wo'ald:

(1) Increase wear on the control rod drive seals due to isolation of cooling water.

(2) Cause undue termal shock.

(3) Cause fuel damage due to flux peaks.

Following each refueling outage all control rods are scram tested; following each scram from rated pressure, the mean 90% insertion time for at least 8 control rods is determined and after each outage not initiated '

by a scram, eight rods are scram tested. Results of the above listed test verifies proper operation of these valves.

6.1.1.3 Evaluation. The ifcensee has demonstrated that frequent exercising of these valves would increase wear on the control rod drive seals and cause thermal shock to rod drive mechanisms and could cause fuel damage due to flux peaks. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the Technical Specification identified scram testing method and frequency is sufficient to demonstrate proper operability for these valves.

7. Feedwater System 7.1 Category A/C Valves 7.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for valves 31-01 and 31-02, feedwater to the reactor check valves. ,

7.1.1.1 Code Reauirement. Refer to Appendix A.

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7.1.1. 2 Licensee's Basis for Reauesting Relief. These valves do not have an attached position indicating device (local or remote), nor does the system have adequate sensing devices to give secondary indications of the valve position. The valves shall be integrated leak rate tested every refueling outage.

7.1.1.3 Evaluation. The licensee has demonstrated that exercis-Ing these valves closed (their safety related position) during power opera-tion could cause a reactor scram. Additionally, the only practical method to verify valve closure is during a valve leak rate test which is performed each refueling outage. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the licensee's proposed alternate test of verification of valve closure dur!ng the leak test performed during refuelinn outages will adequately verify proper valve operability.

8. Reactor Water Cleanup System 8.1 Category A/C Valves 8.1.1 Relief Request. Relief is requested from the exercising reautrements of Section XI for valve 33-03, reactor water cleanup to the feedwater system check valve.

8.1.1.1 Code Requirement. Refer to Appendix A.

8.1.1.2 Licensee's Basis for Requesting Relief. This valve does not have an attached position indicating device (local or remote) nor does the system have adequate sensing devices to give secondary indication of the valve position. The valve is included in the Appendix J type A leak -

test which is ,oerformed every refueling outage.

8.1.1. 3 Evaluation. The only practical method to verify valve closure is during a valve leak rate test which is performed each refueling outage. Therefore, we feel relief should be granted from the exercising requirements of Section XI for this valve. We feel the licensee's proposed alternate test of verification of valve closure during the leak test per-formed during refueling outages will adequately verify proper valve operab il ity.

9. Drywell and Torus System 9.1 Category A/C Valves 9.1.1 Relief Request. Relief is requested from the exercising
requirements or Section XI for the following check valves

201.2-39 N2 Purge to TIP System 201.2-40 N2 Purge to TIP System 201.2-67 H2 -02 Sample Return to Containment 13 l

l 1

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. l 201.2-68 H2 -02 Sample Return to Containment 201.2-70 H2 -02 Sample Return to Torus 201.2-71 H2 -02 Sample Return to Torus 9.1.1.1 Code Requirement. Refer to Appendix A.

9.1.1.2 Licensee's Basis for Requesting Relief. These valves do

  • not have attached position indicating devices (local or remote), nor do the systems have adequate sensing devices to give secondary indication of the valve position. Testing would require pressurization of the drywell, quarterly. These valves are included in the Appendix J, type A leak test which is performed every refueling outage.

9.1.1.3 Evaluation. The only practical method to verify valve closure (their safety-related position) is during the valve leak rate tests which are performed each refueling outage. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves.

We feel the licensee's proposed alternate test of verification of valve closure during the leak tests performed during refueling outages will ade-Quately verify proper valve operability.

10. Emergency Cooling System 10.1 Category C Valves.

10.1.1 Relief Request. Relief is requested from the exercising requirements of Section XI for check valves 39-03 and 39-04, emergency cooling return to RCS check valves.

10.1.1.1 Code Requirement. Refer to Appendix A.

10.1.1.2 Licensee's Basis for Reauesting Relief. Full-stroke exercise testing at power or standby conditions would subject the plant to undue termal cycling stress. Also, the valves do not have attached position indicating devices (local or remote). The valves will be full stroked dur- ing the hydrostatic test following each refueling outage.

10.1.1.3 Evaluation. The licensee has shown that exercising these check valves requires establishing flow througn the emergency cooling system. During power operation this would induce severe thermal shock to the emergency cooling return to RCS nozzles and other RCS components. Dur-ing cold shutdown, the thermal driving force does not exist to establish flow through the system. Therefore, we feel relief should be granted from the exercising requirements of Section XI for these valves. We feel the ,

licensee's proposed alternate test of full stroke exercising these valves on a refueling outage frequency will adequately demonstrate proper valve operability. ,

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IV. APPENDIX A

1. Code Requirement--Valves Subsection IWV-3410(a) of the 1974 Edition of the Section XI ASME Code (which discusses full stroke and partial stroke requirements) requires that Code Category A and B valves be exercised once every three months, with exceptions as defined in IWV-3410(b)(1), (e), and (f). IWV-3520(a) (which discusses full stroke and partial strcke requirements) requires that Code Category C valves be exercised once every three months, with exceptions as defined in IWV-3520(b). In the above cases of exceptions, the Code permits the valves to be tested at cold shutdown where:

3

1. It is not practical to exercise the valves to the position required to fulfill their function or to the partial position during power operation.
2. It is not practical to observe the operation of the valves (with f ailsafe actuators) upon loss of actuator power.

Subsection IWV-3410(c) requires all Category A and B power-operated valves to be stroke-time tested to the nearest second or 10% of the maximum allowable owner-specified time.

l 15 l

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V. ATTACMENT I The following is a list of valves that we feel should be reviewed by the NRC to determine if these valves meet the Appendix J criterion for containment isolation. If any of these valves are determined to be Appen-dix J valves then they should be included in the IST program and categor-ized A, A/C or A/E as applicable.

39-03 .

39-04 81-01 81-02 81-21 ,

81-22 40-05 40-06 40-01 -

40- 02 40-09 40-10 40-11 40-12 80-01 80- 02 80-21 80-22 80-15 80-16 80-35 80-36 70-92 70-93 70-94 70-96 301-112 301-113 63.1-02 63.1-01 k

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VI. ATTACHMENT II The following are Category A, B, and C valves that meet the require-ments of the ASME Code,Section XI, and are not full stroke exercised every three months during plant operation. These valves are specifically identi-fied by the owner and are full stroke exercised during cold shutdowns and refueling outages. EG86 has reviewed all valves in this attachment and agrees with the licensee that testing these valves during power operation is not possible, due to the valve type and location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be exercied during power operation. These valves are listed below and grouped according to the system in which they are

, located.

1. Emergency Cooling System 1.1 Category A Valves 39-05 and 39-06, emergency cooling outside containment isolation valves cannot be exercised during power operation since this would thermal shock the Reactor Coolant and emergency cooling systems and could ultimately result in component failures. As an alternate, these valves will be full stroke exercised during cold shutdowns.

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VII. ATTACif4ENT III _.,

The P&ID's listed below were used during the course of this review.

System P&ID Number Revision Main Steam 18002 Sh. 1 11 Feedwater 18003 Sh. 2 5 ,

Drywell and Torus Isolation 18006 Sh. 1 3 Drywell and Torus Isolation 18006 Sh. 2 2 Reactor Core Spray 18007 11 Reactor Cleanup 18009 Sh. 1 7 Reactor Containment Spray 18012 6 Drywell and Torus Leak Rate and Analyzer 18014 Sh. 2 16 Control Rod Drive 18016 5 Emergency Cooling System 18017 9 Reactor Shutdown Cooling 18018 4 Reactor Liquid Poison 18019 6 c

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