ML20058K170
| ML20058K170 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/30/1990 |
| From: | Rockhold H, Stockton N EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML18153C351 | List: |
| References | |
| CON-FIN-A-6812 EGG-NTA-8419, TAC-65555, TAC-65556, NUDOCS 9004190250 | |
| Download: ML20058K170 (91) | |
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w z.* . TECHNICAL EVALUATION REPORT a
. Idaho , PUMP AND VALVE INSERVICE TESTING PROGRAM-LNetional- '; SURRY POWER STATION, UNITS 1 & 2-Engineering
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- Dis report was prepared as an account of work sponsorid by'an agency .
of the. United States Government. Neither the United States ~ ' l, Governm, st not any agency thereof, not any of their employees, makes l any warranty, empressed or implied, or assumes any legal liabGky.or . L, responsibility for any third party's use, or the resuhs of such use, of any j, information, apparstus, product or process disclosed la this report, or - h represents that lu use by such third party would not infringe privasely owned rights. ?~ 1 4 I s. Y. . %
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- TECHNICAL EVALUATION REPORT- l PUMP AND VALVE INSERVICE TESTING PROGRAM *
' SVRRY POWER STATION l UNITS 1 & 2 i
Docket =No. 50-280 & 50-281 -
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Published March 1990 t Idaho National Engineering Laboratory. EG&G Idaho,'Inc. L Idaho Falls, Idaho- 83415: x Prepared for the - t U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ; g Under DOE Contract No. DOE-AC07-76ID01570 l FIN ik). A6812 i TAC'Nos. 65555 and 65556'
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, ABSTRACT This EG&G Idaho, Inc., report presents the results of our evaluation ~of
.the Surry Power Station Inservice Testing Program for pumps and valves whose, function:is safety related.
' PREFACE This report _is supplied as part of the-" Review of Pump:and Valve.
Inservice Testing Programs for Operating Plants (III)" Program being conducted for the U23. Nuclear Regulatory. commission, Office of Nuclear; : r Reactor Regulation,: Mechanical Engineering Branch, by EG&G Idaho, Inc... Regulatory andLTechnical Assistance. FIN No. A6812 B&R 920-19-05-02-0 Docket No. 50-280 & 502281 TAC Nos. 65555:and 65556 11
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i CONTENTS
^ ABSTRACT .............................................................; _ ii PREFACE ............................................................... 11
' l. INTR 00VCTION .
..........................-.......................... 1 2.- SCOPE ............................................................ 3
- 3. PUMP TESTING PROGRAM ....................................-......... '7. .l a
3.1 General Relief Requests .................................... 7 3.1.1' Bearing Temperature and Pump Vibration Measurements. .7- a 3.2 Centrifugal ~ Charging Pumps ................................. 10
' 3 . 2 '.1 Measurement of Test Quantities ..................... 10-3.3 Boric Acid Transfer Pumps .................................. 12 ,
l 3.3.1 Measurement of Test Quantities ..................... 12; 'i 3.4 Low Head Safety Injection Pumps ............................ 13 3.4.1 Measurement of Test Quantities ..................... 13: , 3.5 Recirculation Spray Pumps .................................. 15 L Measurement of Test Quantities ..................... 3.5.1 15 i 3.5.2 _ Frequency of Inservice Tests ....................... 16-I 3.6 Auxiliary Feedwater Pumps .................................. 17-i
, 3.6.1 Neasureiaent of Test Quantities-......................
17 j U 3.7 Residual Heat Removal _ Pumps . . . . . . . . . . . . . . . . . . . . . . . . . . . . .-. . . 18' 3.7.1 Frequency of Inservice-Tests ....................... 18L L 3.8 Service Water Pumps ........................................ 19 I -3.8.1 Measurement of Test Quantities ...................-. '19: L 3 '. 9 Diesel Fuel Oll1 Pumps ...................................... 21 [4 3.9.1 Measurement of Test Quantities ..................... 21 I;. l l iii J
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'i U 4.- VALVE TESTING PROGRAM .................. ......................... 23' 4.1- General - Rel i e f Reque st s ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23' 4.1.1 ; Leak Rate Testing of RCS Boundary: Isolation Valves . 23 4.1.2 Rel i e f Val ve Testi ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 4.1.3 Ra p i d - Act i ng V al ve s . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 29 4.1.4: Group Leak Rate Testing of Containment Isolation-Valves.............................................. 29 4.2 Feedwater System ........................................... 35 4.2.1 -Category C Valves .................................. 35 4.3 Chemical and Volume Control System . . . . . . . . . . . . . . . . . . . . . . . . . 38 4.3.1 Category _C Valves .................................. 38 4.4 Safety-Injection System .................................... .40
, 4 . 4 .1._ Category A/C Valves ................................ 40 4.4.2 C at eg o ry C V al v e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 4.5 Refueling Water Crosstie System ............................ 48 4.5.1 Category C Valves .................................. 48 4.6 Reactor Coolant System ..................................... -50 4.6.1 C ateg o ry B V al ve s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '50
~ 4.7 Main' Steam System .......................................... 51 4.7.1 Category C Valves-.................................. :51 4.8 Di e sel Fuel Oi l Sy s tem -. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 4.8.1 ' Category B Valves .................................. 52 4.8.2 Category C kalves .................................. 53 4.9 Diesel Air Start System .................................... 54 4.9.1 Category 8 Valves .................................. 54 APPENDIX A--VALVES TESTED DURING COLD SHUTDOWNS ....................... 'A-1 APPENDIX B--P&ID LIST ................................................. B-1 APPENDIX C--IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW ........ C - l' iv
L s, - o.; e 1 TECHNICAL EVALUATION REPORT f PUMP'AND VALVE INSERVICE TESTING PROGRAM-SURRY POWER STATION. UNITS 1 AND 2 i
.. 1. INTRODUCTION Contained herein is a technical evaluation of the pump and valvs inservice testing (IST) program submitted by Virginia Electric and Power I Company for its Surry Power Station, Units 1 andL2. t The working session with Virginia Electric and Power Company ,
representatives was conducted on March 29 and 30, 1988. The licensee's pump and val've IST programs, Revisions 4 and 2 for Units 1 and 2 respectively, dated September 30, 1988, were reviewed to verify compliance with proposed. _ tests for pumps and valves whose function is safety-related with the > ( requirements of.the ASME Boiler and Pressure Vessel Code (the Code), Section XI, 1983 Edition through Summer 1983 Addenda., A revision for relief-request P.1 for both units was submitted on February 22, 1989.. The licensee l provided further clarification for numerous relief requests in a letter dated January 17, 1990. Any IST program revisions subsequent to those noted ; above are not addressed in this technical evaluation report (TER). Any . program revisions should. follow the guidance of Generic Letter No. 89-04, "duidance on_ Developing Acceptable Inservice Testing Programs". i L i
.n their IST program, the Virginia Electric and Power Company has reques ted relief from the ASME Code testing requirements for specific ' pumps i and ~ val ies. These requests have been evaluated individually to determine if the criteria in 10 CFR 50.55a for granting relief has indeed been met. This review was performed utilizing the acceptance criteria of the . Standard Review. Plan, Section 3.9.6, the Draft Regulatory Guide and Value/ Impact Statement titled, " Identification of Valves for Inclusion in Inservice Testing Programs", and Generic Letter No. 89 04, " Guidance on Developing Acceptable Inservice Testing Programs." The IST Program testing requirements apply only to component testing (i.e., pumps and valves) and are not intended to provide the basis to change the licensee's current
- Technical Specifications for system test requirements.
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f:. ' Section' 2 of this report presents the scope of this review. Section 3' of this report' presents the Virginia ~ Electric'and- P)wer Company-bases for requesting relief frem the Section XI requiremerts for the Surry. Power. Station pump testing program, and the EG&G reviewer's j evaluations and conclusions regarding these requests. Similar irformation ; g is presented in Section 4 for the valve testing program.- Category A, B, and C valves, which are exercised at cold shutdown and i refueling outages and meet the requirements of the ASME Code, Section XI, e are addressed in Appendix A. g , A listing of P&lDs and Figures used for this review is contained in q
- Appendix B.
Inconsistencies and omissions in the licensee's IST program noted during the course of this review are listed in Appendix C. The licensee' should. resolve these items in accordance with the evaluations, conclusions,, and guidelines presented in'this report. I
'This TER,, including all relief requests and component identification numbers, is applicable to Units 1 and 2.. The first digit of the valve 3
number is.the. unit designator. The Unit 2 designator has been placed in
- parentheses, where possible, to minimia repetition (i.e., 1(2)-Rh-5).
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- 2'.' SCOPE i
The EG&G' Idaho review of the Scrry Power Station IST program for pumps
~'and valves began..in April, 1987. The programs initially examined were ,
it Revisions 3 and I dated March 27 and April 1, 1987 for Units 1 and 2~ ! respectively. <These revisions identified the licensee's proposed testing of safety-related pumps and valves in the plant systems listed in Appendix B. The licensee':, proposed'IST program was reviewed by locating and highlighting the components on the appropriate system P& ids and determining' l their function in the system. Then the licensee's proposed testing.was evaloned to determine if it was in compliance with the ASME Code, i
.Section XI,' requirements. 1During the course of this review, questions and-comments were made pertaining to unclear or potential problem areas in the
- licensee's IST. program. These were transmitted to the licensee in the form of a request foriadditional information (PAI) which served as the agenda for ;
the working meeting between the licensee, the NRC, and the EG&G reviewers. Each pump and valve relief request was individually evaluated to ! determine if the licensee .had clearly demonstrated compliance with the Code l requirements-was impractical or presented a hardship without compensating h increaseLin' safety for the identified system components, and to determine if. the proposed alternate testing would provide a reasonable indication of , component operability. Where the licensee's technical basis or alternate s testing was insufficient, the licensee was requested to clarify the relief g ? request. :The system P&ID was also examined to determine whether the-instrumentation necessary to make the identified. measurements is available. If, based on the unavailability of adequate instrumentation, or the reviewer's experience and knowledge, it was determined that it may not be D possible or practical to make the measurements identified in the licensee's IST program, a question or comment was generated requesting clarification. J l - p-1 h For pumps, it was verified that each of the seven inservice test quantities of Section XI, Table IWP-3100-1, were being measured or
- observed. For those test quantities that were not being measured or I
observed quarterly in accordance with the Code, it was verified that a i l 3 l l
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t request;for relief from the Code requirements had been submitted. !f thh testing was not being performed in accordance with the Code and a relief request had not been submitted, the licensee was requested to explain = the inconsistency in the RAI. The review of the proposed testing for valves verified that all appropriate ASME Code testing for each individual valve was performed as required. The proposed testing was evaluated to determine if all valves that were judged to be active Category A, B, and/or C (other than safety and relief valves) were exercised quarterly in accordance with IWV 3410 or 3520. If any active safety-related valve-is not full-stroke exercised, quarterly as required;.then, the licensee's' justification for the deviation, either in the form of a cold shutdown justification or a relief request; was examined to determine its accuracy and adequacy. The proposed alternate
, testing was also evaluated to determine its whether is was an acceptable' alternative to the Code requirements.
Safety and relief valves which are safety-related, excluding. those that perform only a thermal relief function, were confirmed to be included in the-IST program and tested in accordance with IWV-3510. For valves with remote position indication, the reviewer confirmed that ' the valve. remote position indication is ver:fied in accordance with IWV-3300. The reviewer verified that'the' licensee had-. assigned limiting values- of full-stroke times for all power operated valves in the. IST program. as required by-IWV-3413. For valves having a fail-safe actuator, the
-reviewer confirmed that the fail-safe actuator is tested in accordance with IWV-3415.
Each check valve was evaluated to determine if the proposed testihg would verify its ability to perform the-required safety function (s). Extens.ive system knowledge and experience with other similar facilities is used to determine whether the proposed tests would full-stroke exercise the check valve disks open or verify their reverse flow closure capability. If there was any doubt about the adequacy of the identified testing, questions were included in the RAI. 4
- u.- .o Further evaluation'was performed on all valves in the program to determine whether the~ identified testing could practically and. safely be i conducted as. described. If the licensee's ability to perform the. testing was in doubt,'a question was formulated to alert the licensee to the- l
. suspected problem.
- Once all of the components in the licensee's IST program had been .;
identified on the P&lDs and evaluated as described above, the P& ids were i examined closely by at least two trained and experienced reviewers to ! identify any additional pumps or valves that may perform a safety function. The licensee was asked to reconcile any-component's' identified by this process which were not included in the !ST program.- Also, the list of; l systems included in the licensee's program was compared to a system list in the Draft Regulatory Guide and Value/ Impact Statement titled,
. " Identification of Valves for Inclusion in Inservice Testing Programs."
Systems that appear in the Draft Regulatory Guide list but not in the-licensee's program were evaluated, and if appropriate, questions were added ; to the RAI. I Additionally, if the reviewers suspected a specific or a' general aspect '! of the licensee's IST program, questions were included in the RAI to clarify those areas of doubt. Some questions were included to allow the reviewers' '!
.to make' conclusive statements in the RAI.
At the completion of the review, the RAI was transmitted to the j
. licensee. 'These questions were later used as the-agenda.for the working-meeting'with the' licensee'on March 29 and 30, 1988. At the meeting, each question and comment wts discussed in detail and resolved as follows: ,
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- 1. The licensee agreed to make the necessary IST Program corrections or changes to' satisfy the concerns of the NRC and their reviewers.
- 2. The licensee provided additional information or clarification about their IST Program which satisfied the concerns of the NRC and.their reviewers. Therefore a program change is not required. Li 5
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, 3. !The item remained open for_ the licensee to further investigate and'.
. propose;a solution to.the NRC.
- 4. Th'e item remained open for further investigation by!the NRC.
- 5. -The' item remained open for further investigation and discussion by-both the NRC and the licensee. l A revised IST program dated September 30, 1988 was received an'd compared to the previous submittal to identify any changes. A~ revision to ;
Pump Relief Request P-1 was also submitted by the licensee by letter dated
~ February 22, 1989, The licensee provided further clarification for relief j requests P 12, V-5, V 30, V-37, V-38, and V-39, and withdrew relief requests V-23 and V-33, in a letter dated January 17, 1990. The changes and additions were. evaluated to determine whether they were acceptable. I f.. not , !
they were added to the open. items that remained from the meeting.
~ This-TER is based on information contained'in the submittals, and on
. information obtained either-in the meeting or conference calls which took place during.the review process, or contained in the.lST program submittals.
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- 3. PUMP TESTING PROGRAM a
,The IST Program submitted by Virginia Electric and Power Company for~
the Surry Power Station Units 1 and 2, was examined to verify that.all pumps . that are included in the pr.ogram are subjected to the periodic tests required by-t'he ASME Code, Section XI, except for those pumps identified below for which specific relief from testing has been requested and >
- summarized in Appendix C. Each Virginia Electric and Power Company basis i for requesting relief from the pump testing requirements and the reviewer's evaluation of that request are summarized below. <
3.1 General Relief Rea d
-3.1.1 Bearina Temoerature and Pumo Vibration Measurements 3.l.1.1 Relief Reauest. The licensee has requested relief.from the-bearing temperature and vibration amplitude measurement requirements of Section XI, Paragraphs IWP 4300 and 4500, respectively. The licensee.has proposed to measure pump vibration velocity per ANSI /ASME, OM 61988, except that a minimum reference value of 0.05 in/sec will be applied to all
'valocity measurements. !
3.1.1.1.1 Licensee's Basis for Relief--Pump vibration and bearing temperature measurements are used to detect changes in the mechanical .; characteristics of a-pump. Regular testing.should detect developing L problems, thus repairs can be initiated prior to a pump becoming inoperable. The ASME Sect.on XI minimum standards require measurements of L ,- the vibration amplitude displacement in mils every three months and bearing
. temperatures once a year. -
g Our proposed program is based on vibration readings in velocity units j lT rather than vibration amplitude in mils displacement. This technique is an [ industry accepted method which is more sensitive to small changes that are
< indicative of developing mechanical problems and hence more meaningful.
i l. j, Velocity measurements detect not only high amplitude vibrations that l: . indicate a major mechanical problem, but also the equally harmful low 1: 7 s 4+ --
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4 amplitude high frequency vibrationsidue to misalignment in balance,' or .
; bearing wear that usual _ly go' undetected by simple displacement. measurements.
In! addition, these readings go far beyond'the capabilities of a bearing , temperature monitoring program. A bearing will be seriously degraded prior 'T , to the detect' ion'of increased heat at'the bearing houP nt. Quarterly , vibration velocity readings'should achieve a much Fig > robability of ,
-detecting developing problems than the once per y w reWi m .1 bearing.
L temperatures. Boaring temperature tests present problems which include the following:
.1. Certain systems have no recirculation test loops and a limited I source of water. - 'An enforced thirty minute run time would deplete the source, i L 1 t
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- 2. The lubrication fluid for some pumps is taken from the process
, ' water,, which can change temperature depending on ambient conditions.
Data trending for these cases is not meaningful. Therefore, the detection of possible bearing failure by a ' yearly L temperature measurement is extremely unlikely. The small probability of -
. detection' of a bearing -failure by. temperature measurement does not justify-the additional pump: operating time required to obtain the measurements. 'In-addition, it-is impractical to measure bearing temperatures on many pumps. ,
i . Pump vibration measurements will be t' ken in vibration velocity. ' (in/sec). The evaluation of the readings will be per.the attached table. The-ranges of test parameters given in the attached table were taken from ! ANSI /ASME OM-61988, an American. National Standard In-service Testing of l [ Pumps. l l L 8
i ci ! ,,$: 3 l Ranaes of Test Parameters (1) l
. Pump Pump 1 Test Acceptable- . Alert Required :
Tvoe^ Soeed' Parameter Ranoe Ranae Action Ranae . LCentrifugal- <600 rpm Vd 2.5V r >2.5Vp to >6Vp but=not and-Vertical 6V >22 mils'
- Line Shaft. >l5.butnot 5 mi1s
>600 rpm V y 2.5V p >2.5Vp to-
.>6V but not 6V7 but not- >0.f0in/sec
>0.325in/sec-Reciprocating .Vd or 2.5V r >2.5V r to >6V 7 Vy 6V p Note: -(1) V is the vibration reference value in the selected units V is vibration displacement measured peak-to-peak,' unfiltered V is vibration velocity measured. peak, unfiltered '
(2) S all values of V .will produce small acceptable ranges for r pump operation, based on a small acceptable range, an adequately and smoothly running pump could be subject to : corrective action. To avoid this situation, a minimurn value for Vr of.0.05 in/sec has been established for velocity .
. measurements. Pumps with a measured reference velue below 0.05 '[
in/sec shall have subsequent test' results compared to an' t acceptable range based on 0.05 in/sec. , 3.1.1i1.2 Evaluation--For pumps which are not' equipped with
. bearing temperature instrumentation, the required measurements must be.taken ;
L on the bearing housing or major modifications must be made to install [ h instrumentation. Equipment modifications to install bearing temperature 7
. instrumentation would be burdensome forithe licensee due to the cost ,
involved. There are several factors that would affect the-temperature
-measured at the bearing-housing which could mask a change in the bearing ,
k condition (short of catastrophic failure) such as the temperature of the L working fluid, ambient room temperature, and lubricant temperature. Further, many pumps have a limited-capacity source which makes it J impractical-to run the pumps long enough for bearing temperatures to stabilize. L The use of pump vibration velocity can provide a great deal of L'* information about pump mechanical condition that could not be obtained using L
' vibration: displacement readings or by measuring the temperature of the L bearing. housing; Pump bearing degradation results in increased bearing.
L noise at frequencies 10 to 100 times the rotational speed of the pump. ! l-9
These high frequency bearing noises would result in relatively large changes in pump vibration velocity measurementst whereas, vibration displacement and bearing housing temperature measurements may not change significantly. An alternative acceptable to the staff is that relief may be granted from the annual. pump bearing temperature measurement requirements of the Code provided the licensee performs quarterly vibration velocity testing on the affected pumps in accordance with the guidelines of ANSI /ASME OM 6. Tha t licensee has proposed assigning a minimum reference va'ue of 0.05 in/sec. This value of vibration velocity, with pump speeds greater than 600 rpm, is indicative of a pump in excellent operating condition. Values of pump vibration velocity which are 2.5 times higher than thir reference value is ; representative of a pump which is still in good operating condition. Values of vibration ve'ucity at 2.5 to 6 times higher than this minimum reference value appear to be reasonable for establishing the alert range of operation for smoothly running pumps. This issue is being considered by the ASME O&M ' Working Group on Pumps. It is expected that, within two or three years, a l permanent change will'be made to OM 6 to address this issue. Therefore, the ! proposed alternative may be used for a period of three years. Before the i end of this period, this relief request must either be modified to reflect the Code changas on this issue or be withdrawn. I l Based on the determination that the licensee's proposed alternative would provide an acceptable level of quality and safety, interim relief may i be granted for a period of three years. ! 3.2 Centrifuaal Charaina Pumos l 3.2.1 Measurement of Test Ouantities 3.2.1.1 Relitf~4eauest. The licensee has requested relief from the requirements of Section XI, Paragraph IWP-3100, that inlet pressure, ' differential pressure, and flowrate be measured or observed for the chemical and volume control system pumps 1(2)-CH-P-1A, .1B, and IC. The licensee has l oroposed to observe the volume control tank pressure and to install the instrumentation necessary to meet Code requirements during the next refueling outage. l l 10
j i 3.2.1.1.1 Licensee's Basis for Relief Suction pressure i instrumentation is not installed nor required, therefore differential l pressure can not be calculated. These pumps are capable of producing l greater than 2400 psig discharge pressure, while the suction pressure is ! normally 20 psig. Therefore, differential pressure developed by the pump is j more than 100 times the suction pressure and a gauge for suction pressure l would not provide significant data. Therefore, we propose to observe volume control tank pressure using control room indication to assure repeated I initial conditions for pump testing. A design change has been initiated for inlet pressure instrumentation, which will allow for the calculation of i differential pressure, and flow instrumentation. The instrumentation is scheduled for installation during the next refueling outage. 3.2.1.1.2 Evaluation--The volume control tank is the normal
, suction source for these pumps. The static pressurr at the suction of the ;
centrifugal charging pumps will be equal to the pressure of the' volume control tank plus the pressure due to tne height of the tank fluid level , above the pump suction. . Therefore, observing the pressure of the volume. control tank will assure consistent initial conditions and adequate net ! positive suction head for these pumps. l, f Differential pressure and flow are not currently measured by the 'l licensee during pump testing because the system is not equipped with the [ necessary instrumentation. The measurement of these test quantities - requires a design change to the system. The licensee has committed to the + installation of suction pressure and flow instrumentation during the next refueling outage. Because the normal discharge pressure is over 100 times ' greater than the normal suction pressure, and the suction pressure is essentially constant, monitoring discharge pressure during pump testing L would provide a reasonable indication of the differential pressure developed l l- by the pump. Therefore, the evaluation of discharge pressure during pump
- l testing would provide _some indication of the hydraulic performance of these pumps and should provide reasonable assurance of operational readiness until '
L the instrumentation necessary to comply with the Code requirements is installed at the next refueling outage. A grace period for the installation of suction pressure and flow instrumentation is necessary to allow the i l 11
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licensee time to complete design changes, work packages, and procurement. l Imposition of immediate compliance would result in a long outage which would l be burdensome for the licensee due to the cost involved. l h Based on.the determination that the Code requirements are impractical, ! and considering the burden on the licensee if Code requirements were , imposed, relief may be granted provided instrumentation necessary for the ! measurement of differential pressure and flow rate is installed during the { next refueling outage.- 3.3 Boric Acid Transfer Pumos 3.3.1 Measurement of Test Ouantities 3.3.1.1 Relief Reauest. The licensee has requested relief from the reouirements of Section XI, Paragraph IWP 3100, that inlet pressure, differential pressure, flowrate, and vibration be measured or observed for the chemical and volume control system pumps 1 CH P 2A, 2B, 2C, and 20. The licensee has proposed observing the boric acid storage tank level in lieu of
-measuring pump inlet pressure, and installing the instrumentation necessary to meet Code requirements during the next refueling outage.
3.3.1.1.1 Licensee's Basis for Relief -No instrumentation .is installed for inlet pressure, differential pressure, and flow. The pumps are totally encased in insulation. Therefore, probes for vibration cannot be placed in contact with the pumps for a reading. These pumps take suction from the boric acid storage tanks. Tank level will be observed to establish initial conditions of testing, therefore, inlet pressure will not be measured. ~ No flow rate measurement device is currently installed. A design change has been initiated for inlet pressure, flow, and vibration instrumentation. Installation of inlet pressure instrumentation will allow for the calculation of differential pressure. The instrumentation is scheduled for installation during the next refueling outage. 3.3.1.1.2 Evaluation--The boric acid storage tank is the normal l suction source for these pumps. The test loor returns the fluid being pumped to the boric acid storage tank. The static pressure at the suction 12 i
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of the pumps will be equal to the pressure due to the height of the tank fluid level above the pump suction. Therefore, observing the level of the liquid in the volume control tank will assure consistent initial conditions and adequate net positive suction head for these pumps. > E Differential pressure, flow, and vibration are not currently measured ! by the licensee during pump testing. The measurement of these test { quantities requires a design change to the system. The licensee has committed to the design changes and instrumentation installation necessary [ to meet the Code requirements during the next refueling outage. The pumps -* take suction from, and discharge to, the same tank during pump testing. Therefore, the tank level and the pump suction pressure will remain constant and monitoring discharge pressure during pump testing would provide a reasonable indication of the differential pressure developed by the pump.
. The evaluation of discharge pressure during pump testing would provide some indication of the hydraulic performance of these pumps and should provide !
reasonable assurance of operational readiness until the instrumentation
- necessary to comply with the Code requirements is installed at the next refueling outage. A grace period for the installation of suction pressure and flow instrumentation is necessary to allow the licensee time'to complete l design changes, work packages, and procurement. Imposition of immediate ;
compliance would result in a long outage which would be burdensome for the - licensee due to the cost involved. i Based on the determination that the Code requirements are impractical, and considering the burden on the licensee if Code requirements were l imposed, relief may be granted provided the design changes and L instrumentation installation necessary for the measurement of differential pressure, flow rate, and vibration are completed during the next refueling , outage. , l 3.4 Low Head Safety In_iection Pumos 3.4.1 Measurement of Test Ouantities 3.4.1.1 Relief Recuest. The licensee has requested relief from the requirements of Section XI, Paragraph IWP 3100, that inlet pressure and 13
.-. . . - - --.-.-.-y_-
differential pressure be measured or observed for the safety injection system pumps 1(2)-SI P 1A and 18. The licensee has proposed monitoring the refueling water storage tank (RWST) level in lieu of measuring nump inlet pressure, and installing the instrumentation necessary to meet Code requirements .during the next refueling outage. 3.4.1.1.1 Licensee's Basis for Relief.. Inlet and differential pressure instrumentation are not installed. These pumps take suction from I the RWST for performance testing. The tank level has a minimum requirement , by Technical Specifications which will insure initial conditions for testing. A design change has been initiated for inlet pressure ! instrumentation,.which will allow for the calculation of differential pressure. The instrumentation is scheduled for installation during the next refueling outage, j 3 . 4.1.'1. 2 Evaluation The refueling water storage tank is the suction source for these pumps during pump testing. The static pressure at 7 the suction of the pumps will be equal to the pressure due to the height of ! the tank fluid level above the pump suction. Therefore, observing.the level of the liquid in the volume control tank will assure consistent initial conditions and adequate net positive suction head for these pumps. Differential pressure is not currently measured by the licensee during j pump testing. The measurement of this test quantity requires a design change to the system. The licensee has committed to the installation of the instrumentation necessary to meet the Code requirements during the next refueling outage. Flow rate is measured during pump testing. The evaluation of flow rate during pump testing would provide some indication of the hydraulic performance of these pumps and should provide reasonable f assurance'of operational readiness until.the instrumentation necessary to comply with the Code requirements is installed at the next refueling outage. A grace period for the installation of suction pressure and flow. instrumentation is necessary to allow the licensee time to complete design changes, work packages, and procurement. Imposition of immediate compliance would result in a long outage which would be burdensome for the licensee due L- to the cost involved. I p 14
~
l lc ~. Based on the determination that the Code requirements are impractical, and considering the burden on the licensee if Code requirements were I imposed, relief may be granted provided instrumentation necessary for the i measurement of differential pressure is installed during the next refueling outage. 3.5 Recirculation Soray Pumos 3.5.1 Measurement of Test Ouantities 3.5.1.1 Relief Recueil. The licensee has requested relief from the requirements of Section XI, Paragraph IWP 3100, that inlet pressure and differential pressure be measured or observed for the outside recirculation-spray system pumps 1(2) RS P 2A, and 2B, The licensee has proposed
, installing the instrumentation necessary to meet Code requirements during the next refueling outage.
3.5.1.1.1 Licensee's Basis for Relief Suction pressure instrumentation is not installed, therefore differential pressure cannot be calculated. Suction pressure is the same for each test since the suction pressure is only the head of water in the filled pump casing. A design change has been initiated for inlet instrumentation, which will allow for the calculation of differential pressure. The instrumentation is scheduled for instc11ation during the next refueling outage. 3.5.1.1.2 Evaluation- These pumps take suction directly from individual reservoirs. In an accident situation, these reservoirs are filled from the containment sump. During pump testing the test loop recirculates water from the reservoir. The required suction pressure for these pumps is provided by the head of the water in the filled pump casing. However, measurement of suction pressure is required for the calculation of differential pressure. Differential pressure is not curechtly measured by the licensee during
-pump testing. The measurement of this test quantity requires a design change to the system. The licensee has committed to the installation of the j i
15
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necessary instrumentation during the next refueling outage. Flow rate is 1 measured during pump testing. The evaluation of flow rate during pump j testing would provide some indication of the hydraulic performance of these h pumps and should provide reasonable assurance of operational readiness until ! the instrumentation necessary to comply with the Code requirements is installed at the next refueling outage. A grace period for the installation i of suction pressure and flow instrumentation is necessary to allow the licensee time to complete design changes, work packages, and procurement. i imposition of immediate compliance would result in a long outage which would i be burdensome for the licensee due to the cost involved. . Based on the determination that the Code requirements are impractical, and considering the burden on the licensee if Code requirements were imposed, relief may be granted provided instrumentation necessary for the measurement of differential pressure is installed during the next refueling I outage. l J 3.5.2 Frecuency of Inservice Tests 3.5.2.1 Relief Reauest. The licensee has requested relief from the I quarterly testing requirements of Section XI, Paragraph IWP 3400, for the 1 inside recirculation spray pumps 1(2) RS P 1A and 18. The licensee has i proposed a dry run of these pumps quarterly to verify operability and a I complete flow test at a refueling outage frequency. l 3.5.2.1.1 Licensee's Basis for Relief -These pumps are located ! inside containment, therefore, flow testing cannot be performed during plant I operation. Flow testing of these pumps requires the installation of a temporary recirculation line and the erection of a temporary dike to contain recirculated water. Approximately five to six days are needed to set'up, i perform the test, and return the system to its normal configuration, j Testing on a cold shutdown frequency would not allow enough time to plan for and perform a five to six day flow test. These pumps will be run dry to )l verify operability every quarter. Each pump is equipped with a sensor to l detect pump rotation which alarms in the control room. This alarm will be l observed during each pump test. Each pump is equipped with a vibration i i 16
i detector and a high vibration alarm in the control room. This alarm will be ! observed during each pump test. A flow test which includes vibration measurement will be performed every reactor refueling, , 3.5.2.1.2 Evaluati.o.n These pumps are located inside the reactor : containment' and are not accessible during reactor operation. To prevent i spraying down the containment, a temporary recirculation line must be , installed and a dike erected to contain the water needed for pump testing.
-The planning and performance of this testing is a lengthy evolution. Since !
most unplanned outages are short in duration, performing this testing at a cold shutdown frequency would be a significant burden on the licensee. ! Considering that performing this testing during cold shutdowns could preclude less time consuming testing for a number of ot?sr safety related components and the infrequent occurance of cold shutdowns of long duration,
. the extra expense and manpower requirements would not yield a significant.
increase in assurance of operational readiness. A dry run c.c terly to a l verify operability combined with flow testing to Code requit ,ments at a refueling outage frequency would provide reasonable assurance of operational ! readiness. < Based on the determination that the Code requirements are impractical, that the proposed testing provides reasonable assurance of operational readiness, and considering the burden on the licensee if Code requirements ! were imposed, relief may be granted as requested. - 3.6 -Auxiliary Feedwater Pumos 3.6.1 Measurement of Test Ouantitiet 3.6.1.1 Relief Recuest.. The licensee has requested relief from the requirements of Section XI, Paragraph IMPe3100 that flow be measured or observed for the auxiliary feedwater system p a s 1(2) FW P 2, 3A, and 38. The licensee has proposed installing the instrumentation necessary to meet Code requirements during the next refueling outage. 17
m ,_ , o l' 3.6.1.1.1 tieensee's Basis for ReliefuFlow instrumentation is not installed. A design change has been initiated to install larger recirculation' lines with flow and pressure instrumentation. Installation is scheduled for the next refueling outage. 3.6'.1.1.2 Evaluation -Flow is not currently measured by the licensee during the testing of these pumps because no instrumentation is installed in the system. A design change is required to enable the licensee
, to comply with Code requirements. The licensee has committed to the installation of flow instrumentation during the next refueling outage. All other required parameters are measured and analyzed.during quarterly pump testing. The evaluation of differential pressure during pump testing would provide-some indication of the hydraulic performance of these pumps and should provide reasonable assurance of operational readiness until the
. instrumentation necessary to comply with the Code requirements-is installed during the next refueling outage. A grace period for the installation of suction pressure and flow instrumentation is necessary to allow the licensee -
time to complete design changes, work packages, and procurement, imposition of immediate compliance would result in a long outage wnich would be burdensome for the licensee due to the cost involved. Based on the determination that the Code requirements are impractical, ; that the proposed testing provides reasonable assura- e of operational readiness, and considering the burden on the lice',- ~f Code requirements were imposed, relief may be granted provided instrt .ation necessary for the measurement of flow is installed during the next refueling outage. 3.7 Residual Heat Removal Pumos 3.7.1 Freouancy of Inservice Tests 3.7.1.1 Relief Reauest. The licensee has requested relief from the quarterly testing requirements of Section XI, Paragraph IWP 3400 for the residual heat removal (RHR) pumps 1(2) RH P 1A and 18. The licensee has proposed that these pumps be tested during each cold shutdown, but not more frequently than every three months. 3 18
o l
< t 3.7.1.1.1 Licensee's Basis for Relief -The low pressure RHR pumps
-take suction from and discharge to the reactor coolant system which operates f
at 2235 psig. . This is well above the operat'ng pressure of the RHR pumps. Therefore, testing during normal operation is not possible. These pumps will be tested each cold shutdown (but not more frequently than every three months). { i recirculat for um requ r s s etion rom he r a tor. coolant system. The RHR system is a low pressure system and the motor ' operated suction valves cannot be opened when the reactor coolant system is at normal operating pressure. Therefore, the Code required testing cannot - be accomplished during normal plant operation without a significant modifications to the RHR system, such as the addition of an instrumented' !
- test loop, which would allow full or substantial flow, and an alternate l suction source for use during pump testing. These modifications would be burdensome for the licensee due to the cost involved. The licensee's
- proposal to test these pumps during cold shutdowns should provide reasonable ,
assurance of operational readiness. j Based on the determination that the Code required testing is ' 4 impractical, that the proposed testing provides reasonable assurance of l operational readiness, and considering the burden on the licensee if Code ; requirements were imposed, relief may be granted as requested. < 3.8 Service Water Pumos 3.8.1 Measurement of Test Ouantities p 3.8.1.1 Relief Reauest. -The licensee has requested relief from the requirements of Section XI, Paragraph IWP 3100 that inlet pressure,
- differential pressure,. and flow be measured or observed for the service water system pumps 1 SW-P 1A, IB, and 10. The licensee has proposed that '
discharge water be observed to impact the discharge canal in relation to a fixed reference point, that inlet pressure be calculated from the river level, and that the instrumentation necessary to meet Code requirements be installed during the next refueling outage. r 19
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l l 3.8.1.1.1 Licensee's Basis for Relief No installed inlet f pressure, differential pressure, or flow instrumentation exists. A crude ! flow test is performed by observing where the discharge water impacts in the ! canal in relation to a fixed reference point. Vibration is measured. A ; design change has been initiated for discharge pressure and flow rate. Inlet pressur'e will be calculated from the river level. The instrumentation ; ! is scheduled for installation during the next refueling outage. i 3.8.1.1.2 Evaluation- The service water system is not equipped j ! with the instrumentation necessary for the measurement of inlet pressure, ! flow rate, or differential pressure. The licensee's proposal to calculate i 4 the pump inlet pressure based on the river water level meets the intent of ; L the Code requirements provided the accuracy of this technique is within the ! limitations of Section XI, Table IWP 4110 1. The current flow test, while l
. crude, does provide a relative indication of pump hydraulic performance. In 1 combination with vibration testing, this should provide reasonable assurance
'of operational readiness until the instrumentation necessary to comply with the Code requirements can be, installed. A' design change is required to enable the licensee to comply with Code requirements for pump flow rate and l differential pressure. The licensee has committed to the installation of flow and pressure instrumentation during the next refueling outage. A grace period for the installation of pressure and flow instrumentation is necessary to allow the licensee time to complete design changes, work packages, and procurement. Imposition of immediate compliance would result in a long outage which would be burdensome for the licensee due to the cost involved.
l 1- Based on the determination that the Code requirements are impractical, and considering the burden on the licensee if Code requirements were i imposed, relief may be granted provided instrumentation necessary for the measurement of flow and differential pressure is installed during the next
-' *1tng outage.
L L l 20 t . Lu
J 3.9 Diesel Fuel Oil Pumos 3.9.1 Me_asurement of Test Ouantities 3.9.1.1 Relief Reauest. The licensee has requested relief from the requirements of Section XI, Paragraph IWP 3100 that inlet pressure, differential pressure, and flow be measured or observed for the diesel fuel oil system pumps 1-EE P 1A, IB, IC, 10, IE, and IF. The licensee has. proposed that the pumps be tested monthly to ensure fuel oil is flowing to the day tank when the pumps are running, and that the instrumentation necessary to meet Code requirements be installed during the next refueling outage. 3.9.1.1.1 Licensee's Basis for Relief -No instrumentation is
, installed for inlet pressure, differential pressure, or flow rate. These pumps will be tested monthly by observing that the pumps perform their intended function (fuel oil is flowing to the day tank when the pumps are running). A design change has been initiated for inlet pressure, discharge pressure, flow rate, and vibration. The instrumentation is scheduled for installation during the next refueling outage.
3.9.1.1.2 Evaluation Flow rate, inlet pressure, and differential-pressure are not currently measured by-the licensee during the testing of these pumps because the necessary instrumentation is not installed in the system. The licensee's current diesel fual oil day tank level system is not sufficiently accurate to allow a meaningful calculation of pump flowrate. During a conference call held on November 21, 1989, and in a letter dated January 17,1990, the licensee proposed verifying that the capacity of the diesel fuel oil pumps is greater than the rate of fuel oil use by the diesels during emergency diesel generator testing. A design change is required to enable the installation of the flow and pressure instrumentation necessary for compliance with the Code requirements. The licensee has committed to the' installation of flow and pressure instrumentation during the next refueling outage. A grace period for the installation of pressure and flow instrumentation is necessary to allow the licensee time to complete design changes, work packages, and procurement. Imposition of immediate 21 l l
i O ' compliance woul,d result in a long outage which would be burdensome for the
. licensee due to the cost involved.
Based on the determination that the Code requirements are impractical.
- and considering the burden on the licensee if Code requirements were imposed, relief may be granted provided instrumentation necessary for the measurement of flow and differential pressure is installed during the next refueling outage.
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4.0 VALVE TESTING PROGRAM . The Surry Power Station, Units 1 and 2, IST program submitted by l Virginia Power and Electric Company was examined to verify that all valves i that are included in the p ogram are subjected to the periodic tests required by the ASME Code, Section XI, 1980 Edition through Winter 1980 Addenda, and.the NRC positions and guidelines. The reviewers-found that, except as noted in Appendix C or where specific relief from testing has been requested, these valves are tested to the Code requirements and the NRC positions and guidelines. Each Virginia Power and Electric Company basis for requesting relief from the valve testing requirements and the reviewer's ! evaluation of that request are summarized below and grouped according to system and valve category. 4.1 General Relief Reauests 4.1.1 Leak Rate Testina Reactor Coolant System Boundary isolation Valves 4.1.1.1 Relief Reauest. The licensee has requested relief from the analysis of leakage rates and corrective action requirements of Section XI, Paragraphs !WV 3426-and 3427, for the Category A and A/C valves listed in Table 1. The licensee has proposed that these valves be leak rate tested in accordance with Technical Specification Section 3.1.C and 4.3, and Section XI, Subsection !WB 5000. 1 4.1.1.1.1 Licensee's Basis for Relief- These valves are , adequately leak tested in accordance with Technical Specification Sections 3.1.C and 4.3 and ASME Section XI, Subsection !WB 5000. These valves will be. leak tested in accordance with Technical Specification Sections 3.1.C and 4.3 and ASME Section XI, Subsection !WB 5000. Article IWV 3421 states, " Category A valves shall be leak tested except .
, that valves which function in the course of plant operation in a manner that I demonstrates functionally adequate seat tightness need not be leak tested.
in such cases, the valve record shall provide the basis for the conclusion that operational observations constitute satisfactory demonstration." , 23
Table 1. Listino of Reactor Coolant System Boundary Isolation Valves Valve Function 1-RC HCV-1556A, B, C Loop fill boundary valves 2 RC HCV 2556A, B, C 1(2)-51-107,109 Accumulator discharge check valves 1 2)-S1 128, 130 1 2) SI 145, 147 1(2)-SI 88, 91 Combined safety injection check valves to the 1(2)-SI 94, 238 reactor coolant system hot legs 1(2)-SI-239,240 1(2) 51 235, 236, 237 High head safety injection check valves to the reactor coolant system cold legs. 1 RH-MOV-1700, 1701 Residual heat removal system suction from the 2 RH MOV-2700, 2701 reactor coolant system 1 RH MOV-1720A, 17208 Residual heat removal system discharge to the 2 RH-MOV-2720A, 2720B reactor coolant system 4 s 24
i The intent of this relief request is not to identify valves which cannot be leak tested per Section XI, but to present valves which are part I of a leakage detection system that constantly monitors the leakage integrity { of the reactor coolant system (RCS) boundary and thus " demonstrates adequate I seat tightness" for these valvet. The RCS boundary is limited to 1 gpm of f unidentified' leakage and 10 gpm of identified leakage as required by { Technical Specification 3.1.C. i RCS leakage is calculated every day. Several paratheters are used to determine leakage including: increased charging flow required to maintain normal level in the pressurizer, increasing level in the safety injection accumulators and, increasing level in the pressurizer relief tank. j 4.1.1.1.2 Evaluation- These valves are reactor coolant system l boundary isolation valves. Most of these valves interface with low pressure systems, or systems of which portions are low prassure (i.e. - safety J injection accumulators, residual heat removal, safety injection system pump -l suction piping). The failure of these valves could result in a loss of ' coolant accident. The licensee has classified these valves as reactor coolant leakage (RCt.) valves and, as such, proposed testing these valves in l l accordance with Technical Specifications 3.1.C and 4.3 and Section XI, Subsection IWB 5000. The test connections necessary to individually leak rate test these valves are not installed in the system. The licensee has stated that Technical Specification reouirements and the requirements of. ! Substetion IWB-5000 demonstrate adequate seat tightness for these valves. ,l However, since most of these valves are paired in series, the licensee's i proposed testing would not demonstrate the leak tightness of each valve as required by the Code. The leak tight integrity of the second valve in the pair cannot be verified unless the first valve has failed or is leaking significantly, therefore, the proposed testing verifies only the leak tight integrity of each pair of valves. Although the Technical Specification > l? requirements mentioned by the licensee do not verify the leak tight integrity of individual valves as required by the Code, system hydrostatic [
- tests and monitoring the total RCS leakage does provide assurance of the leak tight integrity of the valve pairs at the RCS boundary, s
25
i: i il . l The licensee's proposed testing. combined with the Technical ' Specification corrective action requirements for excessive leakage would , provide some assurance of leak tight integrity. On this basis, the licensee I may continue to monitor leakage and perform leak testing in accordance with l their plant. Technical Specifications until the NRR Inter-System Loss of Coolant Accident (ISLOCA) study is completed, and the results analyzed, to l determine if further testing should be required.
)
i 4.1.2 Relief Valve Testina . 4.1.2.1 Relief Raouest. The licensee has requested relief from test procedure requirements of Section XI, Paragraph IWV-3512, for the safety and , relief valves listed in Table 2. The licensee has proposed that the main l steam safety valves be tested in accordance with PTC 25.3 1976, Section 4.091(a)(2), and that all other safety and relief valves be tested in accordance uith Section 4.091(c)(1). 4.1.2.1.1 Licensee's Basis for Relief--These valves will be l tested in accordance with PTC-25.3 1976 Sections 4.091(a)(2) and .) 4.091(c)(1). The main steam safety valves will be tested in accordance with PTC-25.3-1976, Section4.091(a)(2). All other safety and relief valves will { be tested in accordance with Section 4.091(c)(1). 4.1.2.1.2 Evaluation--Section XI, Paragraph IWV-3512, states that safety and relief valve set points shall be tested in accordance with I ASME PTC 25.3-1976, " Safety and Relief Valve Performance Test Codes". . PTC-25.3-1976, Section 4.091(a)(2) is the test method for system testing to ! determine set pressure with calibrated hydraulic or pneumatic-assist I aquipment. PTC-25.3-1976, Section 4.091(c)(1) is the test method for bench - testing to determine set pressure and valve-leakage. Paragraph IWV-3512 - further states that bench testing, or testing in place, with suitable , hydraulic or pneumatic assist equipment is an acceptable method under r
-PTC 25.3-1976. Since the licensee's proposed testing is specifically
- mentioned as being acceptable in the Code, relief is not required.
l 26
+, - - - -- Table 2. Listina' of Relief Valves Valve ~ Function ; l MS-SV 101A, B, C Main steam safety valves 2 MS SV 201A, B, C ! l MS-SV-102A, B, C 2 MS SV-202A .B, C 1 MS SV 103A, B, C 2 MS SV 203A, B, C 1 MS SV 104A, B, C 2 MS-SV 204A, B, C 1 MS SV 105A, B, C 2 MS-SV 205A, B, C 1 CC RV Illa, B Component cooling to fuel pit cooler relief valves 1 CC RV 116A, B, C Reactor coolant pump thermal barrier relief 2 CC RV 216A, B, C valves 1 CC-RV Il8 Component cooling from excess letdown heat 2+CC-RV 218 exchanger relief valves 1-CC RV Il9A, B Component cooling from residual heat removal 2 CC RV 219A, B heat exchanger relief valves 1 CC-RV-122 Component cooling to surge tank relief valve 1 CC RV-123 Component cooling to surge tank vacuum relief valve l' I l CC-RV-124- Component cooling piping relief valves L 2 CC-RV 224-l- 1 RH RV 1721 Residual heat removal system relief valves 2 RH RV 2721 j l 1 RC SV-1551A, B, C Pressurizer safety valves l 2 RC-SV 2551A, B, C ! L. l CH RV-1203 Volume control tank relief valves 2-CH-RV-2203 ;
-1 CH RV 1209 Reactor coolant system letdown relief valves 2 CH RV 2209 l l CH-RV 1382A, B Seal water return line relief valves ,
2-CH RV 2382A, B l l AS RV-1322 Batching tank heating jacket relief valve i 1-SI RV-1845A, B, C Low head safety injection relief valves ; 2-SI-RV 2845A, B, C ! 27 l l
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- i. j Table 2. '(Continued)
Valve' Function
- 1. ,
1 SI-RV 1858A, B, C Accumulator relief valves ; 2 SI RV 2858A, B, C ; l SI RV 1859" Accumulator return to the refueling water : 2-SI RV 2859 storage tank relief valves I 1 GW RV 107 Gas line to waste gas surge drain relief valve j 1 i
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l 4.1.3. Ranid Actino Valves f t 4.1.3.1 Relief Reauest. The licensee has requested relief from the trending requirements of Section XI, Paragraph IWV 3417(a), for the valves ! listed in Table 3. The licensee has proposed that the corrective actions of j IWV 3417(b) be applied whenever the stroke time of these valves exceeds 2 seconds. ! 4.1.3.1.1 Licensee's Basis for Relief These valves have a normal i stroke time of 2 seconds or less, and they are rapid acting valves. ! Whenever the stroke time of these valves exceeds 2 seconds, IWV 3417(b) will be applied, i 4.1.3.1.2 Evaluation -The values of stroke time for fast acting t valves can be greatly affected by operator response, and therefore, may not be indicative of valve performance. A staff approved alternative to the
- Code requirements is that relief from Section XI, Paragraph !WV 3417(a), may be granted for fast acting valves (those valves whose normal stroke time is .
2 seconds or less) provided: a) those valves designated in the IST program as fast acting valves are assigned a maximum limiting stroke time of 2 i seconds, and b) when the limiting value of 2 seconds is exceeded, j corrective action shall be initiated per Section XI, Paragraph IWV 3417(b). Imposing the Code required testing could cause unnecessary maintenance on valves which are not degraded which would be burdensome for the licensee. ' Based on the determination that the Code required testing is impractical, that the proposed testing provides reasonable assurance of operational readiness, and considering the burden on the licensee if code , requirements were imposed, relief may be granted as requested. 4 . l '. 4 Group leak Rate Testino of Containment Isolation Valves ; 4.1.4.1 Relief Recuest. The licensee has requested relief from the analysis of leakage rate requirements of Section XI, Paragraph IWV 3426, for the containment isolation vtives listed in Table 4. The licensee has 29
Table 3. Listino of Rapid Actino Valves Valve Function 1 MS TV 110 Main steam drain to blowdown valve , 2 MS TV 210 , 1 CC TV 107' ' Component cooling isolation from the 2 CC TV 207 reactor coolant pumps ; I l SS TV 103 A, B Residual heat removal system sample valves 2 SS TV 203 A, B l-SS TV-100 A, B Pressurizer liquid space sample valves 2 SS TV 200 A, B ; l-SS TV 101 A, B Pressurizer vapor space sample valves 2 SS TV 201 A, B l SS TV 102 A, B Primary coolant hot leg sample valves 2 SS TV 202 A, B 1 SS TV 104 A, B Pressurizer relief tank gas sample valves 2 SS TV-204 A, B ; l SS TV 106 A, B Primary coolant hot leg sample valves , 2 SS TV 206 A, B .; l-DA TV-100 A, B Reactor containment sump pump discharge 2 DA TV-200 A, B isolations 1 DA TV 103 A, B Post accident sample return line isolations 2 0A TV 203 A, B l VG TV 109 A, B Gas vent header isolations 2-VG TV 209 A, B c l LM TV-100 A H Leakage monitoring system isolations r 2 LM TV-200 A H 1 CV TV 150 A D Cont &lnment vacuum pump suction isolations 2 CV TV 250 A 0 ; l RC PCV 1456 Pressurizer power operated relief valve 2 RC PCV-2456
-1 RC PCV 1455C Pressurizer power operated relief valve 1 2 RC PCV 2455C 1-RC 50V 100A 1, 2 Reactor vessel head vents 2-RC SOV 200A 1, 2 1 RC-SOV-100B 1, 2 2 RC 50V-200B 1, 2 l
i 30
i ljble 3. (Continued) F Valve Function - 1-RC SOV 101A 1, 2 Pressurizer head vents 2 RC SOV 201A 1, 2 1 RC 50V 1018 1, 2 [ 2 RC 50V 2018 1, 2 1 CH TV-1204 Reactor coolant system letdown isolation trip 2 CH TV 2204 valve 1 GW TV 100 107 Suction / discharge line valves to the hydrogen 2 GW TV 200 207 analyzer 1 GW TV 111 A, B Containment grab sample valves 2 GW TV 211 A, B l 80 TV 100 A F Steam generator blowdown isolations 2 BD TV 200 A F 1 RM TV 100 A, B, C Radiation monitor return line isolations 2 RM TV 200 A, B, C i 31 ( i
C
- e proposed that containment _ isolation valves which cannot be tested individually be tested in groups, with leakage limits assigned to the group which are subject to'the acceptance criteria of IWV-3426 and 3427.
4.1.4.1.1 Licensee's Basis for Relief The piping configurations for some containment penetrations do not allow for the individual leakage testing of the containment isolation valves which isolate the penetrations. In cases where containment isolation valves cannot be individually leakage tested the containment isolation valves are grouped based on the configuration restraints and the groups are assigned permissible leakages. The valve groups are subject to the acceptance criteria described in !WV-3426 and 3427. The group leakage criteria are determined by summing the valve diameters l in the group and multiplying the sum by 0.32 SCFH which carresponds to the guideline criterion of 7.5 SCFD per inch of valve diameter given in IWV 3426. Based on this method, the ratios of the smallest valve to the sum of the val'ev diameters for cases where the valve diameters differ are given below. Ratio of-Smallest Valve Diameter Valve Valve Diameter to Sum of Valve Diameters l' l-51-150 1" l-SI M0V 1867C 3" 0.14 1 SI MOV 18670 3" l 1 51 174 1" 0.25 L l-SI MOV 1869A 3" l-l 1-VS MOV 101 8" l VS MOV-100C 36" 0.10 1 VS MOV-1000 36"
- l. '
The ratios given above establish that the smallest diameter valve in a given group provides a significant contribution to the group leakage. We l 32 l I
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L , Table 4. Listino of Containment Isolation Valves.
! Valve Function 1(2)-St150 Boron injection tank isolations l MOV 1867C, 0 2-MOV 2867C, D 1(2)-51-174 High head safety injection to the reactor 1 M0V 1869A coolant system isolations 2 MOV 2869A 1 SI MOV 1860A, B Low head safety injection pump suction , 2 SI MOV-2860A, B isolations from the containment sump 1 CH HCV 1200A, B, C Letdown orifice isolations 2 CH HCV 2200A, B, C 1 IA 466 Backup instrument air containment isolations 2 IA 704 1 IA TV 100 Instrument air containment isolations 2 IA TV 200 1 LM TV 100A, C, E. G Leakage monitoring system isolations 2 LM TV 200A, C, E. G l LM TV-1008, D, F. H 2 LM TV 200B, D, F. H s
1-CS MOV 101A, B, C D Containment spray pump discharge isolations 2 CS M0V 201A, B, C, O l RS MOV 155A, B Recirculation spray pump suction isolations 2 RS MOV 255A, B from the containment sump 1 VS MOV 100Cr 0 Containment purge exhaust isolations. 1 VS MOV 101 2 VS MOV-200C, D 2 VS MOV 201 L l VS MOV-100A, B Containment purge supply isolations o 1 VS M0V 102 2-VS MOV 200A, B 2 VS MOV 202 1(2) RL-3, 5 Reactor cavity purification return line isolations { j l ; l 33
i j believe that these ratios pro.ide reasonable assurance that no valve will be I returned to service with ex:essive leakage. The leak test procedure also has ]
.an administrative leak limit which is based on 0.16 SCFH per inch of valve I diameter, if the leakage exceeds this limit, the valves will be reworked at the discretton of the Type C test coordinator.
4.1.4.1.2 Evaluation -It is not practicable to individually leak test these valves because of the system design and lack of appropriate test taps. The only practical method of verifying the leak-tight integrity of J these valves is to leak rate test the identified valves in groups. For situations where there are multiple containment isolation valves branching from a common header, ascribing all leakage through the penetration to one valve could cause the performance of baseless maintenance on operable valves.; These valves could only be individually leak rate tested after significant redesign of the systems involved. These modifications would be f burdensome for the licensee due to the cost involved. Further, modifications to enable individual leak rate testing, such as piping reconfiguration or the addition of isolation valves, could result in a reduction of safety system - reliability and plant safety. i i 1
- The licensee has-stated that maximum leakage rates will be assigned to each valve group and if'the measured' leakage exceeds the assigned group l limit, corrective actions will be taken as required by Paragraph IWV-3427. 3 This test method should provide reasonable assurance of the leak-tight i integrity of these valves as long as the assigreed limiting leakage rate for
- each valve grouping is conservative considering the number and sizes of valves in the group. The assigned maximum group leakage rates should be based-on-the smallest valve in the group so that corrective actions are taken l whenever the leak tight integrity of any valve of that group is in question.
The licensee's proposed method of determining maximum-leakage rates for- l L valves tested in groups, suming valve diameters in each group and assigning wge rate equal to 7.5 SCFD per inch of total valve a maximum penetration diameter, does not appeo ;o be conservative. Using this methodology, individual valve leakage rates could be many times the leakage limit which 34
I would be appropriata for that valve, based on IWV 3426(b), before corrective ; action is. required. In some valve groups, leakage through the smallest valve { could be a factor of 10 greater than the individual valve leakage limit of j 1WV-3426(b) before corrective action is required. Significant degradation of the smallest valve could go undetected in a group of otherwise leak tight valves. The licensee should reevaluate this criteria in the light of the { service history of these valve groups. The criteria established for these groups should ensure that no valve will become seriously degraded before corrective action is required. Based on the determination that it is impractical to individually leak ! rate test the listed valves, that it would be burdensome to require the licensee to comply with the Code requirements, relief may be granted provided . the licensee reevaluates the group leakage limits based on the diameter of the smallest valve in each group as discussed above. 4.2 Feedwater System 4.2.1 Catecory C Valves 4.2.1.1 Relief Reauest. The licensee has requested relief from the quarterly check valve exercising requirements of Section XI, Paragraph IWV-3521, for the main feedwater containment isolation check valves 1(2)-FW 10,'41, and 72. The licensee has proposed that these valves be' demonstrated operable by disassembly, on a sampling basis, at a refueling-cutage frequency. I 4.2.1.1.1 Licensee's Basis for Relief--Closure of these vt.1ves during power operation would require securing feedwater which would result in L a reactor trip. Cold shutdown _ testing of valves using flow to. verify closure L is inconclusive due to the low differential pressure across the valve disk. L A test was conducted in an effort to verify whether closure of'these valves , can be determined using flow. Because there is no isolation boundary.between the steam generators and the valycs, the test volume must include the steam generators. A steam generator was pressurized with a nitrogen blanket to l
.approximately 5 psig. The 0.75 inch drain valve just upstream of the check I l
35 i l l
valve was opened and flow was observed. The 14 inch check valve did not stop the back flow through the vent. It was concluded that the flow was inadequate to seat the check valve completely. Just a small gap between the disk and the seat was sufficient to create a flow area equal to or greater than the flow area through the drain. Therefore, the pressure differential associated with the back flow is being created across the drain valve and not the disk of the check valve. This test proved to be inconclusive because of the inability to establish a sufficient differential pressure across the disk. The only way to increase the differential pressure is to increase the flow area from the test volume. However, this is not achievable for the existing configuration. Immediately upstream of the drain valve is another 14 inch check valve, so the only available flow area from the test volume is the drain valve. These valves will be grouped together and one valve from this group will be disassembled every refueling. A different valve will be disassembled every reactor refueling. 4.2.1.1'2 Evaluation--The closure of these check valves would require securing feedwater flow to the steam generators. This cannot be done during power operation because it would cause a reactor trip. Using reverse flow or the head of a pressurized steam generator to verify closure capability could only be done during cold shutdowns and refueling outages. However, the licensee cr.ncluded that the drain valves are too small for the differential pressure 1. cross the check valves to be sufficient to fully seat the' valves. Therefore, these motheds of testing are inconc1'usive. The Code required testing could only be perfomed if modifications were made to the system, such as the installation of significantly larger drain valves. These modifications would be burdensome for the licensee due to the cost involved. Based on the detemination that the Code requirements are impractical, and considering the burden on the licensee if Code requirements were imposed, i 36
relief may be granted provided the licensee follows the NRC staff guidance on i disassembly and inspection in Generic t.etter No. 89 04. I 4.2.1.2 Relief Reauest. The licensee has requested relioi' from the i quarterly check valve exercising requirements of Section XI, Paragraph IW 3521, for' the following auxiliary feedwater pump recirculation line and oil cooler check valves. The licensee has proposed that these valves be ; demonstrated operable by disassembly, on a sampling basis, at a refueling j outage frequency, ; l 1(2)-FW-144 1(2) FW 148 1(2)-FW159 1(2) FW 163 1(2)-FW 174 1(2) FW 178 l 4.2.1.2.1 Licensee's Basis for Relief -These check valves cannot be full flow test'ed because instrumentation is not installed to measure flow ; or differential pressure. These valves cannot be partially flow tested ; during' normal operation because the auxiliary feedwater system must be isolated to perform the test. These valves will be grouped together and one l' valve from this group will be disassembled and inspected every reactor refueling. A different ykive will be disassembled every reactor refueling, i These valves will be partial flow tested every cold shutdown. Valves , L ' l(2)-FW 144,159, and 174 will be verified closed every cold shutdown, 4.2.1.2.2 Evaluation -The instrumentation necessary to verify a full-stroke of these check valves with flow is not' installed in the auxiliary feedwater pump recirculation and oil cooler lines. The testing , connections necessary to verify valve closure are not installed in the system. , Full-stroke exercising these check valves with flow could only be performed if flow rate instrumentation were installed in these lines.. These
- modifications would be burdensome for the licensee due to the cost involved. ,
L l The NRC staff position is that valve disassembly and inspection can be used to verify the full stroke capability of check valves when full-stroke exercising with flow is impractical. The NRC staff positions regard h , check valve disassembly and inspection are explained in detail in Generic 37 ; T
Letter No. '8g 04,'" Guidance on Developing Acceptable Inservice Testing
- Programs."-
! Based on the determination that the Code requirements are impractical,-
and considering the burden;on the licensee if Code m quirements were imposed, relief may be granted provided the licensee conforms to the NRC. staff positions on disassembly-and inspection. 4.3 [hemical and Volume Control System 4.3.1 Cateoorv C ' Valves - 4.3.1.1 Relief Reauest. The licensee has-requested relief from the-quarterly check. valve exercising requirements of Section XI, Paragraph
. - IWV-3521, for the charging pump discharge check valves 1(2)'-CH-258, 267, and 276.- The licensee has proposed that these valves be part-stroked 6 quarterly and full flow tested each refueling.
4.3.1.1.1 Licensee's Basis for Relief--With the present' plant design, these velves can only be partial stroke exercised.during power operation and tm snarging pumps cannot achieve design accident flow when _ pump i ng_. it n o ths reactor coolant system at operating pressure. The only available-flow pathito tesi! these valves is into the reactor coolant system. :During cold shutdown,t; stroke-exercising these valves could result inlan overpressurization of the reactor coolant system and could force a' 1 safety. system to. function. These valves will be partially stroked every three; months and full flow tested each refueling. 4.3.1.12 - Evaluation--The demonstration of a full-stroke with
. flow requires the passage of the maximum required accident flow through
-these valves. The only full flow path through these valves .is into the reactor coolant system..xHowever, the charging pumps do not develop sufficient head to pass the required amount of flow into the reactor coolant system whenTthe plant is at. normal operating pressure. The performance of
- this testing during cold shutdowns could cause a low temperature overpressurization of the. reactor coolant system.
t 0 38 4 a
v - - - - . - ,. . -.. - - . r . L ; .; .
~
i These' valves could be full-stroke' exercised with flow at the Code required frequency only'after system modifications, such as addition of a J
,, full flow test loop. This modification would be burdensome for the licensee ,
due to the cost involved. t Based on the determination that the Code required testing is. { impractical, that the proposed testing provides reasonable assurance of + operational readiness, and considering the burden on the licensee if Code , requirements were imposed, relief may be granted as requested. ; i s 4.3.1.2 Relief Reauest. The licensee has requested relief from the quarterly check valve exercising requirements of Section XI, Paragraph ) IWV-3521,'for the charging pump discharge recirculation line check valves-1(2)-CH-256, 265, and 274.- The licensee has proposed that these valves be- i disassembled and inspected on a sampling basis at a refueling outage 1 frequency, and part-stroke exercised quarterly. h H 4.3.1.2.1 Licensee's Basis for Relief -These check valves cannot be full flow tested because instrumentation is not installed to measure' flow . or differential pressure. These valves will be grouped together and one valve from this group will be disassembled and inspected.every reactor E . refueling. A different valve will be disassembled.every reactor refueling. p These valves will be partial flow tested every three months. 4.3.1.2.2 Evaluation--The instrumentation necessary to verify'a l full-stroke of these check valves with flow is not installed in the charging pump recirculation lines. Installation of flow rate instrumentation to verify a full-stroke of these check valves would be burdensome for the licensee due to the cost involved. *
'The NRC staff position is that valve disassembly and inspection can be
-l used to verify the full-stroke capability of check valves when full-stroke- ,
exercising with flow is impractical. The NRC: staff positions regardirg disassembly and inspection are explained in detail in Generic Letter 89-04, o
" Guidance on Developing Acceptable Inservice Testing Programs." i l
39 i
7 qa < me . .
~
^
u -Based on'the determination.that the Code requirements are, impractical.,
?^
;and considering'the: burden on-the licensee if Code requirements were t;
_ imposed, relief may be granted provided the licensee conforms to the'NRC, ; staff-positions on distssembly and inspection. 4.4 Safety Iniection System p' j ', 4.4.1 Cateaory A/C Valves
+
4.4.1.1 Relief Reauest. The licensee has requested relief from the- i quarterly check valve exercising requirements of Section XI, Paragraph-l jl[l , IWV-3521, for the folloving safety injection system accumulator discharge-check valves. The licensee has proposed that one discharge line check valve y be flow tested every refueling outage with a different valve' tested every y Ereactor refueling. ( .l e v -- l 1(2)-SI-107 1(2)-SI-109 1(2)-SI-128 1(2)-SI-130 1(2) SI-145 1(2)-SI-147 7 4< 4.4.1.1.1 Licensee's Basis for Relief--These valves cannot be
? -
-part- or full-stroke' tested during normal operation because the accumulator W pressure (600 to 650 psig) is-below reactor coolant. system (RCS) pressure
( and the injection of borated' water would upset the reactor coolant-chemistry. During cold shutdown, the DCS press'ure still prevents- full flow . testing. One accumulator discharge line will be full flow tested every reactor refueling. During every reactor refueling, a different line will be .
~ tested.- The full flow test will consist of discharging the accumulator from an initial pressure of 100 to 150 psig into a vented reactor coolant -
system. The time-to depressurize from the initial conditions, which will be-held constant for each test, to a final pressure and accumulator level will be compared to a reference discharge time. If test results show an increase in the discharge time greater than the specified limiting discharge time, corrective action will be initiated innediately and the other two accumulator lines will be tested. Analysis has shown that a reduced pressure test will' provide full flow conditions in the check valves. Also, 40
,_ _ _ _ _ _ _ _ - - _ _ _ = _ _
T , W> , 4 i
- the rate of accumulator discharge is directly dependent on the total system resistance, which would increase if.the check valve disks failed to move to
]
the full-open position. These valves are confirmed closed by monitoring-
' [
. seat leakage from each valve.- .The leakage is collected in 'a common header,-
measured, and compared to the criteria in Technical Specification 3.1.C.. 4.4.1.1.2 EvaluatiQS--These valves cannot be part- or full-stroke. -! exercised to the open position quarterly because the head of the safety I injection accumulators'is insufficient to open these valves against reactor : coolant system pressure. Full or substantial flow testing of these check' :i valves requires that the reactor coolant system be depressurized and. vented. In order to perform this testing during cold shutdown, the reactor coolant, pumps and the residual heat removal system must be secured and the , pressurizer cooled down. The residual heat removal system _is required to be in operation to remove decay heat from the reactor core. Reactor coolant a j system chemistry would have to be reestablished within specifications and the reactor coolant pumps must be vented to remove non-condensable gases.- j rt Performance of the Code required testing during cold shutdowns could result in a significant delay in the return to power which would be burdenume for the licensee due to the cost involved. , c-The licensee has proposed that only one set of check valves N aled j every Oueling and that a different set of check valves be tested each h refueling. This would allow the testing 'of each check valve no more than= c L once every three refueling' outages unless failure of. one-valve occurs during 'I this time period. The licensee has neither demonstrated that this testing s frequency would provide reasonable assurance of operational readiness nor I that' it would be burdensome to test all three sets of check valves each ! refueling outage. r , During a conference call with the licensee held on November 21, 1989,
'the licensee stated that they have not developed definitive acceptance criteria for their proposed testing. The licensee is currently working to
,, temonstrate that the proposed testing is capable of detecting valve aegradation, that the results of this test can be extrapolated to deaanstrate a valve's ability to pass design basis flow, and that the #
i 41 7 __z_______._______._________.__.__z________ - . .-. - . . - .
~
acceptance criteria to be adopted would provide reasonable assurance of valve' operationalt readiness. Prior to the start of the next refueling outage, the_ licensee should demonstrate that their proposed testing would provide reasonable assurance of operational readiness or adopt another alt:rriative which meets the criteria of Generic letter No. 89-04, Position 1 or Position 2.
~
a
, 4.4.1.2 Relief Recuett. The licensee has requested relief from the j , quarterly check valve exercising requirements of Section XI, Paragraph IWV-3521, for tho'following safety injection and high head safety injection line' check valves. The licensee has-proposed that these valves be full-stroke exercised open during refueling outages when the reactor vessel head is removed and verified closed by leak testing in accordance with ;
s , Technical Specifications. ' u I Valve Function o- 1(2)-SI-88','91,94,238, Combined safety injection isolation check valves to the RCS hot legs
~
239, 240
'l(2)-SI-235,236,237 High head safety injection isolation check i valves to the RCS cold legs 1 i
1(2)-SI-241,242,243 Low head safety injection isolation check valves to the RCS cold legs !
- 1(2)-SI-79,82,85 Combined safety injection isolation check (
valves to the RCS cold legs
.c '
4.4.1.2.1 Licensee's Basis for Relief--The valves on the high
.' -head injection lines cannot'be part- or full-stroke exercised during power ;
operation because flow through these valves would thermal shock the j '
,r. injection system and cause unnecessary plant transients. Flow cannot be established in the low head-injection lines during power operation. -During cold shutdown, the reactor coolant system pressure still prevents full design flow. Also, a part- or full-stroke test could cause an overpressurization of the reactor coolant system and force a safety system-to function. To verify closure, valves 1(2)-SI-79, 82, 85, 241, 242, and 243 must be ' vented upstreta and a leakage test performed. Per Technical Specification Table 4.1-2A, periodic leakage testing on each valve shall be k
42
.~ ,
.- 1, ,
*i
.}
, accomp1_ished prior to entering power operation condition after every. time f the' plant is placed in.the cold shutdown: condition for 72 hours if testing f has not been' accomplished in the preceding 9 months. 'No significant !
4 increase in safety will be realized by performing the leakage tests every 3 cold shutdown. These valves are full stroke exercised during refueling-outages when-the vessel head is removed. Valves 1(2)-SI-79, 82, 85, 241, { q 242' and 243 will be tested to the closed position per Technical Specification Table 4.1 2A. Valves 1(2)-SI 88, 91,'94, 235, 236, 237, 238, 239,'and 240 are~ confirmed closed by monitoring _-leakage from the reactor
< coolant' system per Technical Specifications 3.1.C and 4.3. Individua1 ' valve I verification to the closed position is not possible with the current line ' '
configurations. u 4.4.1.2.2 Evalbation- The demonstration of a full-stroke to the open position with flow requires the passage of the maximum required accident flow through these valves. The only flow path for exercising these
-valves to the open position with flow bypasses the regenerative heat
- exchanger and would inject cold water into the RCS. During: reactor-operation this would cause pressure. temperature, and reactivity transients d
as well as thermal shock to the safety injection nozzles. Further, the $ safety' injection pumps do not develop sufficient head to overcome reactor ] [ Jcoolant system pressure during normal operation.- During cold shutdowns, '* exercising these valves with flow 'could cause a low temperature i p- overpressurization of the RCS, It is, therefore, impractical to exercise-3
~
0 these valves to the'open position with flow quarterly or during cold shutdowns.. L Valves 1(2)-SI-79, 82, 85, 241, 242, and 243 are simple check valves ! that-do not have position indication. The only practicable way of. verifying = valve closure is by leak testing. These valves'are identified as pressure 1
-boundary isolation valves in the plant Technical Specifications and are leak rate' tested'during cold shutdowns which are 72' hours or greater in length if ,
testing has:not b'een performed in the preceding 9 months. It would be impractical to leak test these valves more frequently than this because ' leak rate testing would render the safety injection system inoperable. Further,
' these valves are located inside the reactor containment and are inaccessible 43
4 , during reactor operation. . The increase in closure verification frequency for-theseEvalves from tho' current Technical Specification frequency to every cold shutdown would not provide a sufficient increase in assurance of- ' i operational readiness to justify the increased burden.
.. Valves =.1(2) .SI 88, 91, 94, 235, 236,'237, 238, 239, and 240 form the l RCS boundary with low pressure systems, or systems 'of which portions are low l pressure. However, these valves are not identified as PIVs in the plant Technical Specifications. The only' feasible method for verifying these- k valves:in the closed position is leak rate testing. However, there are no :
test connections installed in the system to enable leak rate testing of
- these valves. Even if test connections were installed, it would be ,
L impractical .to test these valves quarterly since the valves are -located j inside containment and are inaccessible during reactor operation. Further, leak rate testing during cold shutdowns would require a significant. amount of time for test equipment setup, test performance, and test equipment' L - removal and could result in:a delay in_the return to power. This would be' i '
. burdensome for.the licensee due to the costs involved. The licensee's proposal for leak rate testing these valves is discussed in Section'4.1.1.1 -
of this report. 1
-Based on the determination that it is impractical to full-stroke ;
exercise;these valves to the open position quarterly or during cold j shutdowns, that the proposed testing provides reasonable' assurance of the. ?! l ability of these valves to perform their safety function in the open ! l ' position,;and considering the' burden on the licensee if Code requirements ; were-imposed, relief may be granted, from the Code exercising requirements. y
- for all-valves to the open position.
Basa'd on the determination that it is impractical to leak rate . test , these valves quarterly, and that it would be burdensome to perform this
- testing during cold. shutdowns, relief may be granted from the Code exercising requirements for valves 1(2)-SI-79, 82, 85, 241, 242, and 243 to ,
the closed position provided they are individually leak rate tested. Interim approval. of the licensee's proposed alternative for verifying the closure capability of valves 1(2)-SI-88, 91, 94, 235, 236, 237, 238, 239, ; 44 5 4 .: . a -.
. __ - __ _ . . . _ _ . _ - _ - ~ . - -
7 ,
+ ~and 240 for the leak rate testing requirements of Section XI,--IWV-3420,_is i-M discussed in Section 4.1.1.l' of this report.
-{
'4.4.2 icateaory C Valves 4.4.2.'1' Relief RAnuelt. The licensee has requested relief from the l quarterly' check valve exercising requirements of Section XI, Paragraph IWV-3521, for the following safety injection and high head safety injection [
-line check valves. The licensee has proposed that these valves be j Y full stroke exercised during refueling outages when the reactor vessel head: ,
Lis removed. I - ' i 1 2 SI-224 1 SI 225 1 -SI-226 , 1 2 -SI 227 1 -SI 228 1 -S1-229 ' 4.4.2.1.1 Licensee's Basis for Relief--The valves on the high. head-injection lines cannot be part- or full-stroke exercised during power-operation.because flow through these valves would thermal shock the v injection system and cause unnecessary plant transients. Flow cannot be ! l established in the low head injection lines during power operation. During ; cold shutdown, the reactor coolant system pressure still prevents full 4 design' flow. Also, a part- or full-stroke test could cause an overpressurization of the reactor coolant' system and force a' safety system-to function; These valves are full-stroke exercised during refueling j L . outages when the vessel head is removed. r 4'.4.2.1.2 Evaluation- The demonstration of a full-stroke to the open position with flow requires the passage of the maximum required - accident flow through these. valves. The only flow path for exercising these valves to the open position with flow bypasses the regenerative heat ' exchanger and would inject cold water into the RCS. During reactor >
.' operation, this would cause pressure, temperature,-and reactivity transients o
L- as well as' thermal shock to reactor coolant and :afety injection system L components. Further, the safety injection pumps do_ not develop sufficient head to overcome-reactor coolant system pressure during normal operation. Exercising these valves to the open position during cold shutdowns could c'ause a low temperature overpressurization of the RCS. Therefore, it would 45 , .__i-__----_-_ .
y , ,
~
7 i be impractical to full stroke exercise'these valves to the open position < quarterly or'during cold shutdowns. Testing:at the Code required frequency-could only.be achieved after significant' system modifications, such as the addition of-a full flow test loop, which would be burdensome for the licensee due to the cost involved. Based on the determination that the Code required testing is impractical, that the proposed testing provides reasonable assurance of operational readiness, and considering the burden on the licensee if Code f requirements were imposed, relief may be granted as requested.
/ 4.4.2.2 Relief Recuest.'.The licensee has requested. relief from the quarterly check valve exercisir{ requirements of Section XI, Paragraph IWV-3521, for the low head safety injection pump suction check valves from
.. -the containment sump, l(2)-51-56 and 47. The licensee has proposed that these valves be disassembled and inspected on a sampling basis at a refueling outage frequency.
1 4.4.2.2.1 Licensee's Basis for Relief--To partial or full flow test these valves requires taking suction from the reactor containment sump which contains untreated water. This water should not be introduced-into the system. These valves will; be grouped together and one valve from this group will be, disassembled and inspected every reactor refueling. A-
- different valve will be disassembled every reactor refueling.
4.4.2.2.'2 Evaluation--Full- or part-stroke exercising these valves with flow would cause the addition of non-reactor grade containment
~
sump water into the reactor coolant system, the safety injection system, and the refuelir.g water storage tank. This would cause a loss of chemistry control which could result in increased corrosion rates, increased radiation levels, and reduced plant reliability. The code required testing could only-be' performed after significant system modifications, such as the. addition of a full flow test loop, which would be burdensome for the licensee due to the cost involved. The NRC staff position is that valve disassembly and inspection can be used to verify the full-stroke capability of check valves when full-stroke 46
3 4 3 . a m .. : Q exercising with flow is impracticil. The NRC staff positions regarding [ .
, disassembly and inspection are explained in detail in Generic Letter 89 04, t
" Guidance'on Developing Acceptable Inservice Testing Programs."
}
]f ,
' Based on the determination that the Code requirements are impractical, j '
,' and considering the burden'on the licensee if Code requirements were l imposed,' relief may be granted provided the licensee conforms to the NRC
~
q' staff positions 1 on disassembly'and inspection. q 4.4.2.3 Relief Reauest. The licensee has requested relief from the l
. quarterly check valve exercising nquirements of Section XI, Paragraph 4 IWV-3521, for the low head safety injection pump suction check valves from the refueling water storage tank, 1(2)-SI-46A and 468, and the low head .;
L safety l injection pump discharge check valves,1(2)-S150,1-SI-58, and - t 2 51-327. The' licensee has proposed that these valves be part-stroke
' exercised quarterly,'and full-stroke exercised at a refueling outage , frequency. ,
3 4.4.2.3.1 Licensee's Basis for Relief--These valves cannot be fu11 stroke exercised during plant operation. The only full flow path:is 7 [ into the reactor coolant system (RCS) and low head safety injection pumps cannot overcome RCS operating pressure, , These valves will be partially , stroked every three months through the pump recirculatio'n line. During cold shutdown, the'RCS pressure still prevents full flow testing of the check valves.. During cold shutdown, the charging flow could cause an overpressurization condition. . Testing valves 1(2)-SI-50, 1-51-58, and 2-SI-227 to the closed position ; requires isolating the suction lines to the low head safety injection. ; pumps. This test places the unit into a 1.imiting Condition for Operation L(LCO) per Technical Specification 3.3 if performed during normal operation. ; i These valves will be partially stroked every three months and
' full'-stroked every refueling. Valves 1(2)-SI-50, 1-SI-58, and 2-SI-327 will be tested to the closed position every cold shutdown.
47 ,
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u o 1' e .
. . ?!
a L); j 1 j, , t i
], g -
. '4.4.2.3.2 Evaluation--The demonstration of a full-stroke to the h
-open position.with flow requires the passage of. the maximum required safety- 1 injection system accident flow rate through these' valves. The only full- j
^
flow path for the safety injection system is into the reactor coolant-system.; The. low head safety injection pumps cannot develop sufficient head ) to overcome reactor coolant system pressure during. normal. operation. .During cold shutdown, reactor coolant. system pressure prevents the centrifugalalow ( head safety injection pumps from achieving the required flowrate. Further, the discharge head of these pumps is high enough that performance of this 1
' testing during cold shutdown could result in a low temperature 4 overpressurization of the reactor coolant system. '
j L Based on the determination that the Code required testing.is
, impractical, that.the proposed testing provides reasonable assurance 'of operational readiness, and considering .the burden on the licensee if Code'.
requirements were imposed, relief may be granted to exercise these valves to j open position at a refueling outage frequency. 4.5 Refuelina Water Storaae Tank Crosstie System ;
- l 4.5.1 Cateaory C Valves ~
1 4.5.1.1 Relief Raouest. The licenses has requested relief from the 1 quarterly check valve exercising requirements of Section XI, Paragraph l IWV-3521, for the charging pump suction check valves from the refueling ) water cross-tie, 1(2)-SI-25, 1-SI-410, and 2-SI-400. The licensee has proposed that these valves be part-stroke exercised open at a cold shutdown frequency and full-stroke exercised open at a refueling outage frequency y also, that valve 1(2)-SI-25 be exempt'd e from exercising;to the closed position. l
- 4. 5. I'.1.1 Licensee's Basis for Relief--Exercising these valves l
^ '
.during power operation would require the charging pump suctions to be aligned with the refueling water storage tank (RWST). This would cause a sudden increase in reactor coolant boron inventory. Full flow for the charging' system can only be established during reactor refueling when the 1
48 ; . a
~ , - - .- _ - , , _ .__ _ _ _ _ _ _ __
'L ,-
[s reactor coolant system (RCS) is depressurized.. Valve 1(2)-5125 cannot be adequately-tested to the closed position because the current configuration 7 would require. draining at least one RWST and possibly the other RWST. If the valveldid not backseat the other RWST would drain. This test would place the unit into a Limiting Condition for Operation (LCO).per Technical Specification 3.4. The valve cannot be disassembled because both RWSTs would-have to be drained. These valves will be partial flow tested during every coldishutdown and full flow tested during every reactor refueling. 4 .' 5.1.1. 2 Evaluation--The demonstration of a full-stroke to the - open position with flow requires the passage of the maximum required safety-analysis flow rate through these valves. The only full flow path for this - test is into the reactor coolant system. The high flow rate ' required cannot be achieved during reactor operation without causing pressure and reactivity
- - transients which could cause a reactor trip. The discharge head of these pumps is high enough that performance of this testing during cold shutdown:
could result in:a low temperature overpressurization of the reactor coolant system. This testing.could only be performed at the Code required frequencyz after significant system modifications, .such as the addition of a full-flow-test loop, which would be burdensome-for the licensee due to the cost involved.. Valve l'(2)-SI-25 has a safety function in the closed pos'ition to prevent-diversion of flow when the other RWST is -used as a source-for the high. head safety. injection pumps. :The licensee has' proposed that testing which demonstrates the valves' closure capability not be performed. This is unacceptable. The licensee-has not provided sufficient technical justification for their claim that performance of this testing would require draining one or both-RWSTs. Further, the licensee has. not explained why valves shown in P& ids supplied by the licensee (1(2)-SI-24,'26, TV-102A, B, and 1(2)-CS-25) cannot be shut to enable testing without draining one or both refueling water storage tanks. Based on the determination that the Code requirements are impractical, that the proposed testing provides reasonable assurance.of operational readiness, and considering the burden on the licensee if Code requirements 49
y' : ,
~'
Q l
'll were imposed, relief may be gra'nted as requested for exercising these valves to the open position. However, relief _ should not be granted from the closure verification requirements for valve 1(2)-51-25 since the' licensee- ,
hasLoroposed no alternatives to the Code required testing. ' 9 4.6 - Reactor Coolant System 4.6.1 Cateoorv B Valves 4.6.1.1 Relief Reauest. The licensee has requested relief from the exercising and fail-safe testing requirements of Section XI, Paragraphs IWV-3412 and'3415, respectively, for the following reactor vessel and pressurizer vent valves. The licensee has proposed that this' testing be performed,during cold shutdowns when the reactor coolant system is not: pressurized. 1 RC-50V-100A-1 1-RC-SOV-100A-2 1-RC-SOV-1008-1 1-RC-SOV-100B-2 di
" 1 RC-SOV-101A-1 1-RC-SOV-101A-2 1-RC-SOV-1018-1 1-RC-50V-1018-2
,2-RC-SOV-200A-1 2-RC-SOV-200A-2 2 RC-SOV-2006 1 2-RC-SOV-200B-2 2-RC-SOV-201A 2-RC-SOV-201A-2 2-RC-SOV-2018-1 '2-RC-SOV-2018-2 4.6.1.1.1 Licensee's Basis for Relief--These valves isolate the reactor vessel-and pressurizer from containment atmosphere. Partial or full stroke exercising the valves during normalcoperation or during cold '
shutdowns where the reactor coolant system'is pressurized could result in y the release ~of uncontrolled contamination to theicontainment. These valves ! Lwill-be exercised for operability during cold shutdowns when the reactor- i coolant system is not pressurized (but not more frequently that once per -i
'threemonths)i 4.6.1.1.2 Evaluation--The exercising of these valves during reactor operation or cold. shutdowns when the reactor coolant. system is pressurized, would cause the discharge of reactor coolant water to the l containment environment.. This could result in uncontrolled surface and 7 airborne contamination. Therefore, exercising these valves during cold ,
shutdowns-when:the RCS is depressurized and refueling outages, not to exceed every three months, is a reasonable alterriative to the Code requirements. 50
x , 1 ;. ,=
- TheLsystem! modifications necessary to enable; the performance of the Code required testing quarterly'during power operation.would be burdensome'for / , the licensee due:toithe cost involved.
f 1 Based on the determination that the Code required testing is impractical',Jthat .the proposed te-ting provides reasonable essurance of operational readines's, and considering the burden on the licensee if Code requirements were imposed, relief may be grante'd as requested. 4.7 Main Steam System
~4.7.1 Cateaorv ' C - Valves s
4.751'1 Relief Reouest. The licensee.has requeste'd relief from the
., check' valve exercising requirements of Section.XI, Paragraph IWV-3521, for-the' main steam header supply check valves to the turbine driven; auxiliary.
4 feedwater; pump,1(2) MS-176,178, and 182. - The. licensee has proposed that these valves'be-disassembled and inspected.on a-sampling basis at a-refueling Loutage frequency, and part-stroke exercised quarterly. 1 4.7.1.1.1 Licensee's Basis for Relief--These check. valves cannot 1be exercised to the closed position during normal operation because this
~ test .would ' require the venting of process steam while verifying the closed - M poditioni Venting of process steam would endanger the test personne1~.
M ;These valves will; be grouped together and one valve from this group will' be e ' disassembled and inspected every reactor refueling. .A different valve will
, be' disassembled'every reactor refueling. The valves will be partial flow tested every three maths,
- m. 4.7.1.1.2 Evaluation--Verifying the closure capability of .these valves by leak rate testing requires the-pressurization of the downstream 3 ;y . piping and venting of the upstream piping. Since the upstream piping'is 1, pressurized with high pressure steam during normal operation, this testing could not be done quarterly. Due to the system design a leak test to verify valve closure cannot be done since test lines are not installed to facilitate this testing.
51 a ,
g T i l. L ,
' Based on the-determination-that the Code requirements are impractical, and considering the burden on the licensee-if Code requirements;were imposed relief may be granted'provided the licensee follows the NRC staff guidance-on disassembly and; inspection in Generic Letter No. 89-04.
=
4.8 Diesel Fuel Oil System 4.8.1 Catecory B Valves 4.8.1.1 Relief Reauest.~ The licensee has requested relief from the
. exercising requirements of Section XI, Paragraph IWV-3412, for--the following
- diesel fuel oil pump discharge valves. The licensee has proposed that these valves be tested monthly by observing that fuel oil'is flowing to the day tank after the solenoid' valve has opened.
~1-EE-SOV-100 1-EE-SOV-101 1-EE-SOV-102 1-EE-SOV-103 1-EE-SOV-104 1-EE-SOV-105' 4.8.1.1.1 Licensee's Basis for Relief--These valves are small (1 inch), fast acting solenoid operated gate valves with no position.
indication lights and no local visual means of determining stroke time.
-Valve operability can 'only be; indirectly observed by verifying. system operability. Also, these valvesLare interlocked with the' pumps.to open and close upon pump startup and shutdown. :These solenoid valves will be stroke tested. monthly by observing that the solenoid. valves perform their intended function (fuel oil is flowing to the day tank.after the solenoid valve has beenopened).
4.8.1.1.2 Evaluation--These solenoid operated valves have no control-switches.-or position indication. The valve design is such that valve stem movement cannot be visually verified. Therefore, stroke timing of these valves is not possible. The licensee has proposed that these valves be verified operable by observing that the solenoid valves pass fuel
- oil. During a conference call held on- November 21, 1989, and in a letter
' dated January 17, 1990, the licensee proposed verifying that the capacity of the diesel fuel. oil pumps is greater than the rate of fuel oil use by the diesels during emergency diesel generator testing. This should be 52
-J
_ sufficient to provide reasonable assurance of operational readiness until flow rate, instrumentation can beLinstalled. The licensee has comitted to :) j
~
the installation of flow rate instrumentation during-the next refuelingL
, Loutage. This instrumentation will enable the licensee to positively v'erify 1 that'all valves are' performing their intended design function. '
A grace period for the installation of flow instrumentation is I necessary to allow the licensee time to complete design changes, work ; packages, and procurement. Imposition of imediate compliance would result-
'in a long outage which would be burdensome for the licensee due to the cost '
s n involved. l t Based on the determination that the Code requirements are impractical,. . L q and considering the burden on the' licensee if Code requirements were
. imposed, relief may be granted'provided instrumentation necessary for the measurement flow rate _is installed during the next refueling outage.-
I l 4.8.2 Cateaory C Valves . 4.8.2.l' Relief Reauest. The licensee has requested relief from the ., check valve exercising requirements of Section XI, Paragraph IWV-3521.-for L the following. diesel fuel oil. pump discharge check valves. The licensee has , proposed that demonstration of system operability be considered adequate for -a
' verification of the check valves' operability. i 1-EE-13 1-EE-15 1-EE-19 l-EE 28 1-EE-31 EE-35 L h
a 4.8.2.1.1 Licensee's Basis for Relief--These check valves cannot L . be full flow tested because instrumentation is not installed.to measure flow-L( * , or. differentia 1 pressure. Verifying system operability every three months a d', - during pump testing is adequate for verifying valve operability. No further valve testing is necessary. NOTE: When flow instrumentation is installed during the next refueling outage, full flow will be verified every three f , months. 4
'\
53 5
. .e .,
. e y L
x ,. l O j ' 4.8.2'.1.2: Evaluation--During a conference call held on, j L November 21,_1989; .and in a . letter dated January-17,1990, the licensee l g proposed verifying thatcthe capacity of the diesel fuel oil pumps is greater
]
th'an the rate of fuel oil use .by the diesels during emergency. diesel j generator testing. This should be sufficient to provide reasonable 1 assurance of operational readiness until' flow rate instrumentation can be .f installed. The licensee has committed to the installation of flow rate- l L instrumentation during the next refueling outage. This instrumentation will j ( enable the licensee t'o-individually verify a full stroke of these valves to the open posit _ ion with flow. -
}
L , o) i L, A grace period for the installation of flow instrumentation is necessary to allow the licensee time to complete design changes, work packages, and procurement. Imposition of immediate compliance would result ! in a long outage which would be burdensome for the licensee due to the. cost ~ o involved, l i Based on the' determination that the Code requirements _=are impractical,
- and considering the burden on the licensee if Code requirements were l
-imposed, relief may be granted provided instrumentation necessary for the L . measurement flow rate is installed during the next refueling outage.
L 4.9 Diesel Generator Startina Air System , i 4.9.1 Cateaory B Valves 4.9.1.1 Relief Reauest. The licensee has requested relief from theJ stroke' timing requirements of Section-XI, Paragraph IWV-3413, for the following diesel air start system solenoid valves. The licensee has proposed that these valves be tested monthly by verifying that the diesel: generator starts. . a 1-EG-50V-100A 1-Et 50V-1008 1-EG-SOV-200A 1-EG-SOV-2008 1-E' SOV-300A 1-EG-SOV-300B 4.9.1.1.1 Licensee's Basis for Relief--These valves have actuation times considerably under a second and there is no-visual reference 54
^
. ... . ~ . _ . . .
g y . e !- -.'
%1 ; .
4 on the solencio valve when it has stroked, therefore, the stroke time cannot - ! c -be measured.; These solenoid valves will be stroke tested monthly:by. observing that- the; solenoid valves perform their intended function'(if the-
~ diesel starts, then.thefsolenoid. valve was stroked successfully).,;.The' '
Lfailure of these1 valves to open will promptly give a diesel engine trouble
- al arm., Further investigation would identify problems with the operability of these valves.
4.9.1,1.2 Evaluation -These solenoid operated valves have no ; control switchestor position. indication. Due to the valve design,= valve
, stem movement cannot be' visually verified. Therefore, stroke timing of-these valves is'not possible with the current system design. However,=the.
.only acceptance criteria proposed by the licensee for a successful test' is
=
that the diesel engine starts, which would provide no indication of valve j degradation. Therefore. the licensee should add additional acceptance- [ j criteria to ensure that the proposed testing would provide reasonable assurance of operational readiness. Measuring the diesel generator start-L time. and. assigning- a maximum limiting start time for a satisfactory test-could provide an ' indication of degradation if each bank is individually ; tested. This maximum start time should be less than or equal to the. Technical Specification requirement. J Compliance with the Code stroke timing requirements could only be achieved after significant modifications of these valves and their control [ circuitry to provide individual valve control-and. position. indication. These: design changes would be burdensome for the licensee due to'the cost:
- involved.
p Based on-the determination that the Code required testing is impractical, and considering the burden on the licensee if Code requirements were imposed, relief may be granted provided these valves are individually tested and the licensee's acceptance criteria for the proposed test is , expanded to include a maximum limiting start time which is less than or l L equal to the Technical Specification limit. l . 55 l p
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. z, APPENDIX A -
o, VALVES TESTED DURING COLD SHUTDOWNS' F - I i t>
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,- 7 :
w APPENDIX A VALVES TESTED DURING COLD SHUTDOWNS
'la j
,4 The following are Category A, B, and C valves which meet the exercising; requirements of the- ASME Code, Section XI, and are not full-stroke exercised-
' ~
every three nionths _during plant operation. These valves are specifically- !
'dentified i by the owner,in accordance with Paragraphs lWV-3412 an'd 3522 and are full-stroke exercised during cold shutdowns and refueling outages ~All i valves in'this Appendix have been evaluated and the reviewer agrees with'the y licensee that' testing these valves during power operation is not practical 4
due to the valve type, location, or system design. These valves.should not ; i be full-stroke exercised during power operation. These valves are listed i below and grouped according to the system in which they are located.
. 1. MAIN: STEAM ,
^
1.1 Cateaory B Valves l The following main steam line trip valves cannot be full- or part stroke p exercised during power operation because this could result in a turbine and ' i; reactor trip. Further, the Technical Specification acceptance criteria are
.l more-limiting than the standard Section XI test criteria. The Technical: .t Specification requires the measurement of elapsed, time from the manual [
'. initiation of steam line isolation to initiation of main trip valve motion- ;
, 'and the measurement of elapsed time from r'ull open to fulliclosed. 'If either If- :of Lthe limiting times are exceeded, the. valve. fails the test. Section~XI. , requires only the measurement of elapsed time from initiation of' steam line ! nisolation to full valve closure, which is a less conservative test. These: . valvesewill be full-stroke exercised during cold shutdowns and refueling outages. 1-MS-TV-101A 1-MS-TV-101B l-MS-TV-101C 2-MS-TV-201A '2-MS-TV-201B 2-MS-TV-201C Decay heat release control valves, 1-MS-HCV-104 and 2 MS-HCV-204. cannot i be full- or part-stroke exercised quarterly during reactor operatica because this testing would result in added steam load to the reactor which could j A-3
j
- 1. I N '. result lin!anoverpowercondition'andreactortrip. These valves will be T , f0ll stroke exe'rcised during cold shutdowns and. refueling outages,
,1 :
-i. k The following main steam system power operated relief valves cannot be full or part-stroke exercised during power operation because this could iresul't in 'a turbine and reactor trip. These valves'will be' full-stroke 1
- exercised during cold shutdowns and refueling outages.
" 1 MS-RV-101A -1 MS-RV-101B MS-RV-101C- '
2-MS.RV-201A- 2-MS-RV-2018 2-MS-RV-201C l.2 Cateaory C Val'ves a The following main steam system non-return valves cannot.be full- or 7 part stroke exercised during power operation because this could result in a ; turbine and reactor trip. These valves will be full-stroke exercised during l
. cold shutdowns and refueling outages. ,
a
'2. AUXILIARY FEEDWATER SYSTEM-1 2.1 Cateaory C Valves 3 The following auxiliary feedwater system check valves cannot be full- or part-stroke exercised to the open position during power operation because L this would introduce. cold auxiliary feedwater toithe steam generators 1 resulting in' thermal stress and possible degradation. - Also, full flow can only be established to a depressurized steam generator. These valves will be
~
-full-stroke exercised during cold shutdowne and refueling outages.
l Valve Function , L ;1(2)-FW-27,58,89 Auxiliary feedwater header check valves L 1(2)-FW-131,133,136,138 Auxiliary feedwater header containment 4 isolation check valves ! a 1(2) FW-142, 157, 172 Auxiliary feedwater pump discharge check i n >m vaives 1 1(2)-FW-272,273, Auxiliary _feedwater cross-connect header !
;1-FW-309, 310 containment isolation valves L 2-FW 305, 360 .
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-3. COMPONENT COOLING SYSTEM U
-y - 3.1 Cateaory B Valves L. .a
,, The following component cooling system return line isolation valves ;
from the rea'ctor coolant pumps cannot be full-stroke exercised or' fail 1 safe tested quarterly during reactor coolant pump operation. 'This testing would require the isolation of the component cooling _ lines thereby. stopping the flow of cooling water to the pumps. The loss of cooling water to these
~
m pumps can be damaging, even for short periods of time. These valves will be full-stroke exercised.and fail-safe tested during cold shutdowns and- 2 refueling-outages. i
.1 CC TV-105A
. 1-CC-TV-105B 'l-CC-TV-105C 1-CC-TV-107 2-CC-TV-205A 2 CC-TV-205B 2 CC-TV-205C 2-CC-TV 207 3.2 Cateaory C Valves
, The following twnponent cooling system check valves'cannot be exercised ;
1 to. the open or- closed positions during reactor. operation:because these valves 2 L are located inside the containment. They may be open or closed depending o~n f
,the-system lineup. A containment entry, and the . manipulation of 'other systems'. valves is necessary to test these valves:to either the open or-closed position' These valves will be full-stroke exercised:to the open and' closed-positions during cold shutdowns and' refueling outages.. <
y . Valve Function 3 ? 1(2)-CC-176, 177 Component cooling to the residual-. heat 4 removal heat exchangers 1(2)-CC-242,233,224 Component cooling to the containment air ! recirculation coolers , Ls Component cooling system supply line isolation check valves to the~ reactor coolant pumps, 1(2)-CC 1, 58, and 59, cannot be full-stroke exercised q quarterly._ during reactor coolant pump operation. This testing would require the isolation of- the component cooling lines thereby stopping the flow of cooling water _to the pumps. The loss of cooling water tc these pumps can be A-5 m
y L 1
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- 1. - i ;
Edamaging even for short' periods of: time. -These valves will be full-stroke-exercised during refueling outages.: 1
- 4. REACTOR COOLANT SYSTEM 4.1 Cateaory B' Valves'. '
Pressurizer power. operated relief valves, 1-RC PCV-1456, 1-RC-PCV-1455C, RC PCV-2456,'and 2-RC PCV 2455C have shown a high probability of sticking;
.t open while being exercised during power operation. These valves are not-required for overpressure protection unless the primary' system temperature is L 7
under 350 0F, T'hese valves will be tested on'the approach to cold shutdown and testing.shall not be deferred.
-4.2 Cateaory A/C Valves ,
-The primary grade water line to the pressurizer relief tank containment :
-isolation valves,.1 RC-160 and 1-RC-160, cannot be full-stroke exercised to theLclosed position quarterly during reactor operation.. The only method to- 3 verify closure capability of-this valve is by performing a local leak rate ,
e test. Since this check valve is located inside the reactor containment, a i, local leak rate test cannot be performed during reactor operation. This ,
-valve will be' full-stroke: exercised.to the closed position during' cold shutdowns.and refueling outages. ,[
l
- 5. RESIOVAL HEAT REMOVAL SYSTEM r
5.1 Cateaory A Valves Residual heat removal (RHR) pump suction valves from the reactor coolant system, 1-RH-MOV-1700, 1-RH-MOV-1701, 2-RH-MOV-2700, and:2-RH-MOV-2701 cannot-be full-stroke exercised quarterly during reactor operation. These valves are interlocked with the reactor coolant system to prevent them from opening at' elevated reactor coolant system pressure, because this would cause overpressurization of the RHR system and could result in a loss of coolant accident. The valve interlocks cannot be bypassed with normal control A-6 .
~
..---L---L---__-_---.-._., - - -, , -
-------w*w~ *
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L;, ..e ) j Y . circuits. These valves will: be full-stroke exercised during cold shut' downs t-and' refueling outages. 1 i l g . RHR system discharge valves to the reactor coolant system,- 1-RH-MOV-1720A,-1-RH-MOV-17208, 2-RH MOV-2720A, and 2 RH MOV-27200 cannot be s full-stroke. exercised quarterly during reactor operation. With these motor Li { operated valves shut, there is.no way to determine if-its respective check i valveiis leaking before opening the valve. If this condition did exist,~an overpressurizaiion condition could occur when the primary pressure of 2235- ' 5 psig was released into the RHR system. The RHR system pressure relief valve has a setting of 700 psig. This would unnecessarily challenge the-
, overpressure protection system. Since these valves are also part of the n , . discharge piping of the accumulators, there is.a possibility of discharging l an accumulator into, and disabling, the RHR system. :The accumulators are '
'lL. -maintained at pressure above the normal operating.or shutdown, pressure of;the
'RHR system. Opening these valves would dump accumulator water-into the RHR j < system. This would' dilute the boron concentration of the. accumulator-as well: )
, as lower its level and pressure, which is a violation of: Technical !
Specifications. These valves will be full-stroke exercised during cold shutdowns and refueling outages. RHR system heat exchanger flow control valves,1-RH-FCV 1605,
.1-HCV-1758, 2-RH-FCV-2605, and 2-HCV-2758:cannot.be full- or part stroke exercised quarterly during reactor operation because theycare located inside containment'and a containment entry is required to perform the Code required testing. These valves are not equipped with remote position indication.
l" 'Therefore, an exercise test can only be verified by locally observing stem L : movement. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
'i . 2 Cateoory C Valves RHR pump discharge check valves, 1(2)-RH-5,and 1(2)-RH-ll, and 2-RH 47 ,
- c cannot be full-stroke exercised to the open or closed positions quarterly during reactor operation. These low head pumps take suction from, and discharge to, tho reactor coolant system which operates at 2235 psig. This A-7
y 1 N pressure is we11'above;the shutoff head'of the RHR' pumps. Therefore, testing' '
# is not possible during reactor operation. These valves will be full stroke
~ exercised t'o the open and closed positions during cold shutdowns-and' refueling. outages.
- 3. ._
- 6. CHEMICAL AND VOLUME CONTROL SYSTEM 6.1 Cateaory A Valves The reactor coolant pump seal water return valves,1-CH MOV-1381 and:
. 2 CH MOV-2381, -cannot be full-stroke exercised quarterly during reactor coolant pump operation because closure of these-valves with:the reactor coolant pumps in operation would cause a loss of seal water flow which could
~
result in pump seal-damage.- These valves will be full-stroke exercised I 1. . during cold shutdowns and refueling outages. The reactor coolant system (RCS) letdown isolation trip valves, 1 CH-TV-1204 and 2-CH TV-2204,. cannot be- full-stroke exercised quarterly during' reactor operation because this testing would interrupt the letdown:
; flow from the RCS t , the volume control tank.- If these valves failed in the-closed position, reactor coolant inventory control would be lost. -The pres'surizer level control program _ controls reactor < coolant inventory by-n regulation the operation of-the charging flow control valve so that the
'chirging input flow to-the RCS and reactor coolant pump seal injection flow into the RCS matches letdown flow. These valves will be full-stroke exercised during cold shutdowns ~and refueling outages.
The normal charging header isolation valves, 1-CH MOV-1289A and 2-CH-MOV-2289A, cannot be full-stroke exercised quarterly during reactor operation because failure of these valves in the closed position during
-testing would cause a loss of charging flow and could result in the inability
.to maintain reactor coolant inventory. These valves will be full-stroke exercised during cold shutdowns and refueling outages, a
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gy , , 4 l p:4 ,6.2 Cateaory B Valves i a
. The normal . charging header is'olation valves,1-CH-MOV-1289B andL I 2-CH-MOV-2289BE cannot be full-stroke-exercised quarterly during reactor _ ,
D, = operation. Failure of these valves in the closed position during testing-wouldicause i loss of charging ' flow and could result in the inability to ! [ . maintain. reactor; coolant inventory. These valves will be full-stroke 1 exercised during. cold-shutdowns and refueling' outages. i Charging pump suction valves from the volume control. tank, 1 CH LCV-lll5C, 1-CH LCV-1115E, 2 CH LCV 2115C, and 2-CH-LCV-2115E cannot be
*[ "
. fully: or part-stroke exercised quarterly during reactor operation because-
.this testing would require the charging p -os' suction to be aligned'with the 4 refueling water storage tank.- This would cause.a sudden increase in the 1
, reactor coolant system boron inventory which could cause reactor pressure, j temperature, and' reactivity transients. These valves will be full-stroke .j exercised during cold shutdowns and refueling outages, j
,q The charging. pump recirculati.on header stop valves,'l-CH-MOV-1373 and- t 2-CH MOV 2373, cannot be full stroke exercised quarterly during reactor ,
operation;because failure of these valves in the closed position during. ) testing would-challenge the operability of the charging pumps. .The individual pump recirculation valves are cycled, but the failure of one of l these valves would only disable one~ pump. Since valves 1-CH-MOV-1373land 2-CH-M0V-2373 are common to all recirculation lines (for their respective I units) failure in the closed position would jeopardize the operabil.ity of all-ithree. charging pumps. These: valves will be full-stroke exercised during cold ! shutdowns and refueling outages. j
i 6.3 Cateaorv A/C Valves
'The normal charging line containment. isolation check valve,1(2)-CH-309, cannot;be full-stroke exercised to the closed position quarterly during s reactor operation. The only method to verify closure capability of this valve is by performing a local leak rate test. Since this check valve is ,
located inside the reactor contair.unt, a local leak rate test cannot be b*9 3
+
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[ ! performed during reactor operation. This valve will be full-stroke exercised i to the closed position during cold shutdowns and refueling outages. ! c i
- 7. SAFETY INJECTION SYSTEM 7.1 Cateoory A Valves l
The following high head safety injection to reactor coolant system isolation >alves cannot be part or full stroke exercised during power ; operation. Opening these valves would bypass the regenerative heat exchanger. ; and allow cold charging flow into the reactor coolant system causing' 1 p reactivity transients and possible thermal shock to the high head safety 1 injection system. These valves will be full-stroke exercised during cold shutdowns and refueling outages. 1 SI MOV-1842 i 1 SI MOV 1869A 1 SI MOV 18698 2 SI MOV 2869A 2 SI MOV 2869B 2-SI MOV 2842
- The low head safety injection line to the RCS cold legs containment isolation valves, 1-SI MOV 1890C and 2-SI M0V-2890C cannot be full or
,. part stroke exercised quarterly during reactor. operation. Technical . Specification 3.3.A.8 requires these valves to be in the open position, with ! power removed, during power operation. If these valves failed in the closed I
< +, ion during testing, the' low head safety injection system would be ]
rendered inoperable. THe valves will be full stroke exercised during cold ; L shutdowns and refueling outages. : The boron injection tank outlet isolation valves,1 SI.MOV 1867C, l l SI MOV 18670, 2 SI MOV 2867C, and 2-SI-MOV 28670 cannot be full- or ! part stroke exercised during reactor operation because opening these valves would bypass the' flow control valve and the regenerative heat exchanger. L This would allow cold excess charging flow into the reactor coolant system causing a reactivity transient and thermal shock to the injection nozzles. These valves will be full-stroke exercised during cold shutdcwns and , refueling outages. A 10 l i __, _. . - _ _ .-~ -_- .._ _ _ _ __.__
, 7.2 Cateoory B Valves The following accumulator nitrogen supply / vent line isolation valves cannot be full- or part stroke exercised quarterly during reactor operatit,n because this testing would provide a vent path from the accumulators whien would result in their depressurization. These valves will be full-stroke exercised during cold shutdowns and refueling outages.
1 St HCV 1853A 1 SI HCV 18538 1 St HCV 1853C 1 SI-HCV 1936 2 SI-HCV 2853A 2 SI HCV-2853B 2 SI HCV 2853C 2 SI HCV-2936 7.3 Cateoory A/C Valves The containment isolation valve for the nitrogen supply line to the accumulators, 1(2) S1 234, cannot be full stroke exercised to tha closed position quarterly during reactor operation. The only method to verify closure capability of this valve is by performing a local leak rate test. Since this check valve is located inside the reactor containment, a local leak rate test cannot be performed during reactor operation. This valve will be full stroke exercised to the closed position during cold shutdowns and refueling outages.
- 8. STEAM GENERATOR BLOWOOWN SYSTEM 8.1 Cateaory B Valves The following steam generator blowdown isolation valves cannot be full stroke exercised quarterly during reactor operation. Closir.g these valves during power operation causes the downstream piping to become empty due to drainage and the water flashing to steam. When the valves reopen, a flow surge occurs which automatically isolates the inner valves due to high flow. A containment entry is then necessary to reset these valves. Upon reopening, the process may occur again. These valves will be full stroke exercised during cold shutdowns and refueling outages.
1(2) BD TV-100A 1(2) BD TV-100B 1(2) BD-TV 100C 1(2) BD TV 1000 1(2)-BD TV-100E 1(2) BD TV 100F A-ll
- 9. CONTAINMENT SPRAY SYSTEM 9.1 Cateoory A/C Valves The containment spray pump discharge containment isolation check valves,
'l(2) RS II,^1(2) RS-17, 1(2) CS 13, and 1(2)-CS 24 cannot be full- or part stroke exercised during normal operation because this testing would result in spraying down the containment which could result in equipment damage. These valves will be full stroke exercised during cold shutdowns and 9- refueling outages. ,
9.2 Cateaory C Valves i The containment spray pump discharge check valves, 1(2)-CS-105, 1 CS 127, i
, and 2 CS 104 cannot be full- or part stroke exercised during normal operation '
because this testing would result in spraying down the containment which could result in equipment damage. These valves will be full stroke exercised during cold shutdowns and refueling outages.
- 10. RADIATION MONITORING SYSTEM 10.1 Cateaory A/C Valves I
The monitor return line containment isolation valve, 1(2)-RM 3, cannot be full stroke exercised to the closed position quarterly during reactor operation. The only method to verify closure capability of this valve is by 9erarming a local leak rate test. Since this check valve is located inside l the reactor containment, a local leak rate test cannot be performed during reactor operation. -This valve will be full-stroke exercised to the closed position during cold shutdowns and refueling outages.
- 11. INSTRUMENT /IR SYSTEM 11.1 C.g.tigery A/C Valves !
I Instrument air system containment isolation valves, 1-IA-938, 1 IA 939, 2 IA 864, and 2-IA-868 cannot be full-stroke exercised to the closed position l 1 A-12 l l i
l;- .. ., L .. l quarterly during reactor operation. The only method to verify closure l capability of this valve is by performing a local leak rate test. Since this J check valve is located inside the reactor containment, a local leak rate test l cannot be performed during reactor operation. These valves will be full stroke exercised to the closed position during cold shutdowns and I refueling outages
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APPENDIX B-Pl!D LIST , i The P&lDs listed below were used during the course of this review, , Unit 1 , SYSTEM DRAWING NO. i Main Steam System ll448 CBM 64A Auxiliary Steam and Air Removal System 11448 FM 66A Feedwater System 11448 FM 68A > Auxiliary Feedwater Cross connect System ll448 FM 688 l Circulating and Service Water System 11448 FM 71A ! circulating and Service Water System Il448 FM 718 , Component Cooling Water System ll448-FM 72A j Component Cooling Water System 11448 FM-728 Component Cooling Water System ll448 FM 72C ' Comoonent Cooling Water System ll448 FM 72D i Compressed Air System ll448 FM-75E i Compressed Air System ll448 FM 75G ! Containment Instrument Air System ll448 FM 75J. !. Sampling System ll448 FM 828 Vents and Drains System 11448 FM 83A Vents and Drains System ll448 FM 838 Containment Spray System ll448-FM 84A f Recirculation Spray System ll40-FM-848 l . Containment Vacuum and Leakage Monitoring Systau 11448 FM 85A Reactor Coolant System ll448 FM-86A Reactor Coolant System ll448 FM 86B Residual Heat Re'moval System ll448-FM 87A Chemical and Volume Control System ll448-FM 88A Chemical and Volume Control System 11448 FM 888 , Chemical and Volume Control System ll448-FM 88C Safety injection System ll448 FM 89A ' L B3
- - * ,m., s, .
r i-.
SYSTEM DRAWING NO. Safety injection System
- ll448 FM 89B 3 Gaseous Waste Disposal System 11448 FM 90A !
Gaseous Waste Disposal System 11446.rM 908 Containment Hydrogen Analyzer System 11448 FM-90C Reactor Cavity Purification System ll448 FM-Il8A .
. Steam Generator Blowdown System ll448-FM 124A , Containment Particulate Radiation Monitor System ll448 SPS 14A 4
Air Cooling And Purging System ll448 FB 6A ! llDll I SYSTEM DRAWING NO. l
- Main Steam System ll548 CBM 64A ;
Auxiliary Steam and Air Removal System ll548 FM 66A ! Feedwater System ll548 FM 68A . Auxiliary feedwater Cross connect System ll548 FM 68B Circulating and Service Water System ll548 FM-71A , Circulating and Service Water System 11548 FM 71B Component Cooling Water. System ll548 FM 72A j Component Cooling Water System ll548 FM 72B l Component Cooling Water System ll548 FM 72C Component Cooling Water System ll548 FM 720 Compressed Air System ll548 FM 75E Compressed Air System 11548-FM 750 Containment Instrument Air System ll548-FM-75J [ Sampling System ll548-FM 828 j Vents and'Orains System ll548 FM 83A
-Vents and Drains System 11548-FM 83B Containment Spray System ll548-FM 84A Recirculation Spray System 11548 FM 84B ,
Containment Vacuum and Leakage Monitoring System 11548 FM 85A Reactor Coolant System ll548 FM 86A Peactor Coolant System ll548-FM 86B Residual Heat Removal System ll548 FM-87A B4
o' SYSTEM ORAWING NO.- I Chemical and Volume Cc., trol System 11548 FM 88A Chemical and Volume Control System ll548 FM-888 : Chemical and Volume Control System 11548-FM 88C Safety 'litjection System ll548 FM 89A : Safety injection System 11548 FM 89P l Gaseous Waste Disposal System ll548 FM 90A l Gaseous Waste Disposal System ll548 FM 908 4 Containment Hydrogen Analyzer System ll548 FM 90C Reactor Cavity Purification System Il548-FM ll8A- ' Steam Generator Blowdown System 11548 FM 124A . Containment Particulate Radiation Monitor System ll548 SPS 14A Air Cooling And Purging System 11548-FB 6A Units 1 & 2 SYSTEM ORAWING NO. Diesel Fuel Oil System 11448 FB 4B i Fire Protection System ll448 FB 478 l' Emergency Diesel Generator System 11448 FB-46A- , Emergency Diesel Generator System 11448 FB-46B - Emergency Diesel Generator System ll448 FB-46B
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e i 6 APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW.
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T APPENDIX C IST PROGRAM ANOMALIES IDENTIFIED DURING THE REVIEW Incons'istencies and omissions in the licensee's program noted during the , course of this review are summarized below. The licensee should resolve l these items in accordance with the evaluations, conclusions, and guidelines
- presented in this rebett. I
- 1. Section 4.1 (program development philosophy) of the licensee's IST f
program states "The requirements of Section XI are not interpreted ; as superceding or adding to any limiting condition for operation". The licensee's meaning is nat apparent and this statement should bc
. clarified. However, the following points should be noted: ;
(a) 10CFR50.55(a)(5)(ii) states that if the IST program for a L facility conflicts with the Technical Specifications, the licensee shall apply to the commission for amendment of the Technical Specifications to conform the Technical Specifications with the revised program, (b) though the licensee is not expected to violate Technical Specifications to perform Section XI testing, the Code requirements in excess of Technical Specifications do apply , l and should be performed, (c) Technical-Specifications should be L changed to conform to Section XI requirements unless specific ; relief from the Code requirements is grar,ted and, (d) if i Section XI testing requires a component to be declared inoperable - l and the inoperability of this component results in entering a f Limiting Condition for Operation, the Technical Specification Limiting Condition for Operation rhould be followed even if the Technical Specification operability requirements are less stringent. s
- 2. Section 4.2 (program implementation) of the licensee's IST program- !
states, "Certain valves cannot be full-stroke exercised during normal operation following maintenance. If maintenance cannot be deferred to cold shutdown, then an engineering evaluation must be ' performed prior to the maintenance being performed to determine the C-3
y , o . ye effect on valve operability. If the evaluation shows the operability of the valve will not be affected, then no post maintenance testing will be required. A partial stroke test will be performed if possible." Section XI, Paragraph IWV 3200, states, "When a valve or its control system has been replaced or repaired or has undergone maintenance (adjustment of stem packing, removal of the bonnet, stem assembly, or actuator, and disconnection of hydraulle or electrical lines are examples) that could affect its
, performance, and prior to the time it is returned to service, it i shall be tested to demonstrate that the performance parameters
,, which could be affected by the replacement, repair, or maintenance a- are within acceptable limits". If the maintenance could affect the i
'o performance of the valve (stroke time, leak rate, ect.) then post maintenance testing must be performed even if the licensee decides ;
that the valve will still be operable. The licensee should change j this statement to conform to the Code requirements.
- 3. Relief has been requested for the following pumps because there is no installed instrumentation for the measurement of various test
/ quantities. Relief may be granted provided the required instrumentation is installed during the next refueling outage.
/
< RR No. Pumo Identification Function TER Section P2 1(2)-CH P 1A. IB, 1C High head charging 3.2.1.1 P-3 1(2)-Si-P-1A,1B Low head safety injection 3.4.1.1 P4 1(2)-RS P-2A, 2B Outside recirculation spray 3.5.1.1 g, ' P-6 1(2) FW P 3A, 38, 2 Auxiliary feedwater 3.6.1.1
,P-9 1(2)-CH-P20,2D Boric acid transfer 3.3.1.1 P ll 1 SW-P 1A, IB, IC Service water 3.8.1.1 1 - Unit 1 only l o 4. The NRC staff position is that valve disassembly and inspection can l
- be used to verify check valve operability when full-stroke Y y exercising by flow or by the other positive means allowed by i IWV 3522 are not practicable. The NRC staff positions regarding disassembly and inspection are explained in detail in Generic Letter 89-04, " Guidance on Developing Acceptable Inservice Testing c.s I y
Programs." Relief may be granted for the listed valves in Relief. , Requests V 20. V 40, and V 41 provided the licensee complies with ! these staff positions.
^
(Reference Sections 4.2.1.2, 4.3.1.2, l and 4.4.2.2 of this report.) : H. 5. The licensee has proposed, in valve relief requests V 5 and V 42, l to disassemble and inspect valves to verify their closure ! capability. Relief may be granted provided the licensee follows [ the NRC staff guidance on disassembly and inspection in Generic f Letter No. 89 04. (Reference Sections 4.2.1.1 and 4.7.1.1 of this report.). f
- 6. In-Valve Relief Request V-1, the licensee proposes'that the main steam safety valves be tested in accordance with PTC-25.3-1976, L .
Section 4.091(a)(2), and that all other safety and relief valves be , tested in accordance with Section 4.091(c)(1). Section XI, ; l Paragraph IWV-3512, states that safety and relief valve set points c shall be tested in accordance with ASME PTC 25.3-1976, " Safety and : Relief Valve Performance Test Codes " PTC 25.3 1976, Section ; 4.091(a)(2) is the test method for system testing to determine set pressure with calibrated hydraulic or pneumatic assist equipment. PTC 25.3-1976, Section 4.091(c)(1) is the test method for bench . , testing to determine set pressure and valve leakage. Paragraph IWV 3512 further states'that' bench testing, or testing in place, with suitable hydraulic or pneumatic assist equipment is an ; acceptable method under PTC 25.3 1976. Since the licensee's l proposed testing _ is specifically mentioned as being acceptable in ; the Code, relief is not required. (ReferenceSection4.1.2.1of ! thisreport.)
.7. Valve Relief Request V 30 states that the following valves are adequately leak rate tested by Technical Specification ,
requirements. These valves are reactor coolant system boundary isolation valves. The failure of these valves could result in a , loss of coolant accident. However, since most of these valves are paired in series, the licensee's proposed testing would not demonstrate the leak tightness of each valve as required by the C-5 i
q, _ . _ _ _ . _ _ __ _ _ _ - _ _ _ . _ _ _ - _ _ _ _ ___m_. _
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Code. The leak tight integrity of the second valve in the pair ! cannot be verified unless the first valve has failed or is leaking ! significantly, therefore, the proposed testing verifies only the ! leak tight integrity of each pair of valves. Although the ! Technical Specification requirem nts mentioned by'the licensee do ! not verify the leak tight integrity of individual valves as required by the Code, system hydrostatic tests and monitoring the , total RCS leakage does provide assurance of the leak tight , integrity of the valve pairs at the RCS boundary. The licensee's : proposed testing combined with the Technical Specification , corrective action requirements for excessive leakage would provide j some assurance of leak tight integrity. On this basis, the licensee may continue to monitor leakage and perform leak testing in accordance with their plant Technical Specifications until the NRR Inter System Loss of Coolant Accident (ISLOCA) study is completed, and the results analyzed, to determine if further L testing should be required. (Reference Section 4.1.1.1 of this L ' report.) - l-l Valve Function 1-RC HCV-1556A, B, C Loop fill boundary valves 2 RC HCV 2556A,-B, C 1 -SI-107, 109 Accumulator discharge check valves 1 SI 128, 130 ' 1 SI 145, 147 1 -SI-88, 91 Combined safety injection isolation 1 SI-94, 238 check valves to the RCS hot legs 1 -51.238, 240 1(2)SI235,236,237 High head safety injection isolation ! check valves to the RCS cold legs 1 RH MOV-1700, 1701 RHR system suction valves free the RCS 2 RH-MOV-2700, 2701 1
, 1-RH-MOV-1720A, 17208 RHR syR em discharge valves to the RCS 2-RH MOV-2720A, 27208 1'
- 8. In Valve Relief Request V 39, the licensee proposes that containment isolation valves which cannot be individua'11y leak rate c.s l
.a ,, ..,.--,.n , , . . - . , . . . . . . . , . . , - . . - , - , - - . . - . - . - - + - - . . _ . - - _ _ _ - - - _ _ - . - - - _ _ _ - - - - - - - - - - -
.a .
j j tested be tested in groups, with leakage limits assigned to the ! group which'are subject to the acceptance criteria of IWV-3426 ' and 3427. This test method should provide reasonable assurance of the leak tight integrity of these valves as long as the assigned l 1.initing leakage rate for each valve grouping is conservative : considering the number and sizes of valves in the group. The ! assigned. leakage rates should be based on the smallest valve in the . group so_that. corrective actions are taken whenever the leak-tight l' integrity of any valve of that group is in question. However, using the licensee's methodology for determining group leakage rates, individual valve leakage rates could be many times the leakage limit which would be appropriate for that valve, based on IWV 3426(b), before corrective action is required. In some valve groups, leakage through the smallest valve could be a factor of 10 greater than the individual valve leakage limit of IWV-3426(b) before corrective action is required. Significant degradation of the smallest valve could go undetected in a group of otherwise leak j tight valves. The licensee should reevaluate this criteria in the l light of the service history of these valve groups. The criteria { established for these groups should ensure that no valve will become seriously degraded before corrective action is required. Relief may be granted provided the licensee reevaluates the group leakage limits bued on the diameter of the smallest valve in each group as discussed above. (Reference Section 4.1.4.1 of this report.) ,
- 9. Valve Relief Request V-26 proposes that the following safety ,
in[ection systein accumulator discharge check valves be full flow tested on a sampling basis at a refueling outage frequency. This would allow the testing of each check valve no more than once every ; three re. fueling outages unless failure of one valve occurs during this-time period. The licensee has neither demonstrated that this . testing frequency would provide reasonable assurance of operational readiness nor that it would be burdensome to test all three sets of
- check valves each refueling outage. During a conference call with '
- the licensee held on November 21, 1989, the licensee stated that 4
C7
{ q they have not developed definitive acceptance criteria for their l proposed testing. The licensee is currently working to demonstrate l that the proposed testing is capable of detecting valve ;
-degradation, that the results of this test can be extrapolated to !
comonstrate a valve's ability of pass design basis flow, and that ' the acceptance criteria to be adopted would provide reasonable j assurance of operational readiness. Prior to the start.of the next ) refueling outage, the licensee should demonstrate that their'
- proposed testing would provide reasonable assurance of operational i readiness or adopt another alternative which meets the criteria of i Generic Letter No. 89 04, Position 1 or Position 2. (Reference Section 4.4.1.1 of this report.) .
1(2)-SI-107 1(2)-SI-109 1(2)-SI 128 #
. 1(2)-51-130 1(2)-51-145 1(2)-51-147
- 10. Valve Relief Request V 27 proposes that the following safety injection system check valves to the reactor coolant system be exercised to the closed position in accordance with plant Technical Specifications. Relief may be granted from the Code exercising requirements for valves 1(2)-51-79,82,85,241,242, !
and 243 to the closed position provided they are individually ! leak rate tested. Interim approval of the licensee's proposed alternative for verifying the closure capability of valves 1(2)-51-08, 91, 94, 235, 236, 237, 238, 239,-and 240 for the leak rate testing requirements of Section XI, IW-3420, is discussed in Section 4.1.1.1 of this report. . (ReferenceSection4.4.1.2of
- this report.)
Valve Function 1(2)-51-88,91,94,238, Combined safety injection isolation 239, 240 check valves to the RCS hot legs. 1(2)-SI-235,236,237 High head safety injection isolation check valves to the RCS cold legs 1(2)-SI-241,242,243 Low head safety injection isolation check valves to the RCS cold legs 1(2) SI-79, 82, 85 Combined safety injection isolation check valves to the RCS cold legs C-8
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- 11. Valve Relief Request V 28 proposes that valve 1(2) SI 25, a l charging pump suction check valve from the refueling water storage ]
tank cross tie, be exempted from exercising to the closed l position. Valve 1(2)51-25 has a safety function in the closed ] position to prevent diversion of flow when the other RWST is used
- as a source for the high head safety injection pumps. The {
licensee has not provided sufficient technical justification for l
^
their claim that performance of this testing would require l draining one or both RWSTs. For this reason, and because the , licensee has proposed no alternatives to the Code required l" testing, relief _should not be granted. (ReferenceSection4.5.1.1 ofthisreport.) E !
- 12. Valve Relief Request Y-37 proposes that the following diesel generator air start solenoid valves.be demonstrated operable ,
monthly by verifying that the diesel generator starts. However,- , the only acceptance criteria proposed by the licensee for a successful test is that the diesel engine starts, which would provide no indication of valve degradation. TherGfore, the , licensee should add additional acceptance criteria to ansure that , the proposed testing would provide a reasonable assurance of , , operational readiness. Measuring the diesel generator s' art time ; and assigning a maximum limiting start time for a satis (actory test could provide an indication of degradation if caeh bank is individ'ually tested. This maximum start time should be less than
~
or equal to the Technical Specification requirement. Relief may be granted provided the licensee's acceptance ariteria for the l proposed test is expanded to include a maximum limiting start time which is less than or equal to the Technical Specification limit. (Reference section 4.9.1.1 of this report.). j 1-EG 50V-100A 1-EG-50V 1008 1-EG 50V-200A 1-EG 50V-200B 1-EG-50V-300A 1-EG-50V-3008
- 13. Cold Shutdown Justification CSV 19 for the following emergency boration system valves states: ' Exercising these valves during power operation would allow the injection of boric.icid into the C-9
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reactor coolant system, which would upset the boron concentration ! in the primary plant water. There is a possibility of discharging l an accumulator into the residual heat removal system'(RHR) and ! disabling it. The accumulators are maintained at pressure above l the normal operating or shutdown pressure of the RHR system.
'l Opening of these valves would dump accumulator water into the RHR l system. This will dilute the boron concentration of the l accumulator as well as lower its level and pressure, which is a j violation of Technical Specifications. Valves 1-CH 76, 92, 109, i and 116 will be partial flow exercised every quarter." The first '!
sentence, by itself, does not provide sufficient detail to justify cold shutdown testing. Exercising emergency boration line valves 'j has no relation to safety injection ac:.umulator pressure or level nor would it affect the operability of the accumulators or the RHR system. For these reasons, this cold shutdown justification is unacceptable. 1 CH MOV-1350 2 CH MOV 2350 1(2) CH 227 1 CH 76 1 CH 92 1 CH 109 i 1 CH 116 l 14 Cold Shutdown Justification CSV 20 for Unit 2 lists the primary :i grade water supply to the pressurizer relief tank as 2 RC 20 while ; the IST program valve table lists this valve as 2 RC 160. This cold shutdown justification also lists the instrument air i containment isolation valves as 2 IA 864 and 939 while the valve table lists them as 2 IA 864 and 868. This discrepancy should be corrected. ;
- 15. Relief' Request V 21 provides the cold shutdown justification for i not exercising valves 1(2)-51 50, 1 51 58, and 2-SI-327 to the closed position quarterly. Relief is not required to perform cold ;
shutdown testing. Therefore, this portion of the licensee's relief request was not evaluated in Section 4.0 of this report. 3 The licensee's justification for not testing these valves , quarterly during power operation is inadequate. The licensee has stated that testing these valves to the closed position quarterly [ i L : C-10 L
{ . 14 ( ,~. f o ( . would require isolating the suction line to the low pressure l[, safety injection pumps, which would require them to enter a Technical Specification LCO. However, the licensee ~ currently exercis'es valves 1(2) SI MOV 1862A and B quarterly during power p operation. Closing these valves isolates'the suction piping for t'e' h low pressure safety injection pumps. Therefore, valves 1(2) 5150,1-5158, and.2-SI 327 should be tested quarterly during power operation. ..c ; i P sf'
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TECHNICAL EVAL'dTION REPORT. PUMP AND VALVE INSERVICE l TESTING PROGRAM, SURRY POWF.R STATION, UNITS 1 & 2 . 3 : A ti .e.e., ,,, us 3 i
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March 1990 a fin CA C A ant a.vunga A6812 o l AWfMORill g.typgc,ogpony i H..B. Stockton Technical Evaluation > H. C. Rockhold Report ; L PERiOO Cov 4800 na o, , 4 f
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Renulatory and Technical Assistance EGl,GIdaho.Inc. P. O. Box 1625 .. I Idaho Falls. ID 83415
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- 9. PO #6 Aael2 A T:08: Naast Am0 ACOR 688 iss =sc. ress 1.== m assie ; et emanerer. suusser est asema. osene , asem.. v s asum, assassy, esaseems, Hechanical Engineering Branch ;
Office of Nuclear Reactor Regulation . U.S. Nuclear Regulatory Commission 1 Washington, DC 20555 ; 10 SWP'L8WGNTARY 40785
- 11. AS$f R ACT <ser =ee n es, -
This EGSG Idaho, Inc., report ~ presents the results of our evaluation of the Surry Power Station Inservice Testing Program for Pumps and Valves whose function , is safety related. l . L , 4 1
- 12. EE Y WOR 05,0ESCA;PTOR5 ftme sse sreasumso asr ==n amor asemmen eme sse ,emy,., '
ia...vaiseswiv svaruwe=T Unlimited 64 55EW888TY EggaFiCaTegas
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