ML20058F380
| ML20058F380 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/29/1982 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20058F368 | List: |
| References | |
| TAC-6363, NUDOCS 8207300461 | |
| Download: ML20058F380 (6) | |
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'o UNITED STATES
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NUCLEAR REGULATORY COMMISSION n
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WASHINGTON, D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO REQUESTS FOR RELIEF FROM INSERVICE TESTING REQUIREMENTS DUQUESNE LIGHT COMPANY OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY BEAVER VALLEY P0llER STATION, UNIT NO. I DOCKET NO. 50-334
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Introduction Technical Specification 4.0.5 for the Beaver Valley Power Station, Unit No.1 (Beaver Valley-1) states that inservice testing (IST) os ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda, as required by 10 CFR 50.55a(g). 10 CFR 50 150.55a(g)(6)(i) authorizes the Commission.to grant relief from Code requirements upon making the necessary findings.
By letter dated May 2,1979, Duquesne Light Company (the licensee) submitted its pump and valve inservice testing program for the period January 30,1980 to September 29, 1981. This program was revised by letter from the licensee dated March 17,1980.
In its submittals, the licensee requested relief from certain requirements of the ASME Boilercand Pressure Vessel Code,Section XI,1974 Edition through the Summer of 1974 Addenda (The Code).
Evaluation The licensee's surveillance program and requests for relief have been reviewed by the staff's contractor EG&G Idaho, Inc. The contractor's. evaluations and recommendations are presented in its Technical Evaluation Report (TER)
(Attachment 1). A copy of the staff _ guidance concerning inservice testing of pumps and valves (Attachment 2) is also provided for information. The staff has reviewed the TER and agrees with the contractor's findings and approves the actions that are recomended. A summary of the determinations made by the staff is presented in Lists A through F of this Safety Evaluation as follows.
8207300461 820629 PDR ADOCK 05000334 P
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A.
VALVES FOR WHICH REQ 9ESTED RELIEF IS DE'NIED MOV-1 HY 201 A MOV-1 HY 201 B The licensee requested relief from exercising these two H7 recombiner flow regulating valves on a quarterly schedule and proposed a six month frequency. This request is denied because the licensee has not provided a specific technical basis for the longer frequency. The valves should continue to be tested in accordance,4th the Code.
B.
PUMPS AND VALVES PEQUIRING ALTERNATE' TESTING Component Evaluation
Response
- Licensee investigate Within 12 months ',
CH-P-2B methods to determine' s
mechnical characteristics
' ' (1'.e., vibration monitoring)
RS-P-1A Licensee investigate other Within T months RS-P-1B methods of determining RS-P-2A hydraulic and mechanical RS-P-2B characteristics to monitor degradation WithN~12 months ISI-48 Licensee investigate other 15I-49 methods of full stroke 151-50 exercising (e.g., manual s
151-51 exercising during refueling 151-52 outages)
ISI-53 1RW-197 N
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Although the licensee provided a valid technical basis for not meeting the Code, permanent relief is not granted at this time for thes'e pumps-and s
valves pending supplemental infonnation. The licensee is required to '
investigate methods (plant modifications, etc.) by which Code requirements can be satisfied and is expected to submit alternate proposals for staff - 4 review within the time periods indicated.
Response within 12 months means 12 months from the date of this letter.
Relief is granted until such time as the staff has reviewed and evaluated these proposalf.
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3-e C.
VALVES REQUIRING PERIODIC POSITION VERIFICATION HCV-lCH-105 HCV-l CV-151 1CV-36 100-251 IPC-10 HCV-lCH-110 HCV-l CV-151 -1 100-247 10C-252 1PC-37 151-41 1CV-35 100-248 IPC-9 1PC-38 Relief is granted as requested for the valves listed here.
However, the staff has taken the position that valve position should be verified quarterly and each time the valve is cycled.
The licensee is expected to respond within six months of the date of this letter with a method and schedule for position verification of these valves.
D.
, VALVES TO BE TESTED AT COLD SHUTDOWN AND REFUELING MOV-CH-142 FCV-l CH-160 MOV-lCH-ll5C MOV-lCH-115E MOV-lCH-311 1CH-141 1SI-91 M0V-lSI-860A MOV-1SI-860B MOV-ISI-867C MOV-lSI-867D MOV-lSI-869A MOV-lSI-869B M0V-lSI-890A MOV-lSI-8908 MOV-lSI-890C MOV-lSI-867A MOV-lSI-867B TV-lSI-884B TV-lSI-884C 1SQ-3 15Q-4 1RS-100 1 RS-101 TV-NS101 TV-lCC-110F1 TV-lCC-lllA2 TV-lCC-lllD1 TV-lCC-lllD2 1MS-18 1MS-19 1MS-20 NRV-lMS-101 A s
NRV-l MS-101B NRV-lMS-101C PCV-l MS-101 A PCV-lMS-1018 PCV-lMS-1010 TV-l MS-101 A TV-1MS-101 B TV-l MS-101 C 1 FW-33 1FW-34 1FW-35 1FW-42 1FW-43 IFW-44 1FW-387 1FW-388 1 FW-389 1FW-390 1 FW-391 1FW-392 MOV-l FW-156A MOV-1 FW-156B MOV-l FW-156C FCV-l FW-478 FVC-lFW-479 FCV-l FW-488 FCV-l FW-489 FCV-l FW-498 FCV-l FW-499 lIA-90 1SA-15
~~, 05-3A lVS-05-38 IVS-DS-5A tv;-05-5B IVS-D5-6 TV-IVS-101 A TV-lVS-10lB TV-l VS-101 C TV-l VS-1010 TV-1VS-101E lHY-101 lHY-102 lHY-103 1HY-104 s
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'N lHY-110 lHY-111 1SA-14 N'
TV-lSI-884A TV-lCC-lllAl ll A-91
~ The valves listed here are those specifically identified by the licensee as being impractical to full stroke exercise every three months during power operation. Since cold shutdown testing satisfies Code requirements, and it has been verified, in accor-dance with current NRC staff positions, that testing at power operation is impractical for these valves, it is not necessary to grant relief for these components. The licensee agrees and has committed to full stroke exercising these valves during cold shutdowns and refueling outages rather than every three months.
E.
PUMPS AND VALVES FOR WHICH RELIEF IS GRANTED TO ALLOW ALTERNATE TESTING AS REQUESTED RH-P-1A RH-P-1B 1 RM-P-RW100 1RM-P-RW100A 1RM-P-RW1008 1RM-P-RW100C 1RM-P-RW1000 1RM-P-RW101 1PM-P-BD100 RC-68 RC-72 RC-277 RC-278 1CH-31 1 CH-181 1CH-182 1CH-183 1CH-170 1CH-369 MOV-lCH-308A M0V-lCH-308B MOV-lCH-308C MOV-lCH-378 MOV-1CH-381 1CH-22 1CH-23 1CH-24 MOV-lRH-700 M0V-1 RH-701 MOV-1RH-720A MOV-lRH-720B 1RH-14 1RH-15 1RH-16 ISI-10 1SI-11 15I-12 1S1-13 151-14 ISI-42 ISI-83 ISI-84 ISI-94 ISI-95 1S1-1 ISI-2 ISI-5 ISI-6 ISI-7 ISI-15 ISI-16 ISI-17 1SI-21 151-22 151-23 ISI-24 ISI-25 15I-27 ISI-100 1 S1 -1 01 1S1-102 TV-1CC-103A TV-lCC-103Al TV-l CC-103B TV-l CC-103B1 TV-lCC-103C TV-l CC-103Cl TV-1CC-105A TV-1 CC-105B TV-l CC-105D1 TV-l CC-105D2 TV-1 CC-105El TV-lCC-105E2 TV-l CC-107D1 TV-l CC-107 D2 TV-1 CC-107El TV-l CC-107E2 TV-1 CC-107A TV-1CC-107B TV-l CC-107C 1MS-80 1MS-81 1MS-82 lHY-119 lHY-20 ISI-20 Relief is granted as requested for the testing of the pumps and valves listed here.
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VALVES REQUIRING PRESSURE ISOLATION VERIFICATION 1RH-720A 1RH-720B 1RH-700 1 RH-701 151-8503 1SI-850D ISI-850F 151-10 151-11 151-12 ISI-15 ISI-16 ISI-17 1SI-20 1SI-21 15I-22 1SI-23 1S1-24 ISI-25 151-48 151-49 151-50 1SI-51 151-52 151-53 15I-83 ISI-84 ISI-100 15I-101 1SI-102 1CH-170 1RC-556A 1RC-556B 1RC-556C The valves listed here perform a pressure isolation function between high and low pressure systems and the staff has determined that verification of this capability, beyond the exercising requirements of the Code, by the licensee is necessary. The licensee is expected to select a method to be used in determining the condition of each of these valves and submit it for staff review within six months of the date of his letter. Possible methods include pressure monitoring, leak testing, radiography and ultrasonic testing.
If leak testing is selected as the desirable method, these valves should be classified as A or AC and tested in accordance with IWV-3420 of the Code.
Based on the review summarized herein, the staff concludes that the relief granted and alternate testing imposed through this document, for Code requirements that are considered impractical, give reasonable assurance 1
that the pump and valve operational readiness intended by the Code will i
be satisfied. Additionally, we have concluded that this relief does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin; and that there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner.
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, Environmental Consideration We have determined that granting relief from specific ASME Section IX Code requi,rements does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that this is an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the granting of this relief.
I Conclusion l
l We have concluded, based on the considerations discussed above, that:
(1) l because this action does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the action does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with l
the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Date: June 29,1982 i
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Environmental Consideration We have determined that granting relief from specific ASME Section IX Code requi,rements does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having mide this determination, we have further concluded that this is an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 151.5(d)(4), that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the granting of this relief.
Conclusion We have concluded, based on the considerations discussed above, that:
(1) because this action does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, the action does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Date: June 29,1982
EGG-EA-5254,Rev. 1 March 1981 SAFETY EVALUATION REPORT, INSERVICE TESTING PROGRAM, BEAVER VALLEY POWER STATION UNIT 1 - DOCKET N0. 50-334 I
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J. M. Fehringer l
H. C. Rockhold t
U.S. Department of Energy Idaho Operations Office
- Idaho National Engineering Laboratory
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Prepared for the U.S. Nuclear Regulatory Comission Under DOE Contract No. DE-AC07-76ID01570 0
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ATTACHMENT 1 CONTENTS 1.
INTRODUCTION....................................................
1 11.
PUMP TESTING PROGRAM............................................
2 III. VALVE TESTING PROGRAM...........................................
8 IV.
ATTACHMENT I....................................................
55 V.
ATTACHMENT II...................................................
66 VI.
AT T AC H M E N T 1 1 1..................................................
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f I.
Introduction Contained herein is a safety evaluation of the pump and valve inservice testing (IST) program submitted by tha Duquesne Light Company on 5-2-79 for its Beaver Valley Power Station Unit I nuclear plant. The program applies to Beaver Valley for the period 1-30-80 through 9-29-81.
The working session with Duquesne Light and Beaver Valley Power Station Unit I representatives was conducted on 12-13-79 and 12-14-79.
The licensee resubmittal was issued on 3-17-80 and was 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.
Duquesne Light Company 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 impr ac ti cal.
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 II-I are the recommendations of EG&G Idaho, Inc.
Category A, B, and C valves that meet the requirements of the ASME Code Section XI and are not exercised every 3 months are contained in Attachment I.
A listing of P&ID's used for this review are~ contained in Attachment II.
Valves th,at are never full stroke exercised or that have a testing interval greater than each refueling outage and relief requests with 1
insufficient technical basis where relief is not recommended are summarized in Attachment III.
II.
Pump Testing Program The IST program submitted by Duquesne Light Company for its Beaver Valley Power Station Unit I 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 required by the ASME Code,Section XI. Our review found that Class 1, 2, and 3 safety related pumps were included in the IST program and, except for those pumps identified below for which specific relief from testing has been requested, the pump tests and frequency of testing comply with the Each Duquesne Light Company basis for requesting specific code.
relief f rom testing pumps and the EG&G evaluation of that request is sunmarized (B through F) below and grouped according to the system in which the pumps reside:
A.
Code Requirement An inservice test shall be conducted on all safety related pumps, Each nominally once each month during normal plant operation.
inservice test shall include the measurement, observation., and recording of all quantities in Table IWP-3100-1, except bearing temperature, which shall be measured during at least one inservice test each year.
Boric Acid Transfer Pumps (CH-P-2A and CH-P-28)
B.
1.
Relief Request The licensee has requested specific relief from measuring bearing temperature (T ) and vibration velocity (V) on the b
boric acid transfer pumps in accordance with the requirements of Section XI.
2
Code Requirement Refer to pump testing paragraph II. A.
Licensee's Basis for Requesting Relief These pumps are located in a heat traced box. Removal of the box can cause heat trace damage and thus degrade system integrity (cold spots could occur on the heat trace box).
Evaluation We agree with the licensee's basis and therefore feel that temporary relief should be granted for the boric acid transfer pumps from the testing requirments of Section XI.
The licensee has demonstrated that these pumps are inaccessible and T and V cannot be measured. Removal of b
the box could cause heat trace damage that could result in boron precipitation and crystallization that would result in j
system degradation. We conclude that with the present plant design V and T cannot be measured on these pumps.
b However, will feel the licensee should further investigate
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some method to determine the mechanical characteristics of the boric acid transfer pumps.
l C.
Residual Heat Removal Pumps (RH-P-1A and RH-P-18) 1.
Relief Request The licensee has requested specific' relief for the residual heat removal pumps f rom the testing requirements of Section XI and proposed to measure all required parameters
,during cold shutdown.
3 l
Code Requirement Refer to pump testing paragraph-II. A.
Licensee's Basis for Requesting Relief The pumps and associated instrumentation are located inside the subatmosphere containment missile barrier where a high radiation area exists. Radiation levels are approximately 200 mR/hr and an operator work time of 30 minutes is required to perf orm each pump test at power and this wculd violate ALARA guidelines. The pumps are not required to be run at power or fulfill any safety function to mitigate the consequences of an accident.
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for the residual heat removal pumps from the testing requirements of Section XI. The licensee has demonstrated that these pumps are inaccessible and are not required to function during power operation. We conclude that the proposed cold shutdown testing frequency should demonstrate pump operability.
D.
Inside Recirculation Spray Pumps (RS-P-1A and RS-P-18) 1.
Relief Request The licensee has requested specific relief for the inside recirculation spray pumps from the testing requirements of Section XI and proposed to run these pumps dry monthly up to 100 rpm t, hen stop the pumps.
4
Code Requirement Refer to pump testing paragraph II. A.
Licensee's Basis for Requesting Relief For monthly surveillance requirement, the pump is run dry and then stopped when it reaches 100 rpm as indicated by a blue light in the control room. All other monitored parameters are not obtained in any plant mode due to the infeasibility of flooding the containment basement.
Evaluation We agree with the licensee's basis and therefore feel that temporary relief should be granted for the inside recirculation spray pumps from the testing requirements of Section XI.
The licensee has demonstrated that with the present plant design they are performing the only testing possible.
Flooding the containment sump for pump testing would result in damage to electrical equipment located inside the containment.
However, we conclude that the licensee should further investigate other methods and possible plant modifications that would enable the licensee to determine the hydraulic and mechanical characteristics and any degradation of these pumps.
E.
Outside Recirculation Spray Pumps ( RS-P-2A and RS-P-28) 1.
Relief Request The licensee has requested specific relief for the outside recirculation spray pumps from the testing requirements of Section XI and proposed to run these pumps dry monthly for 60 seconds and run them on wet recirculation during refueling outages.
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Code Requirement Ref er to pump testing paragraph II. A.
Licensee's Basis for Requesting Relief These pumps are started and stopped immediately during power operation and cold shutdown. During this test the pumps are run dry and cannot be run more than 60 seconds, thus no parameters are measured. During refueling outages the pumps are isolated f rom the system, filled, vented, and run approximately 2 minutes (to prevent pump overheating and pump damage) so that speed (N), inlet pressure (P ),
j diff erential pressure (dP), and flowrate (Q) can be n'easured. These pumps cannot be run long enough to measure vibration velocity (V) and bearing temperature (T )*
b Evaluation We agree with the licensee's basis and therefore feel that temporary relief should be granted for the outside recirculation spray pumps from the testing requirements of Section XI. The licensee has demonstrated that with the present plant design they are performing the only testing possible. However, we conclude that the licensee should further investigate other methods and possible plant modifications that would enable the licensee to determine the mechanical characteristics and any pump mechanical degradation.
F.
Radiation Monitoring Pumps 1.
Relief Re' quest The licensee has requested specific relief for the radiation monitoring pumps that monitor river water 1RM-P-RW100, recirculation sprays heat exchanger 1RM-P-RW100A 6
through 1000, CCR/RW heat exchanger 1RM-P-RW101, and S/G blowdown 1RM-P-BD100, from the testing requirements of Section XI and proposed to observe radiation monitor system operation to determine each pumps operability.
Code Requirement Refer to pump testing paragraph II. A.
Licensee's Basis for Requesting Relief Relief from all monthly testing of all applicable in plant Radiation Monitor Pumps is requested for the following reasons:
These pumps arc an integral part of a Radiation Monitor.
a.
b.
Radiation Monitor Pumps with an emergency power source serve no automatic safety-related function.
There are high and low flow alarms associated with the c.
applicable radiation monitors that alarm in the Control Room. There is no other installed in'strumentation.
Evaluation l
l We agree with the licensee's basis and therefore feel that relief should be granted for the radiation monitoring pumps i
1RM-P-RW100, IRM-P-RW100A through 0, IRM-P-RW101, and 1RM-P-BD100 from the testing requirements of Section XI. We conclude that the licensee's proposal of observing proper system operation should demonstrate proper pump operation.
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l 7
III. Valve Testing Program Evaluation The IST program submitted by Duquesne Light Company was examined to verify that Class 1, 2, and 3 safety related valves were included in the program and that those valves are subjected to the periodic tests required by the ASME Code,Section XI, and the NRC positions and Our review found that Class 1, 2, and 3 safety related guidelines.
valves were included in the IST program and, except for those valves identified below for which specific relief from testing has been requested, the valve tests and frequency of testing comply with the code requirements and the NRC positions and guidelines listed in Also, included in the General Section A is the NRC General Section A.
position and valve listings for the leak testing of valves that perform a pressure isolation function and a procedure for the Each licensee's use to incorporate these valves into the IST program.
Duquesne Light Company basis for requesting specific relief from testing valves and the EG&G evaluation of that request is summarized (B through K) below and grouped according to each specific system.
A.
General Considerations Testing of Valves which Perform a Pressure Isolation Function 1.
Several safety systems connected to the reactor cool' ant pressure boundary have design pressures below the reactor Redundant isolation coolant system operating pressure.
valves within the Class 1 boundary forming the interface between these high and low pressure systems prevent the low pressure systems from pressures which exceed their design In this role, the valves perform a pressure limit.
The NRC considers the redundant isolation function.
The NRC isolation provided by these valves to be important.
considers it necessary to assure that the condition of each 8
of these valves is adequate to maintain this redundant isolation and system integrity. For these reasons, EG&G' believes that some method, such as pressure monitoring, leak testing, radiography or ultrasonic testing, should be used to assure the condition of each valve is satisfactory 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:
1RH-720A and B 1RH-700 and 701 151-48, 51, 49, 52, 50 and 53 151-8508, D and F 151-15, 16 and 17 ISI-20, 21 and 22 151-10, 11 and 12 ISI-23, 24 and 25 151-100, 101 and 102-15I-83 and 84 ICH-170 1CH-170 IRC-556A, B and C 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.
9
2.
ASME Code Section XI Requirements Subsection IWV-3410(a) of the Section XI Code (which discusses full stroke and partial stroke) requires that Code Category A and B valves be exercised once every 3 months, with the exceptions as defined in IWV-3410(b-1), (e), and (f).
IWV-3520(a) requires that Code Category C valves be exercised once every 3 months, with the exceptions as defined in IWV-3520(b).
IWV-3700 requires no regular testing for Code Category E valves. Operational checks, with appropriate record entries, shall record the position of these valves before operations are performed and after operations are completed and shall verify that each valve is locked, or sealed. The limiting value of full stroke time for each power operated valve shall be identified by the owner and tested in accordance with IWV-3410(c).
In the above exceptions, the code permits the valves to be tested at cold shutdown where:
It is not practical to exercise the valves to the a.
position required to fulfill their function or to the partial position during power operation.
b.
It is not practical to observe the operation of the valves (with f ail-safe actuators) upon loss of actuator power.
3.
Stroke Testing of Check Valves The NRC stated its position to the licensee that check valves whose safety function is to open are expected to be full-stroked.
If only limited operation is possible (and it has been. demonstrated by the licensee and agreed to by the NRC) the check valve shall be partial stroked.
Since disk position is not always observable, the NRC staff stated that 10
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 test to satisfy the above position.
4.
Stroke Testing of Motor Operated Valves The licensee has requested relief from the part-stroke requirement of Section XI for all power operated valves.
The licensee has stated that none of the Category A or B power operated valves identified can be part-stroked because of the design logic of the operating circuits.
These circuits are such that when an open or close signal is received the valve must complete a full stroke before the relay is released to allow the valve to stroke in the other direction. We find that the above relief request from part-stroking is warranted and should be granted because the required function of the valves involves only full open or full closed positions.
5.
Test Frequency of Check Valves Tested at Cold Shutdowns The Code states that, in the case of cold shutdowns, valve testing need not be performed more often than once every f
three months for Category A and B valves and once every nine months for Category C valves.
It is NRC's position that the l
Code is inconsistent and that Category C valves should be tested on the same schedule as Category A and B valves. The licensee has agreed to modify his procedures on cold
' shutdowns to read, "In the case of frequent cold shutdowns, valve testing need not be performed more often than once every three (3) months for Category A, B and C valves."
11 a
r 6.
Licensee Request for Relief to Test Valves at Cold Shutdown The Code permits valves to be tested at cold shutdown, and the Code conditions under which this is permitteo is noted in Appendix A.
These valves are specifically identified by the licensee and are full stroked exercised during cold shutdowns; therefore, the licensee is meeting the requirments 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 shutdown.
7.
Changes to the Technical Specification In a November 1976 letter to the licensee, the NRC provided an attachment 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 the Emergency Core Cooling System (ECCS) is inoperable, nonredundant valves in the remaining train should not be cycled if their failure in a non-safe For position would cause a loss of total system function.
example, during power operation in some plants., there are stated minimum requirements for systems which allow certain limiting 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 plant's Technical Specifications (T.S.), the reactor is required to be put in 12 j
some other mode. Furthermnre, prior to initiating repairs all valves and interlocks in the system that provide a duplicate function are required to be tested to demonstrate operability immediately and periodically thereafter during power operation. For 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 conjunction with the proposed T.S. change, the inoperable condition for each system that is affected which demonstrates that the valve's f ailure 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.
8.
Safety Related Valves i
This review was limited to safety-related valves.
Safety-related valves are defined as those valves that are I
needed to mitigate the consequences of an accident and/or to shutdown 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 I
include some non-code class valves.
It should be noted that l
i the licensee may have included non-safety related valves in their Inservice Test Program as a decisica on the licensee's part to expand the scope of their program.
l 13
9.
Valve Testing at Cold Shutdown Inservice valve testing at cold shutdown is acceptable when the following conditions are met:
It is understood that the licensee is to commence 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 /> af ter shutdown and continue until complete or plant is ready to return to power. Completion of all valve testing is not a prerequisite to return to power.
Any testing not completed at one cold shutdown should be performed during any subsequent cold shutdowns that may occur before refueling to meet the Code specified testing frequency.
For planned cold shutdowns, where the licensee will complete all the valves identified in his IST program for testing in the cold shutdown mode, exceptions to the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> may be taken.
- 10. Category A Valve Leak Check Requirements for Containment Isolation Valves (CIV)
All CIVs shall be classified as Category A valves. T'he Category A valve leak rate test requirements of IWV-3420(a-e) have been superseded by Appendix J requirements for CIVs. The NRC has concluded that t.he applicable leak test procedures and requirements for CIVs i
are determined by 10 CFR 50 Appendix J.
Relief from paragraph IWV-34-20 (a-e) for CIVs presents no safety problem since the intent of IWV-3420 (a-e) is met by Appendix J requirements.
The licensee shall comply with Sections f and g of IWV-3420 l
until relief is requested from these paragraphs.
It should be noted that these paragraphs are only applicable where a
(
Type C Appendix J 1eak test is performed.
Based on the considerations discussed above the NRC concludes that the l
t 14 L_
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 of the common defense and security of the public.
11.
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 determined that the current IST program as submitted by the licensee correctly reflects our interpretation of Section XI vis-a-vis Appendix J.
The licensee has agreed that, should the Appendix J program be amended, they will amend their IST program accordingly.
B.
Category A and A/C Valves a.
Relief Request The licensee has requested specific relief from make-up to exercising Category A/C Valves RC-68, N2 PRT and RC-72, primary water supply to PRT in accordance with the requirements of Section XI and proposed to verify valve closure (their safety related position) during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
15
Licensee's Basis for Requesting Relief During normal plant operation RC-68 and RC-72 are closed and only require opening upon nitrogen or water makeup to the Pressurizer Relief Tank. During an accident condition (DBA) the required position of these valves is shut as is the normal operational position thereby reducing the possibility of the valve being open at the time of the accident.
In addition, no installed instrumentation exists to detect makeup flow or check valve position. No alternate stroke testing is proposed in addition to the 18 month leak test.
Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C Valves RC-68 and RC-72 from the exercising requirements of Section XI. The licensee has denonstrated that due to plant design the only method available to verify valve closure (their safety related position) is during leak testing. These valves are not equipped with valve position indicators nd some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of l
i leak rate testing at refueling outages should demonstrate proper valve operability.
b.
Relief Request The licensee has requested specific relief from exercising Category A Valves RC-277 and RC-278, containment isolations for pressure calibration l
instruments, in accordance with the requirements of Section XI and proposed to leak test these valves during refueling outages.
16
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These valves are closed during normal plant operation and were designed for use in emergency conditions only to open a path to determine RCS pressure, with loss of normal pressure indication, from outside the containment. These are passive valves not required to change position in an accident condition.
No alternate stroke testing is proposed in addition to the 18 month leak test.
Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A,-passive Valves RC-277 and RC-278 from the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
17
C.
Chemical and Volume Control 1.
Category A and A/C Valves a.
Relief Request The licensee has requested specific relief from exercising Category A/C Valve ICH-31, charging header inside containment isolation check, in acccrdance with the requirements of Section XI and proposed to verify valve closure (its safety related position) during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief This check valve is a normally open valve and valve closure can only be checked by leak test. The safety related position of this valve is closed. There is no instrumentation to monitor upstream pressure 'during normal operation. Therefore, relief is requested from f
Quarterly and Cold Shutdown Stroke tests. No alternate seating check is proposed in addition to the refueling i
leak test.
Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C 1
Valve 1-CH-31 from the exercising requirements of Section XI. The licensee has demonstrated that due to i
18
plant design the only method available to verify valve closure (its safety related position) is during leak testing. This valve is not equipped with valve position indicators and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the performance of leak rate testing at refueling outages should demonstrate proper valve operability.
b.
Relief Request The licensee has requested specific relief from exercising Category A/C Valves ICH-181, ICH-182, and 1CH-183 RCP seal injection isolation checks, in accordance with the requirements of Section XI and proposed to verify valve closure (their safety related position) during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Liceraee's Basis for Requesting Relief These check valves are normally open during power operation and are required to close to fulfill their safety function. Closure of these valves would stop seal injection and compromise pump operation.
In addition, seal injection flow is required anytime the system is pressurizei greater than 100 psig.
Therefore, relief from quarterly and cold shutdown full stroke exercising is requested. These valves are full stroke exercised during leak rate testing done at refueling per OST 1.47.28.
19
Evaluation We agree with the licensee's basis, and therefore feel that relief should be granted for Category A/C Valves ICH-181, ICH-182, and ICH-183, from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (their safety related position) is during leak testing. These valves are not equipped with valve position indicators and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the perf ormance of leak rate testing at refueling outages should demonstrate proper valve operability.
c.
Relief Request The licensee has requested specific relief from exercising Category A/C Valve ICH-170, reactor coolant system fill line isolation check, in accordance with the requirements of Section XI and proposed to v'erify valve closure (its safety related position) during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief This check valve is normally closed during power operation and is required to remain closed to fulfill its safety function. Relief from quarterly exercising 20 M
As sl.
_~
a,
\\
7 A
5 of this check valve at power is requested because exercising would thermal shock the RCS piping. Also due to a lack of installed instrumentation, relief is requested from cold shut exercis(ng. This valve is full stroke exercised at refueling pe OST1.47.37.;
i s(
Evaluation We agree with the licensee's5 asis, and therefore feel b
that relief should be granted for Category A/C Valve ICH-170 from the exercising requirements of
,,Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve N
closure (its safety related position) is during leak
~
lesting. This valve is not equipped with valve s
- s s
position indicators and. pie of the required test We connections are located inside the containment.
concludethattheproposedalternate.testinhfrequency of verifying valve closure during the performance.of 3
leak rate testing at refueling outages should s
, demonstrate proper valve operability.
I di Relief Request I
The licensee has requested specific relief from exercising Category A/C Valve ICH-369, press'ure relief check around MOV-CH-378, in accordance with th%
requi~rementsofSectionXIandproposedtc'veriffvalve closure (its safety re'd t position) during refueling outages.
3 Code Requirement C '--
Refer to valve testing paragraph A. 2.
4 1
4 21 s
~3 4
s Licensee's Basis for Requesting Relief This valve is nonnally closed at power operation and
~
required to remain closed to fulfill its safety function.
Since it is a passive valve with no pennanently installed instrumentation, relief from quarterly and cold shutdown full stroke exercising is requested. This valve is full stroke exercised during leak rate testing done at refueling per OST-1.47.18.
Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A/C passive Valve ICH-369 f rom the requirements of Section XI.
This valve is in its safety related position and is not required to open or close to mitigate the consequences of an accident or safely shut down the plant.
Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. We conclude that verifying valve closure during leak testing at refueling should demonstrate proper valve operability, e.
Relief Request The licensee has requested specific relief from exercising Category A valves MOV-1CH-308A, B, and C and MOV-1CH-378 and 381 (RCP seal water isolations) in accordance with the requirenents of Section XI, and proposed to full stroke exercise these valves during cold shutdowns that RCPs are secured and at least once each refueling outage.
22
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief These valves are open during power operation but are required to close to perform their safety function.
Closing either of these valves during power operation would secure seal injection water to the RCP seals resulting in seal damage.
Therefore, relief from quarterly stroke exercising and timing is requested.
These valves will be stroke exercised and timed during cold shutdown and refueling when RCPs are secured per OST 1.1.10.
Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valves MOV-1CH-308A, B, and C and MOV-1CH-378 and -381 from the exercising requirements of Section XI.
The licensee has demonstrated that f ailur'e of either of these valves in the closed position during power operation or cold shutc' owns that RCPs are running would result in seal damage resulting in loss of the RCP until repairs could be performed. We conclude that exercising these valves during cold shutdowns that RCPs are secured and at least once each refueling outage should demonstrate proper valve operability.
23 L
2.
Category B Valves a.
Relief Request The licensee has requested specific relief from exercising Category B Valves HCV-1CH-105 and HCV-1CH-110, boric acid recirculation hand control valves, in accordance with the requirenents of Section XI.
Code Requirenent Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These are passive Category B valves and are not required to change position to perform their intended safety function. Normal position is shut during power operation.
Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category B, passive Valves HCV-1CH-105 and HCV-1CH-110 from the requirements of Section XI.
These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.
Therefore, the operability of these valves is inconsequential with regard to the safety function which they perfonn. We conclude that the quarterly stroke and stroke time measurements are i
meaningless for passive valves.
24 e
m
J' 3.
Category C Valves a.
Relief Request The licensee has requested specific relief from exercising Category C Valves ICH-22,1CH-23, and 1CH-24, charging pump discharge checks in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages and partial stroke exercise these valves during power operation.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief The design function of this check valve is to prevent reverse flow during pump shutdown and to stroke full open for safety analysis flow. Relief from quarterly exercising is requested because no flow paths exist but the design path to facilitate the 500 gpm design flow.
Relief is also requested from cold shutdown exercising due to the generation of additional radioactive waste from the boration to verify full flow conditions. A full flow test of these valves is conducted at refueling to verify full stroke exercise open per O ST 1.11.14.
I 25
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C Valves ICH-22, ICH-23, and ICH-24 from the exercising requirements of Section XI.
The licensee has demonstrated that the only available path for full stroke exercising these valves is through the safety injection / BIT into the RCS. During power operation injecting highly borated water would cause power transients that could result in a reactor trip. During cold shutdown, injecting highly borated water could result in a delay of reactor startup due to the extensive boron cleanup requirenent to return plant water chemistry to startup specifications. We conclude that full stroke exercising these valves during refueling outages should demonstrate proper valve operability.
D.
Residual Heat Renoval 1.
Category A/E Valves Relief Request i
i The licensee has requested specific relief from exercising Category A/E Valves 1RH-14,1RH-15, and 1RH-16, inside and outside RHR containment isolations, in accordance with the requirements of Section XI.
Code Requirement Refer to v'alve testing paragraph A. 2.
I l
[
26
Licensee's Basis f or Requesting Relief These valves are passive normally shut containment isolations that are not required to change their position to fulfill their safety function.
In addition, the valves are administratively controlled with respect to the "as left" position.
Therefore, relief is requested from quarterly and cold shutdown exercising.
A valve full stroke verification is completed at refueling per leak test OST 1.47.20.
Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A/E passive Valves 1RH-14,1RH-15, and 1RH-16, from the requirements of Sec tion XI.
These valves are in their safety related position and are not required to open or.close to mitigate the consequences of an accident or safely shut down the plant.
Therefore, the operability of these valves is inconsequential with regard to the safety function which they perfonn.
We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
t 2.
Category B Valves Relief Request The licensee has requested specific relief from ex9rcising Category B Valves MOV-1RH-700, MOV-1RH-701, MOV-1RH-720A, and MOV-1RH-7208, RHR inlet and outlet isolations, in accordance with the requirements of Section XI and proposed l
to exercise these valves during refueling outages, i
27
Code Requirenent Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief Cycling these valves could subject the Residual Heat Removal System to pressure greater than design.
These valves are normally closed and de-energized during power operations and required to be closed during an accident condition.
Therefore, relief is requested during power operations and cold shutdown.
NOTE:
These valves are exercised but not timed each plant cooldown or heatup from cold shutdorn per applicable plant startup and shutdown procedures.
These valves are exercised and timed in,accordance with OST 1.10.4 Residual Heat Removal System refueling valve exercise testing.
Evaluation We agree with the licencee's basis, and therefore feel relief should be granted for Category B, passive Valves MOV-1RH-700, MOV-1RH-701, and MOV-1RH-726 A and B l
from the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or sdfely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurenents are meaningless for passive valves.
l 6
L as
E.
Safety Injection 1.
Category A/C and A/E Valves Relief Request a.
The licensee has requested specific rellef from exercising Category A/C Valves 151-10, 151-11, and ISI-12, LHSI header checks, and 151-13 and 151-14, inside containment isolation header checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves at refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These valves are normally shut during. power operation but required to open to fulfill their safety function.
Due to the lack of installed instrumentation and relative system pressures, relief from quarterly full or part stroke exercising is requested.
In addition, relief is requested from full or partial stroke exercising at cold shutdown due to the generation of I
additional rad waste by the additional boration required to verify a full flow condition through the l
LHSI inj ec tion flow path. A full flow stroke exercise for these valves will be performed at refueling per OST 1.11.14.
l I
29 t
Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A/C Valves 151-10, 151-11, 151-12, ISI-13, and ISI-14, from the exercising requirements of Section XI. The licensee has demonstrated that these valves cannot be exercised during power operation because the LHSI pumps cannot overcome RCS operating pressure.
During cold shutdown exercising these valves would inject highly borated water into the RCS that could result in a delay of reactor startup due to the extensive cleanup required to return RCS water chemistry to startup spec if ica tions. We conclude that full stroke exercising these valves during refueling outages should demonstrate proper valve operability.
b.
Relief Request The licensee has requested specific relief from exercising Category A/C Valve 15I-42, inside containment isolation on accumulator fill line, in accordance with the requirements of Section XI and proposed to verify valve closure (its safety related position) during refueling outages.
Code Requirement l
Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief This valve is shut during power operation and is required to be shut to fulfill its safety function which is containment isolatlon.
It is not required to i
i 30
change position at all except when filling S.I.
Accumulators. Relief is requested from quarterly and cold shutdown full or part stroke exercising because testing would be meaningless.
In addition, no installed instrumentation exists.
This valve will be exercised at refueling during leak rate testing per OST 1.47.19.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A/C Valve ISI-42 from the exercising requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (its safety related position) is during leak testing. This valve is not equipped with valve position indicators and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure uuring the performance of leak rate testing at refueling outages should demonstrate proper valve operability.
c.
Relief Request The licensee has requested specific relief from exercising Category A/C Valves 15I-48, ISI-49, and 151-50, accumulator discharge checks, in accordance with the requirements of Section XI and proposed to partial stroke exercise these valves during cold shutdown and leak test these valves during refueling i
outages.
31
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief This valve at power operation is shut but required to be open for a low pressure accident requiring passive injection for core cooling to fulfill its safety f unc tion. Relief from full stroke exercising at any mode of operation and part stroke exercising at power is requested due to high differential pressure, lack of installed instrumentation and an uncontrolled test volume change required to simulate safety analysis flow. These valves will be part stroked at extended cold shutdowns per OST 1.11.15 and leak tested per OST 1.11.4.
Evaluation We agree with the licensee's basis and therefore feel that temporary relief should be granted for Category A/C Valves ISI-48, 1S1-49, and 15I-50 from the exercising requirements of Section XI during power operation and cold shutdown.
The licensee has demonstrated that during power operation these valves cannot be exercised because accumulator pressure cannot overcome RCS operating pressure. During cold shutdown, exerci:ing these valves with accumulator' flow could result in a low temperature over-pressurization of the RCS. We also agree that full stroke exercising these valve,s with accumulator flow during refueling outages with the vessel head removed to provide an adequate expansion volume could result in internal core damage 32
because of the excessive flow rates. We conclude that with the present piping configurations, only partial stroke exercising of these valves is possible.
However, we recommend that the utility further investigate a method to full stroke exercise these valves (i.e. manual exercising during refueling outages).
d.
Relief Request The licensee has requested specific relief from exercising Category A/C Valves ISI-51, 1S1-52, and 151-53, reverse flow preventers from the RCS to the accumulators, in accordance with the requirenents of Section XI and proposed to partial stroke exercise these valves during cold shutdown and leak test during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These valves at power operation are shut but required to be open for a low pressure passive injection for core cooling to fulfill its safety function. Relief from full stroke exercising at any mode of operation and partial stroke exercising at~ power is requested due to differential pressure considerations, lack of installed instrumentation required to simulate safety analysis flow and uncontrollable test volume changes.
These valves are part stroke exercised with operation of the RHR at cold shutdowns.
These valves are also leak checked at a refueling frequency per OST 1.11.4.
33
Evaluation We agree with the licensee's basis and therefore feel
. temporary relief should be granted for Category A/C Valves 151-51, 151-52, and 15I-53 from the exercising requirements of Section XI.
The licensee has demonstrated that the valves cannot be exercised during power operation because accumulator pressure or LHSI flow cannot overcome RCS operating pressure. During cold shutdown these valves are partial stroke exercised with RHR flow. These valves cannot be full stroke exercised during cold shutdown because accumulator flow could result in a low temperature overpressurization of the RCS. We also agree that full stroke exercising these valves with accumulator flow during refueling outages with the vessel head removed to provide an adequate expansion volume could result in internal core damage because of the excessive flow rates. We conclude that with the present piping configurations, only partial stroke exercising of these valves is possible. However, we recommend that the utility further investigate a method to full stroke exercise these valves (i.e. manual exercising curing refueling outages).
e.
Relief Request The licensee has requested specific relief from exercising Category A/C Valves 1S1-83 and ISI-84, HHSI recirculation to hot leg inside containment isolation checks, in accordance with the requirements of Section XI and proposed to full stroke exercise and leak test at refueling outages.
34
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These valves are normally shut during power operation but are required to open to fulfill their safety function.
Due to the lack of installed instrumentation and relative system pressures, relief from quarterly full or part stroke exercising is requested.
In addition, relief from cold shutdown full or partial stroke exercising is requested due to the increased RCS i
boration required that would necessitate processing a large volume of RCS water. Waste processing could result in increased down time and more generation of rad waste.
A full flow stroke exercise for these valves will be performed at refueling per OST 1.11.14.
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category A/C 1SI-83 and 1S1-84 from the exercising requirements of Sec tion XI.
The licensee has demonstrated that these valves cannot be full stroke exercised during power operation becuse the HHSI pumps cannot overcome RCS operating pressure.
Partial stroke exercising would result in thennal shocking of the injection nozzles.
Exercising these valves during cold shutdown with
~
highly borated water could delay reactor startup due to the extensive cleanup required to return the RCS water to startup specifications. We conclude that full stroke exercising these valves during refueling outages snould demonstrate proper valve operability.
35
f.
Relief Request The licensee has requested specific relief from exercising Category A/C Valves ISI-94 and ISI-95, inside containment isolation checks for the BIT and fill header, in accordance with the requirements of -
Section XI and proposed to full stroke exercise and leak test these valves during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These valves are normally shut during power op(ration but are required to open to fulfill their safety function. Due to the lack of installed iistrumentation and relative system pressures, relief from quarterly full or part stroke exercising is requested.
In addition, relief from cold shutdown full or partial stroke exercising is requested due to the increased RCS boration required that would necessitate processing a large volume of RCS water. Waste processing could result in increased down time and more generation of rad waste. A full flow stroke exercise for these valves will be performed at refueling per OST 1.11.14.
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category A/C 151-94 and"1SI-95 from the exercising requirements of Sec tion XI. The licensee has demonstrated valves 36
cannot be full stroke exercised du:ing power operation because the HHSI pumps cannot overcome RCS operating pressure.
Partial stroke these valves exercising would result in reactivity excursions from BIT injection nozzles that could result in a reactor trip.
Exercising these valves during cold shutdown with highly borated water could delay reactor startup due to the extensive cleanup required to return the RCS water to startup specifications. We conclude that full stroke exercising these valves during refueling outages should demonstrate proper valve operability, g.
Relief Request The licensee has requested specific relief from exercising Category A/E Valve ISI-41, accumulator fill line isolation in accordance with the requirements of Section XI and proposed to leak test this valve it refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief Relief from quarterly and cold shutdown full or part stroke exercising is requested because this is a manual passive valve and its normal position is closed. Also its safety related position is closed and testing would be meaningless.
l This valve will be leak rate tested at refueling per
~
OST 1. 47.19.
37 L
Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A/E, passive Valve 151-41 from the requirements of Section XI.
This valve is in its safety related position and is not required to open or close to mitigate the c'onsequences of an accident or safely shut down the plant.
Therefore, the operability of this valve is inconsequential with regard to the safety function which it performs. We conclude that the quarterly stroke and stroke time measurements are meaningless for a passive valve.
2.
Category C Valves a.
Relief Request The licensee has requested specific relief from exercising Category C Valves 1S1-1 and ISI-2, LHSI pump suction checks from the containment sump in accordance with the requirements of Section XI and proposed to physically inspect and manually exercise the check valve discs during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These check valves, at power operation, are in their intended design position and remain closed. Any type of stroke testing would violate containment integrity.
To fulfill its safety function for long term core L
38
cooling the valve must open.
Due to the lack of test instrument tap offs and the feasibility of simulating actual safety injection long term cooling water flow from the containment sump because of physical limitations, relief from quarterly and cold shutdown exercising is requested.
A maintenance inspection to physically inspect these check valvas will be performed at refueling to verify proper stroke.
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C Valves 151-1 and ISI-2 from the exercising requirements of Section XI.
The licensee has demonstrated that due to present piping configuration and test taps that these valves cannot be exercised during power operation or cold shutdown.
In addition, flooding the containment sump to provide adequate LHSI pump suction would result in damage to electrical equipment inside the containment. We conclude that valve disassembly and manually full stroke exercising these valves during refueling outages should demonstrate proper valve operability.
b.
Relief Request The licensee hhs requested specific relief from exercising Category C Valve ISI-5, LHSI pumps suction from the RWST, ISI-6 and 151-7, LHSI pump discharge checks, and 151-27, LHSI to charging pump suction in accordance with the requirements of Section XI and 39
proposed to partial stroke these valves quarterly and full stroke exercise these valves during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These valves are normally shut but to fulfill their safety function they must open permitting flow from the RWST to the LHSI pump suctions. Quarterly the valve-is part stroked through surveillance checks but full stroke verification requires safety analysis flow.
Therefore, relief from quarterly full stroke exercising is requested due to the lack of test flow capability to simulate safety analysis flow and actual LHSI injection flow path inaccessability due to pressure differentials.
In addition, relief from cold shutdown full stroke exercising in requested due to the generation of additional radioactive waste by the additional boration required to verify a full flow condition through the LSHI injection flow path. A full flow stroke exercise for these valves will be performed at refueling per OST 1.11.14.
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C Valves ISI-5, ISI-6, ISI-7 and 1SI-27 from the exercising requirements of Section XI.
The licensee has demonstrated that the only full flow test path is into the RCS and that the LHSI pumps cannot overcome 40
RCS operating pressure.
Partial stroke exercising during power operation is accomplished during the LHSI pump testing on a recirculation flow path. During cold shutdown exercising these valves would inject highly borated water into the RCS which could result in a delay of reactor startup due to the extensive cleanup requirements to return the RCS water to startup specifications. We conclude that full stroke exercising these valves during refueling outages should demonstrate proper valve operability.
c.
Relief Request The licensee has requested specific relief from exercising Category C Valves ISI-15,151-16, ISI-17, 15I-20, 151-21, 151-22, 1SI-23, 15I-24, 1S1-25, 1SI-100,1S1-101, and 1S1-102, safety injection to RCS header checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.
Code Requirement Refer to valve testing paragrapn A. 2.
Licensee's Basis for Requesting Relief These valves are nonnally shut during power operation but are required to open to fulfill their safety function.
Due to the lack of installed instrumentation and relative system pressures, reli.ef from quarterly full or part stroke exercising is requested.
In addition, relief from cold shutdown full or partial stroke exercising is requested due to the increased RCS boration required that would necessitate processing a l
41
large volume of RCS water. Waste processing could result in increased downtime and more generation of rad waste. A full flow stroke exercise for these valves will be performed at refueling per OST 1.11.14.
Evaluation We agree with the licensee's basis and therefore feel that relief should be granted for Category C Valves 151-15, 1S1-16, 1S1-17, 151-21, 151-22, 151-23, 1S1-24, 1S1-25, 151-100, 151-101, and 151-102, from the exercising requirements of Section XI.
The licensee has demonstrated that these valves cannot be exercised during power operation because the safety injection pumps cannot overcome RCS operating pressure.
Exercising these valves during cold shutdown would inject highly borated water into the RCS and could result in a delay of reactor startup due to the extensive cleanup required to return the RCS water to startup specifications. We conclude that full stroke exercising these valves during refueling outages should demonstrate proper yalve operability.
F.
Containment Vacuum and Leakage 1.
Category A and A/E Valves a.
Relief Request The licensee has requested specific relief from exercising Category A/E Valves HCV-1CV151 and HCV-1CV151-1 inside and outside containment isolations f or vacuum air ejectors, in accordance with the requirements of Section XI.
42
Code Requirenent Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These valves are shut at power and are passive manual valves not required to change position to fulfill their safety function.
Evaluation We agree witn the licensee's basis, and therefore feel relief should be granted for Category A Valves HCV-1CV151 and HCV-1CV151-1 from the requirements of Section XI. These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.
Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time' measurements are meaningless for passive valves.
b.
Relief Request The licensee has requested specific relief from exercising Category A/E Valves ICV-35 and ICV-36, inside and outside containment' isolations for the sealed pressure system in accordance with the requirements of Section XI.
Code Requirenent Refer to valve testing paragraph A. 2.
43
1 Licensee's Basis for Requesting Relief These valves are manual passive valves shut at power and are required to be shut to fulfill their safety f unc tion. Relief, therefore, is requested from full or partial stroke exercising at power or cold shutdowns.
Evaluation We agree with the licensee's basis, and therefore feel relief should be granted for Category A Valves ICV-35 and ICV-36 from the requirements of Section XI.
These valves are in their safety related position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant.
Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurements are meaningless for passive valves.
G.
Component Cooling 1.
Category A and A/E Valves a.
Relief Request The licensee has requested specific relief from-exercising Category A/E Valves ICC-247, ICC-248, ICC-251 and ICC-252, componeat cooling water to and from RHR heat exchangers, in accordance with the requirements of Section XI.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These passive valves are not required to change position to fulfill their safety function.
These valves are exercised during cold shutdowns.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category A Valves ICC-247, ICC-248, ICC-251 and 1CC-252, from the_ requirements of Section XI.
These valves are in their safety related position and are not required to op'en or close to mitigate the consequences of an accidnet or safely shut down the plant.
Therefore, the operability of these valves is inconsequential with regard to the safety function which they perform. We conclude that the quarterly stroke and stroke time measurement, are meaningless for passive valves.
b.
Relief Request The licensee has requested specific relief from exercising Category A valves TV-1CC103A, TV-1CC103A1, l
TV-1CC103B, TV-1CC103B1, TV-1CC103C, TV-1CC103C1, TV-1CC105A, TV-1CC1058, TV-1CC105D1, TV-1CC105D2, TV-1CC105E1, TV-1CC105E2, TV-1CC10701, TV-1CC107D2, TV-1CC107E1, TV-1CC107E2, component cooling supply and i
return to RCPs containment isolations, in accordance with the requirements of Section XI and proposed to l
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full stroke exercise these valves during cold shutdowns that RCPs are secured and at least once each refueling outage.
Code Requirenent Refer to valve testing paragrpah A.2.
Licensee's Basis for Requesting Relief Stroking any of these valves with the associated RCP running would cause severe danage to the pump bearings, stator, and thennal barriers if the affected valve would f ail to reopen. Theref ore, relief is requested from f ull or partial stroke exercising these valves during power operation and cold shutdowns when RCPs are running.
Evaluation We agree with the licensee's basis and, therefore, feel that relief should be granted for Category A valves TV-1CC103A, TV-1CC103A1, TV-1CC1038, TV-1CC10381, TV-1CC103C, TV-1CC103C1, TV-1CC105A, TV-1CC1058, TV-1CC10501, TV-1CC10502, TV-1CC105E1, TV-1CC105E2, TV-1CC10701, TV-1CC10702, TV-1CC107E1, TV-1CC107E2, canponent cooling supply and return to RCPs containment isolations, from the exercising requirements of Section XI.
The licensee has demonstrated that f ailure of any of these valves in the closed position during power operation or cold shutdowns that RCPs are running would result in severe dsnage to the RCP bearings, stator, and/or thermal barriers resulting in loss of the RCP until repairs could be performed. We conclude 46
h that exercising these valves during cold shutdowns t at RCPs are secured and at least once each refueling outage should demonstrate proper valve operability.
2.
Category B Valves _
Relief Request _
a.
The licensee has requested specific relief from exercising Category B valves TV-1CC107A, TV-1CC1078, and TV-lCC107C, component cooling to RCPs trip valves, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during cold shutdowns that RCPs are secured and at least o each refueling outage.
Code Requirement Refer to valve testing paragraph A.2.
Licensee's Basis for Requesting Relief Stroking any of these valves with the associated RCP i
running would cause severe damage to the ptsnp bear ngs, stator, and thermal barriers if the affected valve Therefore, relief is requested would f ail to reopen.
from full or partial stroke exercising these valves during power operation and cold shutdowns when RCPs are running.
Evaluation _
feel We agree with the licensee's basis and, therefnro, that relief should be granted for Category B valves TV-1CC107A, TV-1CC1078, orid TV-ICC107C, component m
e cooling to RCPs trip valves, from the exercising requirements of Section XI. The licensee has denonstrated that f ailure of either of these valves in the closed position during power operation or cold shutdowns that RCPs are running would result in severe damage to the RCP bearings, stator, and/or thermal barriers resulting in loss of the RCP until repairs could be perfonned. We conclude that exercising these valves during cold shutdowns that RCPs are secured and at least once each refueling outage should demonstrate proper valve operability.
H.
Fuel Pool Cooling and Purification 1.
Category A/E Valves Relief Request The licensee has requested specific relief from exercising Category A/E Valves 1PC-9,1PC-10, IPC-37, and IPC-38, fuel pooling cooling and purification containmtnt isolations, in accordance with the requirenents of Section XI.
Code Requirenent Refer tu valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief Relief is requested from power and cold shutdown full or part stroke testing because these are nonnally shut, manual passive containment isolation valves and their safety position is shut. These valves will be leak tested during refueling outages.
48
\\.
s
~
Evaluation T
i We agree with the licensee's basis, and therefore feel, relief should be granted for Category A/E Valves IPC-9, IPC-10, IPC-32 and IPC-38 from the requirements of s
Section XI.
These valves are in their safety related
,f position and are not required to open or close to mitigate the consequences of an accident or safely shut down the plant. Therefore, the operability of these valves is inconsequential with regard to the safety functior, which they perform. We conclude that the quarterly stro<e and stroke time measurements are meaningleis for passive va'lves.
1.
Ma i n S tea _m_
1.
Category C Valves a.
Relief Request The licensee has requested specific relief fron exercising Category C Valves IMS-80, IMS-81, and 1MS-82, Loop A, B, and C residual heat release reverse, l
flow checks, in accordance with the requirenents of.
Section XI and proposed to manually disassemble and a
exercise these valves during refueling outages, s
l Code Requirenent_
Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief x
Relief is requested frSn at power and cold shutdowrs full stroke testing because there is no installed 1
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3
instrunentation to check f or reverse flow and the headers are nonnally cross connected and pressurized.
No way exists to isolate and systematically check operation of these valves. A maintenance inspection to disassemble and check full stroke exercising will be perfonned at refueling outages.
Evaluation We agree with the licensee's basis and therefore feel relief should be granted for Category C Valves IMS-80, IMS-81, and IMS-82 from the exercising requirements of Section XI. These valves are not equipped with position indicators and no other instrumentation is installed that could indicate valve position. The licensee has demonstrated that due to plant design the only method available to verify valve position and exercising is visually and manually. We conclude that valve disassembly with a visual inspection and a manual full stroke exercise during refueling outages should verify valve operability.
J.
River Water 1.
Category C Valves Ry,1,igf,,Reye.s t, a.
t~
The licensee has requested specific relief from exercising Category C Valves 1RW-197, and 1RW-198, river water reverse flow checks, in accordance with the requirements of Section XI and proposed to partial stroke exercise these valves during refueling outages.
t 50
r Code Requirement Refer to valve testing paragraph A. 2.
Licensee
- s Basis for Requesting Relief These valves are normally shut at power operation but are required to open to fulfill their safety function.
Relief from quarterly and cold shutdown full stroke exercising is requested due to rendering the entire river water system inoperable to f acilitate maintenance to remove the checks for visual inspection. There is no existing instrumentation to verify check valve position. These valves are partial stroked at refueling outages through flow checks on the recirculation spray heat exchangers.
Evaluation We agree with the licensee's basis and therefore feel tenporary relief should be granted for Category C Valves 1RW-197, and 1RW-198 from the exercising requirements of Section XI. The licensee has demonstrated that due to present plant design these redundant parallel valves cannot be individually exercised.
In addition, no instrumentation is installed that could assure each valve is full stroke exercised. Therefore, only partial stroke exercising is possible. The river water system is required for reactor power operation, cold shutdown and refuell'ng outages. Thus, these valves cannot be renoved from the system and manually exercised. We conclude that due to present plant design the only available test is partial stroke exercising through the recirculation spray heat exchangers. However, we feel the licensee should 51
further investigate a method to full stroke exercise each valve.
K.
Post H DBAControl 2
1.
Cat,egory A/C Valves a.
R,ellef Request The licensee has requested specific relief from exercising Category A/C Valves 1HY-119 and 1HY-120, recombiner containment isolation checks, in accordance with the requirements of Section XI and proposed to full stroke exercise these valves during refueling outages.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief These check valves are shut at power and are required to remain shut at the onset of the postulated accident tu fulfill their safety function. Relief from quarterly and cold shutdown full or part stroke i
exercising is requested due to inaccessibilit, of the valves inside containment and the need for extensive rigging to get near the valve. These valves are full stroke exercised during refueling outages.
I l
Evaluation _
j We agree with the licensee's basis and therefore feel relief should be granted for Category A/C Valves lHY-119 and 1HY-120 from the exercising i
52 l
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requirements of Section XI. The licensee has demonstrated that due to plant design the only method available to verify valve closure (their safety related position) is during leak testing. These valves are not equipped with valve position indicators and some of the required test connections are located inside the containment. We conclude that the proposed alternate testing frequency of verifying valve closure during the perfonnance of leak rate testing at refueling outages should demonstrate proper valve operability.
2.
Category B Valves a.
Relief Request The licensee has requested specific relief from exercising Category B Valves MOV-1HY201A and MOV-1HY201B, H recombiner flow regulating valves, in 2
accordance with the requirements of Section XI and proposed to exercise these valves every 6 months.
Code Requirement Refer to valve testing paragraph A. 2.
Licensee's Basis for Requesting Relief Relief is requested from quarterly full or part stroke testing of these valves because they are an integral part of the Hydrogen Recombiner.
It is presently tested every six months during nonnal operation. These valves cannot be physically observed, but operation is checked by virtue of the valve maintaining a specific flow. These valves will be exercised every six months.
53
i Evaluation We do not agree with the licensee's basis and therefore feel relief should not be granted for Category B j
Valves M0y-1HY201A and M0V-1HY2018 from the exercising requirements of Section XI. The licensee has not provided a specific technical basis for not exercising these valves quarterly. We conclude that these valves should be exercised quarterly and this test method should demonstrate proper valve operability.
l, i
i 4
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54
-r
V.
Attachnent_1 The following are Category A, B, and C valves that meet the requirenents of the ASME Code Section XI and are not full stroke exercised every three months during plant operation. These valves are specifically identified by the owner and are full stroke exercised during cold shutdowns and refueling outages.
EG&G has reviewed all valves in this attachment and agrees with the licensee that testing tnese valves during power operation is not possible due to the valve type and location, system design, or because this action would place the plant in an unsafe condition. We feel these valves should not be exercised during power operation. These valves are listed below and grouped according to the system in which they are located.
A.
Chemical and Volume Control 1.
Category A Valve MOV-CH-142, residual heat removal letdown to chemical and volume control isolation, cannot be exercised during power. operation. During power operation this valve is snut and is not required to change position to fulfill its safety function.
It is a passive valve and opening it during normal operation of the plant would divert nonnal letdown back into the RhR system and cause an overpressure condition to exist. Therefore, relief fran nonnal three month exercising is being requested. This valve will be stroke exercised and timed at each cold shutdown per OST 1.1.10.
2.
Category A Valve FCV-1CH-160, reactor coolaa,t system fill header isolation, need not be exercised during power operation. This valve is a nonnally closed passive containment isolation valve and is not required to change position to fulfill its safety function. During cold
, shutdown this valve will be stroked and timed per OST 1.1.10.
55
3.
Category B Valves MOV-1CH-115C and E, volume control tank isolations cannot oe exercised during power operation.
These valves are normally open during power operation and shutting them would isolate the Volume Control Tank from the Charging Pumps. This would result in a loss of nonnal Reactor Coolant System makeup and Reactor Coolant Pump seal injection water causing possible pump danage and system degradation. These valves will be exercised and timed per OST 1.1.10 during cold shutdowns.
4.
Category B Valve MOV-1CH-311, pressurizer alternate spray valve, cannot be exercised during power operation. At power operation this valve is shut and is required to be shut to perf orm its saf ety f unction. Opening this valve at power operation would thermally shock the spray nozzles, exceed the 320F T, and cause an uncontrolled pressure transient.
Therefore, relief from quarterly stroke exercising and timing is requested. This valve will be full stroke exercised and timed at each cold shutdown and refueling per OST 1.1.10.
5.
Category C Valve ICH-141, emergency boration line non-return check, cannot be exercised during power operation. During power operation this valve is shut and the only means to verify valve operation, due to the lack of installed instrumentation, would be to initiate flow through the emergency boration path. Tnis would cause an undesired power transient that could result in a reactor trip.
Theref ore, relief from quarterly full stroke testing is l
requested. This valve will be full stroke tested at each cold shutdoan per OST 1.1.10.
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B.
Safety Injection 1.
Category A Valve 151-91, BIT manual bypass, cannot be exercised during po.;er operation. This is a manual passive valve not required to change position to fulfill its safety f unc tion. This valve is shut at power operation and opening fully or partially would thermal shock the cold leg safety injection line nozzles. Therefore, relief is requested from full as well as partial stroke exercising at power. This valve will be full stroke exercised at cold shutdown and leak tested at refueling per OST 1.1.10 and OST 1.47.70.
2.
Category A Valves MOV-1SI-860A and M0V-1SI-8608, LHSI containment suctions, cannot be exercised during power operation. These valves are containment isolation valves open to containment atmosphere. Failure of these valves in the open position during power operations testing would compromise containment integrity. Therefore, relief is requested from testing during power operation. These valves will be stroked and timed during cold shutdown and leak tested during refueling.
3.
Category A Valves MOV-1SI-867C and MOV-1SI-S67D, BIT outlet containment isolations cannot be exercised during power operation. These valves are shut at power but required to open to fulfill their safety function. Opening these valves at power would require isolating the recirculation system to prevent possible overpressurization of lower pressure piping due to the lack of instrunentation. With isolation of the recirculation system the possibility of f ailure to reopen tne isolation valves could render the BIT inoperable.
Therefore, relief from full or part stroke exercising at power i; requested. These valves will be full stroke exercised al cold shutdowns and leak tested at refueling.
57
4.
Category A Valve MOV-iS!-869B, charging header BIT by-pass and MOV-ISI-869A, RCS hot leg fill, cannot be exercised during power operation. This valve is shut at power and is not required to change position to fulfill its safety function at the onset of the accident. Only during the simultaneous cold and hot leg recirculation phase is the valve opened.
In addition, thermal stressing of the hot leg injection nozzles would occur. Therefore, relief from full or part stroke exercising of this valve at power is requested. This valve will be full stroked at cold shutdowns per OST 0.1.10 and leak tested at refueling per OST 1.47.9.
J 5.
Category A Valves MOV-1SI-890A and MOV-1SI-8908, LHSI to RCS hot legs, cannot be exercised during power operation. These valves are shut at power and remain shut to fulfill their safety function. Relief f rom full or partial stroke exercising at power is requested due to the possibility of overpressurizing the LHSI system caused by f ailure of the upstream check valve and lack of positive pressure indication. These valves will be full stroke exercised at cold shutdown per OST 1.1.10 and leak tested at refueling per OST 1.47.52.
6.
Category A Valve MOV-1SI-890C, LHSI to RCS cold legs, cannot be exercised during power operation. This valve is open during plant operation and is required to be open to fulfill its saf ety f unction at the onset of the accident. Relief fram full or partial stroke exercising of this valve at power is requested because failure of this valve to reopen would render LHSI cold leg injection from both trains l
Inoperable. This valve will be full stroked at cold snutdown per OST 1.1.10 and refueling leak tested per OST 1.47.53.
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7.
Category B Valves MOV-1SI-867A and MOV-1SI-8678, BIT inlet isolations, cannot be exercised during power operation.
These valves are shut at power operation but are required to open to fulfill their safety function. Opening partially or fully at power would dilute the concentration and lower the operating temperature of the (BIT) rendering it inoperable per technical speciflCation requirenents. Therefore, relief is requested from full or partial stroke exercising at power. These valves will be full stroke exercised at extended cold shutdowns and refuelings.
8.
Category B Valves TV-1SI-884A, TV-1SI-8848, and TV-1SI-884C, BIT recirculation isolations, cannot be exercised during power operation. These valves are nonnally open during power operation for boric acid recirculation. Their safety position is shut and closing this valve with subsequent f ailure to reopen could degrade the Baron Injection System due to acid solidification. Relief from exercising is requested for the above reason during poser operation.
These valves will be exercised and timed during cold shutdown per OST 1.1.10.
C.
Contairrnent Depressurization 1.
Category A/C Valves 1Q5-3 and 1QS-4, inside containment isolation checks for quench spray headers, cannot be exercised during power operation. These valves are shut at power and open with initiation of quench spray flow at onset of the accident, and shut af ter containment depressurization is achieved. Relief from full or part stroke exercising this valve at power is requested because of physical limitations, (scaffolding needs to be built to reach these valves) that are located inside the containment. These
, alves will be exercised during cold shutdowns.
v 59 1
2.
Category A/C Valves 1RS-100 and 1RS-101, inside containment isolation checks for outside recirculation spray lines, cannot be exercised during power operation. These valves are nonnally shut at power but are required to open to fulfill their safety function. Due to inaccessibility without ladders or scaffolding, being located inside the sub-aunospheric containment, and being dry pipe, relief from part or full stroke exercising quarterly is requested.
These valves will be manually full stroke exercised during cold shutdowns.
D.
Conponent Cooling 1.
Category B Valve TV-NS101, neutron shield tank makeup water isolation, cannot be exercised during power operation. This valve is shut at power and is required to remain shut to fulfill its saf ety function. Relief from quarterly full or partial exercising is requested due to the possibility of the valve sticking open and overflowing the neutron shield expansion tank. This valve will be exercised during cold shutdowns.
2.
Category A Valve TV-lCC110F1, cooling water discharge from containment air recirculation coolers, cannot be exercised during power operation. Relief is requested from at power testing because if this valve f ailed to close while being tested, this would incapacitate the contalmnent cooling j
system that is nonnally cooled by chilled water. This valve will be tested at cold shutdown. This valve will be full stroke exercised during cold shutdowns.
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3.
Category A Valves TV-1CC111A1, TV-1CC111A2, TV-1CC111D1, and TV-1CC11102, inside and outside containment isolations for the CRDM coolers, cannot be exercised during power operation. These valves are nonnally open at power operation and are required to close to fulfill their safety function upon a CIB signal. Relief from at power part or full stroke testing is requested because shutting any of these valves and isolating cooling water, while the reactor control or shutdown rods are energized, or the plant is above 250 degrees Fahrenheit, would result in component danage. These valves will be exercised during cold shutdowns.
E.
Main Stean 1.
Category L Valves 1MS-18, IMS-19, and IMS-20, steam driven auxiliary feed planp reverse flow checks, cannot be exercised during power operation. Relief is requested from quarterly, full stroke and backseat verification because of the (potentially hazardous) environment encountered in the main steam valve room. These valves are exercised during the monthly OST because it is one of three steam supplies to a stean header. These valves are nonnally closed, but may be
~
required to either open or shut to fulfill their intended purpose. These valves are full stroke exercised during return to power from cold shutdown.
2.
Category B/C Valves NRV-1MS-101A, NRV-1MS-101B, and NRV-1MS-101C, main steam non-return checks, cannot be exercised during power operation. Relief is requested for stroke testing during power operatio'n because it is not 61
possible to stroke these valves due to both physical restraints (steam flow) and reactor protection (steam break) restraints. These valves will be verified closed during cold shutdown valve exercising.
3.
Category B Valves PCV-lMS-101A, PCV-1MS-1018, and PCV-1MS-101C, main steam line abnospheric dump valves, cannot be exercised during power operation. Relief is requested f rom full or part stroke testing during power operation because these manual isolation valves are located in a potentially hazardous area. The manual valve could possibly be damaged when being reopened against a 1,000 psi dp.
These valves will be full stroked and timed at cold shutdown.
4.
Category B/C Valves TV-1MS-101A, TV-1MS-1018, and TV-1MS-101C, main steam line isolations, cannot be exercised during power operation. Relief is requested for full stroke testing during power operation because it would cause a possible safety injection and reactor trip. These valves will be part stroked quarterly during power operation and full stroked and timed during hot standby.
F.
Feedwater 1.
Category C Valves IFW-33, 1FW-34, and 1FW-35, auxiliary feed pump discharge checks, cannot be exercised during power operation. Relief is requested from stroking at power due to thermal shock of auxiliary feed and main feed interf ace.
Feeding steam generators with cold water would result in large level transients. These valves will be exercised during cold shutdowns.
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c 2.
Category C Valves 1FW-42,1FW-43, and 1FW-44, auxiliary feedwater to main feedwater checks, cannot be exercised during power operation. Relief is requested from stroking at power due to thermal shocking of auxiliary feed and main feed interface. Feeding steam generators with cold water would result in large level transients. These valves are full stroke exercised during cold shutdowns.
3.
Category C Valves 1FW-387, 1FW-388, 1FW-389, 1FW-390, 1FW-391, and 1FW-392, auxiliary feedwater redundant header cnecks, cannot be exercised during power operation. Relief is requested from full or part stroke testing at power because of the thermal shock of auxiliary feed and main feed interface. Feeding steam generators with cold water would result in large level transients. These valves will be full stroke exercised during cold shutdowns.
4.
Category B/C Valves MOV-1FW-156A, MOV-1FW-156B, and MOV-1FW-156C, loop feedwater containment isolation checks, cannot be exercised during power operation. Relief is requested from full and part stroke testing at power because shutting these valves during power operation could cause a loss of f eedwater resulting in a loss of h' eat sink and a reactor trip. The motor operator associated with this valve is for closure with a very small or no differential pressure across the valve; it is not for use at power. These valves will be exercised during cold shutdown.
l 5.
Category B Valves FCV-1FW-478, FCV-1FW-479, FCV-1FW-488, FCV-1FW-489, FCV-1FW-498, and FCV-1FW-499, main feedwater flow control and bypass valves, cannot be exercised during power operation. Relief is requested from full or part stroke testing at power because shutting these valves at power could cause a loss of feedwater resulting in a loss of l
heat sink and a reactor trip. These valves are backup containment isolation valves. These valves will be full stroke exercised during cold shutdown.
63
G.
Compressed Air 1.
Category A Valve 11A-90 and Category A/C Valve 11A-91, instrument air contalmnent isolations, need not be exercised during powe operation. Relief from quarterly full or partial stroke exercising is requested because these valves are passive valves not required to change position to fulfill their safety function. These valves are full stroke exercised during cold shutdown.
2.
Category A/C Valve 15A-15, and Category A/E Valve 1SA-14, station air containment isolations need not be exercised during power operation. These valves are shut at power and are required to remain shut to fulfill their safety f unc t i on. Theref ore, they are classified as passive valves and relief from quarterly full or partial stroke exercising is requested. T.4ese valves are full stroke exercised during cold shutdowns.
H.
Control Air Ventilation 1.
Category A Valves IVS-05-3A, IVS-DS-38, IVS-D5-SA, and IVS-D5-58, containment isolations for refueling purge lines, need not be exercised during power operation. These dampers are shut at power operation and are required to remain shut to fulfill their safety function. Relief from quarterly full or part stroke exercising is requested for these passive valves not required to change position to fulfill their safety function. These valves will be exercised during cold snutdowns.
4 2.
Category A/E Valve IVS-D-5-6, containment vacuum break line isolation, need not be exercised during power operation.
This damper is shut. at power operation and required to 64
remain shut to fulfill its safety function. Relief from quarterly full or part stroke exercising is requested because of it being a passive valve not required to change position to fulfill its safety function. This valve will be exercised during cold shutdown.
3.
Category B Valves TV-IVS101A, TV-1VS101B, TV-1VS101C, TV-1VS1010, and TV-1VS101E, control room emergency air bottle outlet isolations cannot be exercised during power operation. These valves are shut at power operation and are required to open to fulfill their safety function. Relief from quarterly full or partial stroke exercising is requested due to the fact that present testing capabilities would possibly violate technical specification bottle pressure requirements. These valves will be full stroke exercised during cold shutdown.
I.
Post H DBA Control 2
1.
Category A/E Valves 1HY101, 1HY102, 1HY103, 1HY104, 1HY110, and 1HY111, H recombiner containment isolations, need not 2
be exercised during power operation. These valves are shut at power and are required to remain shut at the onset of the postulated accident to fulfill their safety function.
Relief fron quarterly full or part stroke exercising is requested to prevent violating containment integrity. These valves will be full stroke exercised during cold shutdown.
t
e VI. Attachment 11
.Tne drawings listed below were used during the course of this review.
Drawing No.
System 155A-6 & 155B-6 Reactor Coolant Chemical and Volume Control 159A-6 & 1598-7 169A-6, 169B-5, & 169C-6 Vent and Drain 156A-6 Residual Heat Renoval 167A-4 & 167P-4 Safety Injection Containment Vac. and Leakage Monitoring 168A-5 Containment Depressurization 165A-6 179A-6, 179B-6, & 179C-5 Sample 157A-6, 157B-5, 157C-5 &
Camponent Cooling 1570-6 162A-4 Fuel Pool Cooling 120A-5 Main Steam 124A-6 Feedwater 180A-4 Steam Generator Blowdown 122A-4 Auxiliary Steam 1298-1 Chilled Water 127A-7 River Water 1278-6 Intake Structure 151A-4 Emergency Diesel 150B-6 Post DBA Hydrogen i
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VII. Attaclynent III T
A.
The following valves are never full stroke exercised or have a l
testing frequency greater than each refueling outage.
4 j
1.
Valve Testing Program a.
E.1.c b.
E.1.d c.
J.1.a B.
The following relief requests have insufficient technical basis, l
and relief is not recommended.
i 1.
Valve Testing Program a.
K.2.b
[
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ENCLOSURE 3 GUIDAftCE CONCERNING INSCRVICE TESTING OF PUMPS AND VALVES Following are staff positions used to determine the adequacy of Inservice Testing.
Programs and to grant relief from ASME Section XI requirements, where appropriate.
A.
Scope - All valves important to safety (e.g. required to shut down the plant to cold shutdown, maintain the plant in cold or hot shutdown condition or mitigate the consequences of an accident) should be included in the IST piogram. Pressure relief valves should not be omitted from the program.
8.
Testina Intervals 1.
Quarterly testing required by the Code should be performed unless impractical.
2.
If quarterly testing is not possible the next interval to be con-sidered is cold shutdown.
3.
Testing at refueling is the longest acceptable'ir.terval.
C.
Exceptions to Testina Recuirements 1.
Passive Gate Valves - Gate valves which are not required to change position for any operating condition of the plant are exempted from the testing requirements of Section XI. However, their positions should be verified quarterly and each time the valve is cycled.
2 Check Valves, Control Valves and Relief Valves - The measurement of stroke times is meaningless for these valves. Relief, if requested, should be granted.
3.
Valves should be exer::ised at intervals as close as practical to those required by the Cc h.
Where full stroking is not practical on a quarterly basis, part stroking quarterly is acceptable when supple-mented by full stroking on a cold shutdown or refueling basis.
4.
Valve tests should not be performed such that they place the plant in an unsafe condition (e.g. a failure might constitui:e a loss of system function).
5.
Valves with very fast closing times'(e.g. less than 2 seconds) may be exempted from the stroke time measurement and acceptance criteria as these are difficult to accomplish.
In such cases, however, it is important to establish reasonable alternatives. Measurement to the nearest second and corrective action based on a change of l second or more are considered acceptable.
D.
Unacceptable Relief Reouests ~
1.
A relief request based solely on radiation exposure to test personnel is not considered sufficient.
2.
Relief from full stroking a valve at some time is not usually granted.
3.
A relief request describing a check valve as a passive component, therefore, not needing exercise, is not granted.
4.
Relief from verifying remote position indicators at least each two years is not granted.
5.
Some licensees have proposed to use the " Maximum acceptable stroke time" as delineated in their FSAR as the value at which corrective action is required. This is not considered an acceptable alternative. For example, a valve's operating time may be acceptable up to a value of 30 seconds to satisfy FSAR commitments. However, the valve actually operates in 10 seconds.
It is readily obvious that considerable degradation could occur without any requirement for corrective action.
6.
Nonspecific relief requests (e.g. plant management to determine whether or not a valve is considered inoperable, plant management to determine conditions for restart, etc.) are not acceptable.
E.
Soecial Cases 1
Corrective Action - When a valve is found to be inoperable at cold shutdown with respect to Code acceptance criteria the use of plant Technical Specifications to determine acceptable conditions for restart has been accepted. However, it should be accompanied by positive statements concerning the plan of action to correct the incoerable status.
' P Past experience has indicated that certain valves are extremely hard 2.
to full stroke test, as follon.
Accumulator or Core Flood Tank Check Valves (PWR) a.
Containment Sump Recirculation Suction Check Valves (PWRs) b.
Containment Spray Check Valves.(BWRs&PWRs) c.
Relief requests pertaining to these components should be referred to the MEB reviewer.
Containment Isolation Valves (CIV) and Pressure Isolation Valves (PIV)
F.
All PIVs and CIVs should be Category A or AC.
1.
PIVs (valves which form the barrier between high and low pressure systems) should have their leak tight integrity and operational readiness (exercise, etc.) verified in accordance with Section XI of the ASME Code.
CIVs (valves which penetrate the containment boundary and comunicate 2.
with either the containment a.tmosphere or the reactor coolant system) should be redundant for each penetration and should have their leak tight integrity verified in accordance with Appendix J to 10CFR50.
These valves are-exempted-from-the perational readiness (exerc j
must also have their oremaining-pegw&Femen h-ef-See hen verified in accordance with Section XI of the Code.
l XL-of-the-Code.
CIV/PIV - Valves which perform both a containment isolation function 3.
and a pressure isolation function, though not necessarily at coincident times, must be tested to both verify their operational readiness in l
accordance with ASME Section XI and leak tight integrity in accordance i
t with Appendix J to 10CFR50 and ASME Section XI.
Ddviations in 1.eak Test Mediums - It is acceptable to leak test a valve G.
with air and analytically determine the equivalent water leakage if the licensee has provided the correlation between the leakages of these two l
i mediums.
l 1
4-II. Pumos A., Scope - All pumps supplied with an emergency power supply are to be included in the program.
B.
Testina Intervals - The 1974 and 1977 editions of the ASME Code required pump testing monthly. However, the 1980 Code has increased the acceptable interhaltoquarterly. Relief to test on a quarterly basis is usually granted for individual pumps if,a reasonable basis is provided. However, it should be demonstrated that the individual pump will not suffer degradation if exercised only at 90 day intervals.
C.
Bearine Temaerature - Relief from measuring this parameter is generally granted if a reasonable basis is provided.
D.
Other Relief Recuests - Relief requests pertaining to other than the measurements of bearing temperature and testing intervals should be referred to the MEB reviewer.
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