ML20058L964
| ML20058L964 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/31/1993 |
| From: | Hartley R, Ransom C EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20058L968 | List: |
| References | |
| CON-FIN-L-2594 EGG-RTAP-10655, TAC-M84494, TAC-M84495, TAC-M84496, NUDOCS 9308170220 | |
| Download: ML20058L964 (36) | |
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O EGG-RTAP-10655 TECHNICAL EVALUATION REPORT PUMP AND VALVE INSERVICE TESTING PROGRAM BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 Docket Numbers 50-259, 50-260, & 50-296 l
Clair B. Ransom R. Scott Hartley Published July 1993 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the -
U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Under DOE Contract Number DE-AC07-761001570 FIN Number L2594, Task Order No. 2 TAC Numbers M84494, M84495, & M84496 l
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o ABSTRACT This report presents the results of our evaluation of the Browns Ferry Nuclear Plant, Units 1, 2, and 3 Inservice Testing program for safety-related pumps and valves.
PREFACE This report is supplied as part of the " Review of Pump and Valve Inservice Testing Programs for Operating License Reactors (III)" being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Mechanical Engineering Branch, by EG&G Idaho, Inc.,
Regulatory and Technical Assistance Programs Unit.
FIN No. L2594 B&R 920-19-05-02-0 Docket Nos. 50-259, 50-260, and 50-296 TAC Nos. M84494, M84495, & M84496 11
CONTENTS ABSTRACT .-............................... 11 PREFACE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
- 1. INTRODUCTION ............................. I 1.1 IST Program Description ................... 1-1.2 IST Requirements . . . . . . . . . . . . . . . . . . . . . . . I 1.3 Scope and Limits of the Review . . . . . . . . . . . . . . . . 2
- 2. PUMP TESTING PROGRAM ........................ 3 2.1 General Pump Relief Requests . . . . . . . . . . , . . . . . . 3 2.1.1 Bearing Temperature Measurements . . . . . . . . . . . 3 2.1.2 Measurement of Inlet and Differential Pressure . . . . 4
- 3. VALVE TESTING PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . 6 3.1 Various Systems ....................... 6 3.1.1 Valves in Systems Out of Service . . . . . . . . . . . 6 3.1.2 Stroke Times of Power-0perated Valves ........ 7 3.2 Main Steam System ...................... 8 3.2.1 Category A Valves .................. 8 3.2.2 Category BC Valves . . . . . . . . . . . . . . . . . . 10 3.2.3 Category C Valves .................. 11 3.3 Feedwater System . . . . . . . . . . . . . . . . . . . . . . . 12 3.3.1 Category AC Val ves . . . . . . . . . . . . . . . . . . 12 3.4 Standby Liquid Control System ................ 14 3.4.1 Category AC Valves . . . . . . . . . . . . . . . . . . 14 3.5 Control Rod Drive System . . . . . . . . . . . . . . . . . . . 15 3.5.1 Category AC Valves . . . . . . . . . . . . . . . . . . 15 3.6 Reactor Water Cleanup System . . . . . . . . . . . . . . . . . 16 3.6.1 Category AC Valves . . . . . . . . . . . . . . . . . . 16 tii
6 3.7 Reactor Building Closed Cooling Water System . . . . . . . . . 17 3.7.1 Category AC Valves . . . . . . . . . . . . . . . . . . 17 3.8 Residual Heat Removal System . . . . . . . . . . . . . . . . . . 19 3.8.1 Category AC Valves . . . . . . . . . . . . . . . . . . 19 3.9 Core Spray System ...................... 21 '
3.9.1 Category AC Valves . . . . . . . . . . . . . . . . . . 21 3.10 HPCI/RCIC Systems . . . . . . . . . . . . . . . . . . . . . . 23 3.10.1 Category A Valves . . . . . . . . . . . . . . . . . . 23 3.10.2 Category AC Valves ................. 24 3.11 Containment Inerting System . . . . . . . . . ........ 25 !
3.11.1 Category AC Valves ................. 25 APPENDIX A - IST PROGRAM AN0HALIES ................... A-1 P
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. l TECHNICAL EVALUATION REPORT I PUMP AND VALVE INSERVICE TESTING PROGRAM BROWNS FERRY NUCLEAR PLANT. UNITS 1. 2. & 3
- 1. INTRODUCTION i
This report provides the results of the technical evaluation of certain 1 relief requests from the pump and valve inservice testing (IST) program for I Browns Ferry Nuclear Plant, Units 1, 2, & 3, which was submitted by the i Tennessee Valley Authority (TVA). i Section 2 presents TVA's bases for requesting relief from the requirements for pumps followed by an evaluation and conclusion. Section 3 presents similar information for valves.
Appendix A lists program inconsistencies and omissions, and identifies needed program changes.
Appendix B is a listing of the P& ids used for this review. >
1.1 IST Proaram Descriotion The TVA submitted an update to the Browns Ferry Nuclear Plant, Units 1, 2, & 3, pump and valve IST program with a letter dated August 31, 1992. The program update is not identified by a specific revision number and therefore will be identified only by its submission date. This program covers the second 120 month IST interval, which runs from September 1,1992, to September 2002. The relief requests pertain to requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),Section XI,1986 Edition, and the Code of Federal Regulations (CFR),
1.2 IST Reouirements 10 CFR 50.55a(g) states that IST of certain ASME Code Class 1, 2, and 3.
pumps and valves will be done according to the ASME Code,Section XI, Subsections IWP and IWV, except where the alternative is authorized or relief is granted by NRC in accordance with 10 CFR 50.55a(a)(3)(1), (a)(3)(ii), or (f)(6)(i). TVA requests relief from the ASME Code testing requirements for specific pumps and valves. Certain of these requests are evaluated in this Technical Evaluation Report (TER) using the acceptance criteria of the Standard Review Plan, Section 3.9.6, NRC Generic Letter No. 89-04 (GL 89-04),
" Guidance on Developing Acceptable Inservice Testing Programs," and 10 CFR 50.55a. Other requests in the licensee's IST program that are not evaluated in this TER, may be granted by provisions of GL 89-04 or solely involve non-Code Class 1, 2, or 3 components.
In rulemaking to 10 CFR 50.55a effective September 8, 1992 (See 57 Federal Reaister 34666), the 1989 Edition of ASME Section XI was incorporated in 5 (b) of 5 50.55a. The 1989 Edition of Section XI provides that the rules for IST of pumps and valves are as specified in ASME/ ANSI Operations and Maintenance Standards Part 6 (OM-6), Inservice Testing of Pumps in Light-Water Reactor Power Plants, and Part 10 (DM-10), Inservice Testing of Valves in Light-Vater Reactor Power Plants. Pursuant to 1 (f)(4)(iv), portions of 1
O editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and therefore, relief is not required for those inservice tests that are conducted in accordance with OH-6 and-0M-10, or portions thereof. Whether all related requirements are met is subject to NRC inspection.
1.3 Scoce and Limits of the Review The scope of the detailed review was limited to the relief requests and cold shutdown justifications submitted with the licensee's IST program. Other portions of the program, such as general discussions, pump and valve test tables, etc., were cursorily reviewed. Endorsement of these aspects of the program by the reviewer is not stated or implied.
The evaluations in this TER are applicable only to the components or groups of components identified by the submitted requests. Further, the evaluations and recommendations are limited to the requirement (s) and/or function (s) explicitly discussed in the applicable TER section. For example, the results of an evaluation of a request involving testing of the containment isolation function of a valve cannot be extended to allow the test to satisfy a requirement to verify the valve's pressure isolation function, unless that extension is explicitly stated.
The TVA provided several cold shutdown justifications for exercising Category A, B, and C valves during cold shutdowns and refueling outages instead of quarterly. Valves identified to be tested during cold shutdowns need not be tested if testing was performed within three months of the cold shutdown in accordance with IWV-3412(a) and -3522. These justifications were reviewed and found to be acceptable except as noted in Appendix A.
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- 2. PUMP TESTING PROGRAM The following relief requests were evaluated against the requirements of the 1986 Edition of the ASME Code,Section XI,10 CFR 50.55a, and applicable NRC positions and guidelines. A summary is presented for each relief request followed by the licensee's basis for relief and the evaluation with the reviewer's recommendations. The evaluations are grouped according to topic or system.
2.1 General Pumo Relief Reouests 2.1.1 Bearina Temoerature Measurements 2.1.1.1 Relief Reouest. PV-1 requests relief from the bearing temperature measurement requirement of Section XI, 1 IWP-3100, for all pumps in the IST program. The licensee proposes to monitor pump vibration in lieu of taking annual bearing temperature measurements, except for pumps equipped with bearing temperature instrumentation.
Note:
The diesel fuel transfer (DFT) pumps included in the request are non-ASME Code Class. Therefore, they are not considered in the following evaluation.
2.1.1.1.1 Licensee's Basis for Reouestina Relief--The bearings for the residual heat removal (RHR), core spray (CS), RHR service water (RHRSW), and DFT pumps are lubricated by the pumped fluid. These pumps and the standby liquid control (SLC) and reactor core isolation cooling (RCIC) pumps are not equipped with temperature indicators.
The RCIC and high pressure coolant injection (HPCI) pumps have oil cooled bearings. However, these pumps cannot be operated long enough for the bearing oil to reach stable temperatures without overheating the torus and causing unit shutdown.
Alternate Testina: Vibration measurements are taken on all the pumps in the Section XI program during testing to detect changes in bearing performance.
Temperature and lubricant level / pressure are monitored on pumps which are equipped with instrumentation.
2.1.1.1.2 Evaluation--The Code requires annual measurement of pump bearing temperatures to aid in detection of bearing degradation.
However, it is widely recognized that pump bearing temperatures taken annually are unlikely to aid in the detection of bearing degradation. A temperature rise in a failing or severely degraded bearing usually occurs only just before failure. This makes detecting impending bearing failure by annual bearing temperature measurement very unlikely. Bearing temperatures taken yearly provide little statistical basis for determining the ir.cremental degradation of a bearing. Measurements of pump bearing vibration provide much better information for assessing pump bearing condition than annual measurement of temperature in accordance with Section XI.
In rulemaking to s 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of s 50.55a. The 1989 Edition of 3
Section XI provides that the rules for inservice testing of pumps are as specified in OH-6. & 50.55a,1 (f)(4)(iv), provides that IST of pumps may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of 6 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OM-6 does not require measurement of pump bearing temperatures. The licensee proposes to measure and assess pump vibration in lieu of bearing temperature for pumps without bearir.g temperature instruments. The NRC staff imposed no limitations to 0M-6 associated with the deletion of pump bearing temperature measurements. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to @ 50.55a 1 (f)(4)(iv). There are no specific related requirements for pump bearing temperature measurements.
2.1.2 Measurement of Inlet and Differential Pressure 2.1.2.1 Relief Reauest. PV-2 requests relief from measuring inlet and differential pressure as required by Section XI, 1 IWP-3100, for the positive displacement SLC and DFT pumps. The licensee proposes to measure discharge pressure during quarterly testing.
Note:
The DFT pumps are non-ASME Code Class. Therefore, they are not considered in the following evaluation.
2.1.2.1.1 Licensee's Basis for Reauestina Relief--During testing, these pumps take suction from a tank that has a relatively small range of level variation during pumps operation. In addition, these are positive displa:ement pumps whose inlet pressure does not affect pump operational characteristics. Therefore, differential pressure measurement is not meaningful in monitoring pump performance. Also, the DFT pumps are not instrumented or constructed to allow measurement of discharge pressure.
Alternate Testina:
SLC: Pump discharge pressure will be measured during quarterly testing.
DFT: Flow rate is measured monthly as required by plant technical -
specifications (TS) utilizing existing tank level instrumentation.
2.1.2.1.2 Evaluation--The Code requires measurement of inlet and l differential pressure. These measurements can be used to assess changes in the condition of centrifugal pumps. However, the SLC pumps are positive displacement type. Their outlet pressure is dependant on the pressure of the system into which they are pumping and is not affected significantly by either inlet pressure (providing adequate net positive suction head exists) or flow rate. For these pumps, differential pressure and flow rate are not dependant variables as they are for centrifugal type pumps. Differential pressure is not a meaningful parameter in determining if hydraulic degradation is occurring for positive displacement pumps.
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In rulemaking to 6 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of 5 50.55a. The 1989 Edition cf Section XI provides that the rules for inservice testing of pumps are as specified in OH-6. 6 50.55a,1 (f)(4)(iv), provides that IST of pitsps may meet the requirements set forth in subsequent editions and addenda that are-incorporated by reference in 1 (b) of 5 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OH-6 does not require measurement of pump inlet or differential pressure for positive displacement pumps. OH-6, Table 2, specifies flow rate and discharge pressure as the hydraulic test parameters for. positive displacement pumps. Table 3b provides the acceptance criteria for these measurements. The licensee proposes to measure and assess pump discharge pressure in lieu of inlet and differential pressure for these positive displacement pumps. The NRC staff imposed no limitations to OH-6 associated with the deletion of pump inlet pressure measurements or with substituting discharge pressure for differential pressure for positive displacement pumps. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8, 1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to 6 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes 1s 5.2 and 6.1 of OH-6. Whether all related requirements are met is subject to NRC inspection.
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- 3. VALVE TESTING PROGRAM The following relief requests were evaluated against the requirements of the 1986 Edition of the ASME Code,Section XI, 10 CFR 50.55a, and applicable NRC positions and guidelines. A summary and the licensee's basis for each relief request is presented followed by an evaluation and reviewer's recommendation. Relief requests are grouped according to system and Code Category.
3.1 Various Systems 3.1.1 Valves in Systems Out of Service 3.1.1.1 Relief Reauest. PV-4 requests relief from the testing requirements of Section XI, 3 IWV-3416 and -3417(b), for valves in systems out of service that are being returned to service and for valves tested at cold shutdowns (CSDs) that require corrective actions due to stroke time measurements. The licensee proposes to determine system requirements for operation from the TS requirements.
3.1.1.1.1 Licensee's Basis for Reauestino Relief--lWV-3416 states that valves shall be exercised within 30 days prior to return of the system to service. IWV-3417 states that when corrective action is required as a result of tests made during CSD, the condition shall be corrected before startup.
The plant TS limiting conditions of operation clearly state the minimum requirements for safe operation of the plant. The failure of a particular valve may not require plant shutdown or prevent startup. System requirements for operation will be per TS requirements.
Alternate Testina: In accordance with plant TS requirements.
3.1.1.1.2 Evaluation--S IWV-3416 states that the exercising test schedule need not be followed for valves located in systems that have been declared inoperable or are not required to be operable. This can permit the elapsed time since the last test of safety-related valves to be greater than the Code test frequency. The valves exempted from testing by this exclusion are required to be exercised within thirty days prior to the return of the associated system to operable status.
Apparently, the licensee is proposing to return out of service systems to operable status based upon the criteria of the TS and not necessarily comply with the Code requirement to exercise the safety-related valves in those systems prior to returning the system to operation. Returning an out of ,
service system to operation before all safety-related valves in the system <
have been tested may not be conservative or appropriate.
TS Limiting Conditions for Operation (LCO) do not specifically address each valve that performs a safety-related function or supports system operation. The TS are established with the consideration that safety-related valves are tested in accordance with Section XI requirements. Since deferring the testing of valves in systems out of service permits exceeding the Section XI test intervals and system maintenance and manipulations might have l affected the valves, the condition of these valves may not be known. l Therefore, compliance with plant TS may not be an adequate basis for returning 6
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a system with untested valves to operation. The licensee has not demonstrated that plant TS adequately cover the testing of all valves in out of service systems.
There may be cases where valves cannot be tested per the Code prior to the return of the system to operable status. However, the licensee's basis for relief does not address those cases or provide specific information that demonstrates the impracticality or burden of complying with this Code requirement for any of the affected valves. For these reasons, relief from the testing requirements of 1 IWV-3416 should not be granted.
1 IWV-3417(b) requires that if a valve fails a stroke time test, the action to repair the valve should start immediately. If the valve is not or cannot be repaired within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the valve is considered inoperative.
In addition, if the test failure occurs during CSD, the repairs must be made '
prior to startup. The NRC provided guidelines in GL 89-04, Position 8, that as soon as it is recognized that the measured stroke time exceeds the limiting stroke time, the valve is to be declared inoperable.
The plant TS provide the minimum system, subsystem, and component operability requirements for safe operation and have been reviewed and approved by the staff. Compliance with the plant TS would provide an acceptable level of quality and safety provided the TS specifically address the valve or its associated system and permit plant startup when the valve is inoperable. Because some shfety-related valves and their systems are not f specifically addressed in the plant TS, the effects of their inoperability may not be considered in an analysis. Therefore, plant operation with these components out of service may be unanalyzed and should not be permitted.
Based on the determination that compliance with the plant TS operability requirements should provide an acceptable level of quality and safety regarding plant startup with inoperable valves, the proposed alternative should be authorized pursuant to 9 50.55a 1 (a)(3)(i) with the following provisions. The TS must specifically address the valve or its associated system and permit plant startup when the valve is inoperable. Additionally, if corrective action for a valve is deferred under this relief request, prior to entering an operating mode where the valve is required to be operable, the valve should be repaired or replaced and successfully tested.
3.1.2 Stroke Times of Power-Operated Valves 3.1.2.1 Relief Reouest. PV-33 requests relief from the stroke time corrective action requirements of Section XI, 1 IWV-3417(a), for all power-operated valves in the IST program. The licensee proposes to base the " Alert" l corrective action requirements on deviations from reference stroke times l determined when the valve is known to operating acceptably rather than on the 1 previous test values. l 3.1.2.1.1 Licensee's Basis for Reouestino Relief--NRC GL 89-04 states that measuring changes in stroke times from a reference value as opposed to measuring changes from the previous test is an acceptable alternative for valves with stroke times of ten seconds or less. The NRC further stated in response to questions on GL 89-04 that the use of reference valve stroke times as a baseline for comparison of routine test stroke times j l
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is a better method of evaluating changes in valve performance (including valves with stroke times over 10 seconds) than that required by the ASME Code (IWV-3400). ASME OM-10 specifies the use of reference values for comparison of routine test stroke times.
Alternate Testina: Use reference values determined when the valve is known to operating acceptably as the baseline for evaluating routine test stroke times for corrective action.
3.1.2.1.2 Evaluation: The Code requires stroke timing of power operated valves quarterly, or during CSDs if quarterly testing is impractical.
This testing helps to identify valve degradation. Position 5 of GL 89-04 provides guidance for developing limiting values of full-stroke times for power-operated valves. It states in part, "The limiting value of full-stroke time should be based on the valve reference or average stroke time of a valve when it is known to be in good condition and operating properly." Further, OH-10, Subsection 4.2.1.8, uses deviations from stroke time reference values to determine valve operational readiness.
The licensee proposes to determine reference stroke times for valves when they are known to be operating acceptably. Stroke times measured during testing will be compared to those reference values and the acceptance criteria. Corrective action, as specified in 1 IWV-3417(a), will be taken if required. This is consistent with the recommendations of GL 89-04, Position 5, and OH-10, Subsection 4.2.1.8. The staff imposed no limitations to 0M-10 associated with the stroke time measurement requirements for power-operated valves. Therefore, the licensee's proposal to use reference stroke times for comparison with test data should provide an acceptable level of quality and safety. However, the implementation must include all applicable and related requirements of OM-10 (1s 1.3, 3.1 through 3.6, and 4.2.1.3 through 4.2.1.6).
Relief is no longer required, related to the use of reference stroke times, based on the rulemaking effective September 8, 1992, pursuant to s 50.55a 1 (f)(4)(iv), provided the licensee implement all related requirements of OM-10. Whether all related requirements are met is subject to NRC inspection.
3.2 Main Steam System 3.2.1 Cateaory A Valves 3.2.1.1 Relief Reauest. PV-32 requests relief from the fail-safe test frequency requirements of Section XI, 1 IWV-3415, for the inboard main steam isolation valves (MSIVs), FCV-1-14, -26, -37, and -51. The licensee proposes to fail-safe test these valves during CSDs when the containment does not remain inerted and during refueling outages.
3.2.1.1.1 Licensee's Basis for Reauestino Relief--The fail-safe testing of these MSIVs requires the isolation of control air to the valve operator and the venting of the control air accumulator for the valve. The MSIV, the control air isolation valve, and accumulator are located inside primary containment. Entry is precluded during operation because the containment atmosphere is inerted with nitrogen gas for oxygen control. In 8
addition, the inert atmosphere is maintained during short duration CSD periods when entry into containment is not mandatory. The extended downtime and the cost required to purge the containment vessel to allow entry for the test and to re-inert the vessel prior to restart place an operational and financial hardship on the utility without a commensurate increase in safety.
Alternate Testina: The fail-safe function of these valves will be tested at each CSD during which the containment vessel atmosphere does not remain inerted, provided they have not been tested within the previous three months.
Should the containment vessel atmosphere remain inerted for an entire fuel cycle, these valves will be tested at a minimum of once each refueling outage.
3.2.1.1.2 Evaluation--Y IWV-3415 requires that valves with fail-safe actuators be tested by observing the operation of the valves upon loss of actuator power. This testing provides asserance that the valves are capable of exercising to their required fail-safe positions upon loss of actuating electrical, pneumatic, and/or hydraulic supply. The licensee proposes to verify the fail-safe function of these valves during those CSDs when the containment is deinerted and during refueling outages.
It is impracticable to fail-safe test these valves quarterly during power operations because this requires isolating the control air to the MSIVs and venting off the accumulators. The MSIVs, the MSIV accumulators, and the control air isolation and vent valves are located inside containment, which is required to be inerted during power operations. Entering this oxygen deficient atmosphere would pose a personnel safety hazard. The containment is maintained inerted during most CSDs due to the large amount of nitrogen and the time required to re-establish the inerted atmosphere. Deinerting containment solely to fail-safe test these valves would be excessively burdensome to the licensee. Therefore, it is impracticable to enter containment to perform this testing during those CSDs when the containment is not deinerted for other reasons.
In rulemaking to 5 50.55a effective September 8,1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of & 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as '
specified in OM-10. 6 50.55a,1 (f)(4)(iv), provides that IST of valves may -
meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of 9 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OM-10, 1 4.2.1.6 specifies that fail-safe testing is to be performed in accordance with the exercising frequency of 1 4.2.1.1. 1 4.2.1.2 permits '
deferral of exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to OM-10 associated with the test frequency requirements for Category A or B valves. Accordingly, the licensee's proposed alternate ,
testing is in compliance with the rulemaking effective September 8,1992, and ;
relief is not required. Therefore, it is recommended that the alternative be I approved pursuant to s 50.55a 1 (f)(4)(iv), provided the licensee implements !
all related requirements, which includes 1s 4.2.1.2(h) and 6.2 of OM-10. l Whether all related requirements are met is subject to NRC inspection. j l
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O 3.2.2 Lateaory BC Valves 3.2.2.1 Relief Reouest. PV-6 requests relief from the test frequency and stroke time measurement requirements of Section XI, 1s IWV-3411, -3412, !
and -3413, for the main steam automatic depressurizatinn system (ADS) valves, 1(2)-PCV-1-5, -19, -22, -30, -31, -34, 3-PCV-1-5, -18, -19, -22. -34, and -41.
The licensee proposes to exercise them during refueling outages and to verify valve operation by observing an indication of steam flow through each valve.
Valve stroke times will not be measured.
3.2.2.1.1 Licensee's Basis for Reouestina Relief--The six safety relief valves assigned to the ADS system perform an essential safety function when operated by the pneumatic actuator with gas supplied through the ADS solenoid valves. Operation of these valves is not practical during power operations because this action will vent main steam to the suppression pool, inducing a transient condition and increasing the potentiality for an open failure of a safety relief valve. Also, no stroke timing is practical as these are pneumatic assisted SRVs. Since " position indication" of the SRVs is provided by acoustic monitors attached to the valve discharge piping, exercising during CSD cannot be accomplished because of lack of steam flow (and attendant noise).
Alternate Testina: The ADS valves will be exercised once each operating cycle in accordance with TS 4.6.D.2 which provides manual opening of each ADS valve observing an indication of steam flow through each valve.
3.2.2.1.2 Evaluation--These valves are connected to the main steam lines upstream of the MSIVs and discharge to the suppression pool.
Full-stroke exercising them quarterly during power operations is inpractical as this may result in a loss-of-coolant accident and an increase in suppression pool temperature. Reactor steam pressure is necessary to full-stroke exercise these valves, therefore, exercising is not practical during CSDs when the reactor pressure is low. NUREG-0626 " Generic Evaluation of Feedwater Transients and Small Break Loss-of-Coolant Accidents in GE-Designed Operating Plants and Near Term Operating License Applications" recommends reduction of challenges to relief valves to lessen the risk of a small break LOCA (see also NUREG-0737,Section II.K.3.16).
Valve or system redesign would be necessary to permit testing these valves at the Code specified frequency. Making these modification would be burdensome for the licensee. The licensee proposes to exercise these valves ,
once each operating cycle with the reactor at power by passing reactor steam through the valves and to verify the valve opens by monitoring steam flow through each valve. ASME/ ANSI OMa-1988, Part 10, Subsection 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this ;
exercising is not practicable during plant operation or CSDs, therefore, this ,
frequency is appropriate. 1 These safety / relief valves operate rapidly, on the order of 100 milliseconds, and are not equipped with direct sensing position indication. Further, their stroke times are dependent on system parameters i such as steam pressure. Therefore, trending the stroke times for ttese valves ;
may not be meaningful since test-personnel response times and variations in i system parameters could mask changes in valve condition. However, the intent i 10
of stroke time measurements is to monitor for degradation and not monitoring for degradation of these valves is unacceptable.
The licensee should develop a method to obtain repeatable stroke times for these valves or propose some other method to adequately monitor for valve degradation. It may be possible to demonstrate that following enhanced maintenance procedures during the periodic refurbishment of these valves provides adequate assurance that the valves are not degraded. If stroke time measurements are used to monitor for valve degradation, the licensee should assign a maximum stroke time limit to these valves that is based on test data and verify that they stroke within that limit during testing. The measured stroke times need not be trended or compared to previous values, but if the maximtim limit is exceeded, the valve should be declared inoperable and corrective action taken in accordance with j IWV-3417(b). An interim period of one year or until the next refueling outage, whichever is longer, should be provided to allow the licensee time to develop a method to monitor for valve degradation. The licensee's proposed exercise test should provide an acceptable level of quality and safety during this interim period.
Based on the determination that the combination of the proposed exercise test of these valves and the periodic maintenanco and refurbishment should provide an acceptable level of quality and safety during the interim period, we recommend the proposed alternative be authorized pursuant to 6 50.55a 1 (a)(3)(i) for one year or until the next refueling outage, whichever is longer. At the end of the interim period, the licensee should implement a-method of stroke timing these valves as discussed above or propose some other method to adequately monitor for valve degradation.
3.2.3 Cadeaory C Valves 3.2.3.1 Relief _BfLqu_qtt. PV-7 requests relief from the test frequency requirements of Section XI, 1 IWV-3521, for the main steam relief valve discharge pipe vacuum breaker check valves (listed in the request). The ;
licensee proposes to manually full-stroke exercise these valves during CSDs 1 when the drywell atmosphere is deinerted and during refueling outages.
3.2.3.1.1 Licensee's Basis for Reauestina Relief--These valves are located in the drywell and access during operation is not practical. The drywell is inerted with nitrogen, and entry would involve personnel safety hazards or deinerting.
Alternate Testing: Valve will be proven to move freely throughout the full range by manually cycling. In cases during CSD when drywell entry is made, these valves will be tested with the other CSD valves (i.e., time permitting) with a minluum of each refueling.
3.2.3.1.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is ,
impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to full-stroke exercise these valves open during CSDs when the drywell atmosphere is deinerted and during refueling outages by manually moving the disks through their full range.
11
CD It is impracticable to exercise these valves quarterly during power operations because the drywell atmosphere is required to be inertcM (oxygen deficient) during this plant mode, which makes entry by personnd W perform this testing impractical due to'the safety hazards of entering this environment. The drywell atmosphere is maintained inerted during many CSDs.
Deinerting the drywell and subsequently restoring i? to the required inert condition requires large amounts of nitrogen gas and +'ca. Requiring the licensee to deinert the drywell atmosphere each CSD solely to test these valves could cause a delay in returning the plant to operation and would be unduly burdensome.
In rulemaking to s 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of 5 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in LM-10. s 50.55a,1 (f)(4)(iv), provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of s 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OH-10, 1 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to OH-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8, 1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to s 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes 1s 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are met is subject to NRC inspection.
l 33 Feedwater System 3.3.1 Cateaory AC Valves 3.3.1.1 Relief Reouest. P'l-8 requests relief from the test frequency ,
requirements of Section XI,1 IWV-3521, for the feedwater header check valves, !
3-554, -558, -568, and -572. The licensee proposes to verify closure of these i valves by performing Appendix J leak rate testing each refueling outage. l 3.3.1.1.1 Licensee's Basis for Reouestina Relief--All four check valves remain open, maintaining the flow path to the reactor vessel whenever the feedwater/ condensate systems are supplying feedwater to tne reactor vessel. When RCIC or reactor water cleanup system (RWCU) are returning flow to the reactor vessel, check valve 3-572 remains open. When HPCI is injecting l to the vessel, check valve 3-558 remains open. Due to the necessity of ,
maintaining this flow path in virtually all modes of operation, closure. l testing is only practical during extended outages such as refueling during which these systems are shutdown. Also, plant design does not provide a practical means of demonstrating closure other than by upstream pressurization performed during leak rate testing in accordance with Appendix J, 10 CFR 50. l This testing involves significant effort for installation of temporary l l
12 l
_ _ _ ._- _ _ _ _i
equipment, and requires entry into an inerted reactor containment. Such entry into containment poses a hazard to personnel safety or deinerting.
Alternate Testino: Valve closure will be verified by completion of local leak l rate testing performed in accordance with 10 CFR 50, Appendix J, at each refueling outage.
3.3.1.1.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to verify closure of these valves by performing Appendix J leak rate testing each refueling outage.
It is impracticable to exercise these valves closed quarterly during power operation because normal feedwater flow passes through them into the reactor vessel and interrupting this flow would cause disturbances in vessel level control and possibly result in a plant trip. Additionally, to perform this testing it is necessary to enter the drywell ad the drywell atmosphere is required to be inerted (oxygen deficient) durir; power operation, which j makes entry impractical due to personnel safety hazards. The drywell j atmosphere is maintained inerted during many CSDs. Deinerting the drywell and j subsequently restoring it to the required inert condition requires large ,
amounts of nitrogen gas and time. This testing also requires installation and i removal of temporary equipment and would take a significant amount of time to !
perform. Requiring the licensee to deinert the drywell atmosphere, install !
the special test equipment, perform the leak rate test, restore the system to '
operation, and reestablish the required drywell atmosphere conditions each CSD could cause a delay in returning the plant to operation and would be unduly burdensome.
l In rulemaking to N 50.55a effective September 8, 1992, the 1989 Edition i of ASME Section XI was incorporated in 1 (b) of 9 50.55a. The 1989 Edition of 1 Section XI provides'that the rules for inservice testing of valves are as l specified in OM-10. 5 50.55a, 5 (f)(4)(iv), provides that IST of valves may ,
meet the requirements set forth in subsequent editions and addenda that are l incorporated by reference in 1 (b) of 5 50.55a, subject to the limitations and l modifications listed, and subject to NRC approval. Portions of editions or l addenda may be used provided that all related requirements of the respective editions or addenda are met.
0M-10, 3 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to OH-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in conpliance with the rulemaking effective September 8, 1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to 6 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes ss 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are met is subject to NRC inspection.
13 w
3.4 Standby Liouid Control System 3.4.1 Cateoory AC Valves 3.4.1.1 Relief Reouest. PV-9 requests relief from the test frequency requirements of Section XI, 1 IWV-3521, for the SLC injection line check valves,63-525 and -526, and proposes to full-stroke exercise them open and closed each refueling outage.
3.4.1.1.1 Licensee's Basis for Reouestino Relief--To verify proper opening of these check valves, it is necessary to pass fluid through each valve. This action would result in an injection into the vessel and would require actuation of an explosive valve, both undesirable during power operations. Closure testing is only practical by pressurizing downstream of the valve (the upstream side being vented) and verifying absence of flow in the upstream side. This requires installation of temporary equipment and access to the containment which is inerted during power operation.
Alternate Testina: The proper functioning of the SLC system injection flow path, including opening of 63-525 and 63-526, will be demonstrated once each operating cycle in accordance with TS. Proper valve closure will be verified by completion of local leak testing performed in accordance with 10 CFR 50, Appendix J.
3.4.1.1.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational ,
readiness. The licensee proposes to exercise these valves open and closed by passing flow through them and performing Appendix J 1eak rate testing each refueling outage.
These check valves are in the common SLC injection line to the reactor vessel, downstream from the explosively actuated squib valves. It is impractical to full-stroke exercise these valves rpen with flow, either quarterly during power operation or at CSD. Initiation of system flow requires the firing of at least one squib valte, which destroys the valve.
Further, the system contains highly borated 9ater that would be introduced l into the reactor coolant system (RCS) and c.tuse a reactor shutdown if the i testing were performed during pt.wer operation. Extensive flushing must be 1 performed on the system to remove all iraces of the boron solution prior to initiating flow for exercising these valves. Performance of this testing during CSDs would be burdensome to the licensee since this testing could l result in an extension of the CSD. l In rulemaking to G 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of s 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as 2 soecified in 0M-10. 5 50.55a, 1 (f)(4)(iv), provides that IST of valves may I meet the requirements set forth in subsequent editions and addenda that are l incorporated by reference in 1 (b) of 5 50.55a, subject to the limitations and !
modifications listed, and subject to NRC approval. Portions of editions or l addenda may be used provided that all related requirements of the respective !
editions or addenda are met.
14 l l
l l
OH-10, 5 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to OH-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to 5 50.55a 5 (f)(4)(iv), provided the licensee implements all related requirements, which includes ss 4.3.2.2(h) and 6.2 of OH-10. Whether all related requirements are met is subject to NRC inspection.
3.5 (pntrol Rod Drive System 3.5.1 Cateaory AC Valves 3.5.1.1 Relief Reauest. PV-10 requests relief from the test frequency requirements of Section XI, 5 IWV-3521, for the control rod drive (CRD) supply to reactor recirculation pump seal injection inboard and outboard containment isolation check valves,68-508, -523, -550, and -555. The licensee proposes to verify closure of these valves by performing an Appendix J leak rate test at refueling outages.
3 5.1.1.1 Licensee's Basis for Reauestina Relief--These check .
valves serve as inboard and outboard CIVs. The valves are not equipped with '
remote indication, and there is no pressure indication downstream of the val ves. For these valves, closure testing is only practical through pressurization downstream of the valve, with the upstream piping vented and verification of the absence of flow upstream. Interruption of the CRD flow ;
(seal injection) is required to perform this testing, and during reactor J recirculation pump operation, could result in seal damage. This type of testing can only be performed during a period when the containment is q accessible. The deinerting of the containment will only be performed during !
major outages. Based on the impact of having to install temporary test equipment, the required testing will be performed during Category A leak rate testing.
Alternate Testina: Proper valve closure will be verified by completion of l local leak rate testing performed in accordance with 10 CFR 50.
3.5.1.1.2 Evaluation--The Code requirr- a full-stroke exercise of safety-related check valves quarterly or during CSL; if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to verify closure of these valves each refueling outage in conjunction with the Appendix J leak rate test. 1 To exercise these valves closed it is necessary to stop CRD flow to the recirculation pump seals. Stopping seal water flow when a recirculation pump is operating could result in damage to the pump. It is impracticable to' '
exercise these valves quarterly during power operations because it would require stopping the recirculation pumps, which would result in a power reduction or plant trip. It is impractical to exercise these valves during CSDs because this would involve stopping the recirculation pumps and entering hazardous areas inside containment to perform complex test evolutions. This 15 i
O testing may take sufficient time to complete that it would result in a delay in returning the plant to power. ,
in rulemaking to j 50.55a effective September 8, 1992, the 1989 Edition :
of ASME Section XI was incorporated in 1 (b) of 9 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OH-10. S 50.55a, 5 (f)(4)(iv), provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 5 (b) of 6 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
0M-10, 5 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to 0M-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking i effective September 8, 1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to @ 50.55a ;
1 (f)(4)(iv), provided the licensee implements all related requirements, which includes 1s 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are met is subject to NRC inspection.
3.6 Reactor Water Cleanuo System J
3.6.1 Cateaory AC Valves 3.6.1.1 Relief Reouest. PV-Il requests relief from the test frequency requirements of Section XI, 1 IWV-3521, for the RWCU return line check valves, 1(2)-69-579 and 3-69-624. The licensee proposes to verify closure of these l valves during Appendix J leak rate testing at refueling outages. l 3.6.1.1.1 Licensee's Basis for Rcouestino Relief--This check valve remains open to return water to the reactor vessel whenever the RWCU !
system is operating. This valve is not testable whenever the RWCU, '
feedwater/ condensate, or RCIC system is returning flow to the reactor vessel.
Testing r quires entry into primary containment and the disruption of system flow (RVN feedwater/ condensate or RCIC). For these reasons, closure testing is only ptactical during extended outages such as refuelings during which these systems are shutdown. Also, plant design does not provide a practical means of demonstrating closure other than by upstream pressurization performad during leak rate testing conducted in accordance with 10 CFR 50 Appendix J.
This testing involves significant effort for installation of temporary equipment. This would require valve lineups to abnormal positions, J
installation of pressurizing equipment and associated test lines as well as deinerting the drywell for safe entry.
Alternate Testina: Proper valve closure will be verified by completion of local leak rate testing performed in accordance with 10 CFR 50, Appendix J.
3.6.1.1.2 Evaluation--The Code requires a full-stroke exercise'of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of 16
D moving to their safety function position (s) to assess their operational readiness. The licensee proposes to verify closure of these valves each refueling outage in conjunction with the Appendix J leak rate test.
To verify these valves closed using pressure or flow it is necessary to stop RWCU flow, feedwater flow, and RCIC flow. It is impracticable to exercise these valve: closed quarterly during power operations because it could disrupt reactor vessel level and RCS water chemistry control and result in a plant trip. It is impractical to exercise these valves closed during CSDs because this involves stopping RWCU flow and leak testing the valves or verifying closure using a non-intrusive technique. Leak testing requires a containment entry to pressurize the downstream piping. The primary containment is maintained inerted during many CSDs, therefore, entry for testing would be a personnel safety hazard. Even during CSDs when containment is deinerted, entering containment, setting up the special test equipment, conducting the test, returning the system to operation, and reestablishing the required water chemistry standards would take sufficient time that it could delay returning the plant to power.
In rulemaking to @ 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of Q 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OM-10. s 50.55a,1 (f)(4)(iv), provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of 5 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OM-10, 1 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant ,
operation or CSDs. The NRC staff imposed no limitations to 0M-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8, 1992, and relief is not required. Therefore, it is i recommended that the alternative be approved pursuant to @ 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes 1s 4.3.2.2(h) and 6.2 of OH-10. Whether all related requirements are l met is subject to NRC inspection. !
3.7 Reactor Buildina Closed Coolino Water System 3.7.1 Cateaory AC Valves l l
3.7.1.1 Relief Reauest. PV-15 requests relief from the test frequency i requirements of Section XI, 1 IWV-3521, for the check valve in the reactor i building closed cooling water (RBCCW) supply to the recirculation pump bearing and seal coolers,70-506. The licensee proposes to verify valve closure in conjunction with Appendix J 1eak rate testing during refueling outages.
3.7.1.1.1 Licensee's Basis for Reouestino Relief--This valve is in the cooling water supply for the reactor recirculation pump bearing and seal coolers. Testing this valve closed during power operation would interrupt this cooling water flow, possibly causing pump bearing damage or 17 l
l
seal failure. Due to the necessity of maintaining this flow path in virtually all modes of operation, closure testing is only practical during extended outages such as refuelings during which this system is shutdown. Plant design does not provide a practical means of demonstrating closure other than by downstream pressurization performed during leak rate testing. This testing involves significant effort for installation of temporary equipment, abnormal valve lineups for test boundaries, and complete purging of the inerted reactor containment.
Alternate Testina: Proper valve closure will be verified by completion of local leak rate testing performed in accordance with 10 CFR 50, Appendix J.
3.7.1.1.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to verify closure of this valve each refueling outage in conjunction with the Appendix J leak rate test.
To exercise this valve closed it is necessary to stop RBCCW flow to the recirculation pump bearing and seal coolers. Stopping recirculation pump bearing cooling water flow when a pump is in operation could result in damage to the pump. It is impracticable to exercise this valve quarterly during power operations because it would require stopping the recirculation pumps, which would result in a power reduction or plant trip. It is impractical to exercise this valve during CSDs because this would involve stopping the recirculation pumps and entering hazardous areas inside containment to perform complex test evolutions. This testing may take sufficient time to complete that it would result in a delay in returning the plant to power.
In rulemaking to @ 50.55a effective September 8, 1992, the 1989 Edition i of ASME Section XI was incorporated in 1 (b) of & 50.55a. The 1989 Edition of i Section XI provides that the rules for inservice testing of valves are as ,
specified in OM-10. s 50.55a,1 (f)(4)(iv), provides that IST of valves may I meet the requirements set forth in subsequent editions and addenda that are l incorporated by reference in 1 (b) of 5 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective
. editions or addenda are met.
OM-10, 1 4.3.2.2, permits deferral of full-stroke exercising until j refueling outages when this exercising is not practicable during plant operation or C; The NRC staff imposed no limitations to 0M-10 associated with the test freo"9ncy requirements for check valves. Accordingly, the licensee's propose ~ alternate testing is in compliance with the rulemaking effective September 8, 1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to 6 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes ss 4.3.2.2(h) and 6.2 of OH-10. Whether all related requirements are met is subject to NRC inspection.
l l
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3.8 Besidual Heat Removal System 3.8.1 Cateaory AC Valves 3.8.1.1 Relief Reouest. PV-25 requests relief from the test frequency requirements of Section XI, 5 IWV-3521, for the RHR injection to recirculation loop testable check valves, 74-54 and -68. The licensee proposes to full-stroke exercise these valves open using the test operator during CSDs when a drywell entry is made and during refueling outages.
3.8.1.1.1 Licensee's Basis for Reouestina Relief--Due to potentially inadvertent valve operation caused by non-class IE circuitry to the valve operator, the air supply is normally disconnected. Since these valves are located in containment, entry to connect the air supply is not -
practical during operation and may not be practical during CSD.
Alternate Testina: Valves will be stroked by reconnection of the actuator air in cases during CSD when drywell entry is made. This testing will be performed along with the other CSD valves (i.e., time permitting) with a
- minimum of each refueling.
3.8.1.1.2 Evaluation--The Code requires a full-stroke exercise of i safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to full-stroke exercise these valves open during CSDs when the drywell atmosphere is deinerted and during refueling outages by connecting the air supply to the test operators and using these operators to stroke the valve disks open. ;
l It is impracticable to exercise these valves quarterly during power operations because the RHR pumps do not develop sufficient head to establish flow into the RCS and the air supplies to the test operators are not connected to prevent inadvertent valve operation. Exercising these valves using the test operators requires entry into the drywell to reconnect the air supply to ;
the test operators. The drywell atmosphere is required ' 'a inerted during l power operations, which makes entry by personnel to pt.for~. t..is testing impractical due to the safety hazards of entering this oxygen deficient environment. The drywell atmosphere is maintained inerted during many CSDs.
Deinerting the drywell and subsequently restoring it to the required inert condition requires large amounts of nitrogen gas and time. Requiring the licensee to deinert the drywell atmosphere each CSD solely to test these valves could cause a delay in returning the plant to operation and would be unduly burdensome.
Relief Request PV-25 does not address exercising these valves open with fl ow. It appears that flow could be established through these valves during cooldown operation of the RHR system at CSDs. This flow path should not be used for long periods of time since it could allow cooling flow to short circuit (bypass) the reactor vessel. If testing these valves open with flow is practicable, it should be done during CSDs as required. If this testing is not practicable, the licensee should document the reason in their IST program within six months of receiving the SER.
19
In rulemaking to s 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of 9 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OH-10. 9 50.55a, 1 (f)(4)(iv), provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of 6 50.55a, subject to the limitations and modifications listed, and subject to NRC apprcval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OM-10, 1 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to 0M-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to 9 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes 1s 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are met is subject to NRC inspection. In addition, the licensee should evaluate the practicality of exercising these valves open with flow at CSDs in accordance with the Code. If it is practical to full-stroke exercise these valves open with flow at CSDs, this testing should be implemented within one year or by the next refueling outage, whichever is longer. The IST program should be updated as necessary to reflect changes.
3.8.1.2 Relief Reauest. PV-28 requests relief from the test frequency requirements of Section XI,1 IWV-3521, for the check valves that provide l thermal relief protection for the line between the RHR shutdown cooling ;
suction isolation valves,74-661 and -662. The licensee proposes to '
full-stroke exercise them open during CSDs when the drywell is deinerted and during refueling outages. These valves will be verified closed at refueling outages in conjunction with the Appendix J leak rate testing.
3.8.1.2.1 Licensee's Basis for Reauestino Relief--These valves !
provide thermal relief between the inboard and outboard shutdown cooling I suction valves. Cycling these valves by system manipulations is not possible !
during operations due to pressure interlocks which prevent the suction valves from opening. These valves are located in the containment drywell which is inerted during unit operation and which remains inerted during cold shutdown periods when dryweil entry is not required.
Alternate Testina: Proper valve open 69 will be tested at CSD when drywell entry and adequate time permit. Vaive closure will be demonstrated at each refueling outage by the performance of 10 CFR 50 Appendix J leakage rate testing.
3.8.1.2.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to exercise these valves open at CSDs when the drywell is deinerted and during refueling outages. These valves will be 20
verified closed each refueling outage in conjunction with the Appendix J leak rate testing.
These valves and their associated test connections are located inside the drywell. It is impractical to exercise them open or closed during power operations because the drywell is required to be inerted during this mode of operation. It would be hazardous for test personnel to enter the inerted drywell to perform testing. The drywell is maintained inerted during many CSDs. Deinerting the drywell, setting up test equipment, establishing test conditions, performing the testing, and restoring the system and the drywell atmosphere to required conditions, requires a great quantity of nitrogen and is time consuming. Performing this testing each CSD could delay returning the plant to power operation, which would be a hardship to the licensee.
In rulemaking to 9 50.55a effective September 8,1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of 9 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OH-10. @ 50.55a, 1 (f)(4)(iv), provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of & 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OH-10, 1 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to OH-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to @ 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes ss 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are met is subject to NRC inspection.
Regarding the test method, these check valves are installed in series with each other with no test connections between the series pair, therefore, they can only be leak rate tested as a pair. If excessive leakage is experienced through the series check valve pair, both valves would have to be in a degraded condition, therefore, both should be repaired or replaced as necessary.
3.9 [ ore Sorav System 3.9.1 Cateaory AC Valves j 3.9.1.1 [Lelief Reauest. PV-25 requests relief from the test frequency requirements of Section XI,1 IWV-3521, for the core spray injection testable check valves, 75-26 and -54. The licensee proposes to exercise these valves open during CSDs when the drywell is deinerted and during refueling outages using the valve test operators.
3.9.1.1.1 Licensee's Basis for Reouestina Relief--Due to potentially inadvertent valve operation caused by non-class IE circuitry to 21 i
1
4 .
the valve operator, the air supply is normally disconnected. - Since these :,
valves are located in containment, entry to connect the air-supply is not practical during operation and may not be practical during CSD.
Alternate Testina: Valves will be stroked by reconnection of the actuator air #
in cases during CSD when drywell entry is made. This testing will be performed along with the other CSD valves (i.e., time permitting) with a minimum of each refueling.
3.9.1.1.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational .
readiness. The licensee proposes to full-stroke exercise these valves open during CSDs when the drywell atmosphere is deinerted and during refueling outages by connecting the air supply to the test operators and using these operators to stroke the valve disks open.
It is impracticable to. exercise these valves quarterly during power-operations because the core spray pumps do not develop sufficient head to establish flow into the RCS and the air supplies to the' test operators are not connected to prevent inadvertent valve operation. Exercising these valves using the test operators requires entry into the drywell to reconnect the air '
4 supply to the test operators. The drywell atmosphere is required to be inerted during power operations. This makes entry by personnel to perform this testing impractical due to the safety hazards of entering this oxygen deficient environment. The drywell atmosphere is maintained inerted during '
many CSDs. Deinerting the drywell and subsequently restoring it to the required inert condition requires large amounts of nitrogen gas and time.
Requiring the licensee to deinert the drywell atmosphere each CSD solely to test these valves could cause a delay in returning the plant to operation and would be unduly burdensome.
Relief Request PV-25 does not address exercising these valves open with e flow. It appears that flow could be established through these valves during CSDs. If testing these valves open with flow is practicable, it should be done during CSDs as required. If this testing is not practicable,-the - -
licensee should document the reason in their IST program within six months of receiving the SER.
4 In rulemaking to 6 50.55a effective September 8,.1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of 9 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in OM-10. s 50.55a,1 (f)(4)(iv), provides that IST of-valves may .
meet the requirements set forth in subsequent editions.and addenda that are incorporated by reference in 1 (b) of 5 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or :
addenda may be used provided that all related requirements of the respective editions or addenda are met.
OH-10, 1 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to OH-10 r ;ociated with the test frequency requirements for check valves. Accordingly, the 22
1 l
l licensee's proposed alternate testing is in compliance with the rulemaking l effective September 8,1992, and relief is not required. Therefore, it is ;
recommended that the alternative be approved pursuant to 9 50.55a 1 1 (f)(4)(iv), provided the licensee implements all related requirements, which l includes 1s 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are i met is subject to NRC inspection. In addition, the licensee should evaluate l the practicality of exercising these valves open with flow at CSDs in i accordance with the Code. If it is practical to full-stroke exercise these valves open with flow at CSDs, this testing should be implemented within one l year or by the next refueling outage, whichever is longer.
3.10 HPC1/RCIC Systems 3.10.1 Cateaory A Valves 3.10.1.1 Relief Recuest. PV-20 requests relief from the leak test differential pressure requirements of Section XI, 1 IWV-3423, for the HPCI and RCIC turbine steam supply and RCIC steam bypass to condenser isolation valves, FCV-1-55, 2, and 2. The licensee proposes to leak rate test these valves with pressure applied in the reverse direction. The leak rate testing will otherwise be performed in accordance with Appendix J and IWV-3426 and
-3427(a).
3.10.1.1.1 Licensee's Basis for Recuestina Relief--The subject valves are the first valves off the reactor in each of their respective piping sections. Due to this location in the piping system, the normal procedure of leakage rate testing by pressurizing the piping volume between two or more valves is not possible. It is impractical to perform leakage rate tests on these valves by pressurizing them from the reactor vessel side.
Alternate Testina: The plant containment leak rate testir.g program (for compliance with 10 CFR 50 Appendix J requirements) has established a leakage rate testing procedure which pressurizes each of these valves in the reverse direction. This test method shall be utilized in lieu of the requirements of IWV-3421 through -3425. The requirements of IWV-3426 and -3427(a) will be met. ,
3.10.1.1.2 Evaluation--These valves are Category A and perform a containment isolation function. 1 IWV-3423 requires that single wedge gate valves be leak rate tested with the pressure differential in the same direction as when the valve is performing its function. 10 CFR 50, Appendix J, also requires that the pressure be applied in the same direction as when the valve would be required to perform its safety function, unless it can be determined that the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative results. The licensee proposes to leak rate test these valves with the differential pressure in the reverse direction.
GL 89-04 and OM-10 permit testing of CIVs in accordance with 9 50, Appendix J. GL 89-04 and the rulemaking of September 8, 1992, also prescribe additional requirements for Analysis of Leakage Rates and Corrective Action for CIVs. Therefore, these valves may be tested in accordance with Appendix J and 1s IWV-3426 and -3427(a).
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An SE transmitted by a letter from D. G. Eisenhut to H. G. Parris, dated October 24, 1984, determined that an exemption to the Appendix J test direction requirement is not acceptable because it does not meet the equivalent or more conservative results criteria. The SE concluded that the fact that plant design does not currently permit testing in the direction of accident pressure is not, in itself, sufficient justification for an exemption from the requirements and intent of Appendix J. Approval of a requested deviation from the ASME Code requirements (IST relief request), does not constitute an exemption from the 9 50, Appendix J, requirements. An exemption should be requested and approved for any deviation from the Appendix J requirements. ;
Accordingly, leak rate testing these valve in accordance with Appendix J and 5s IWV-3426 and -3427(a) is approved by GL 89-04 and by rulemaking.
3.10.2 Cateaory AC Valves ;
3.10.2.1 Relief Reouest. PV-17 requests relief from the test frequency l requirements of Section XI,1 IWV-3521, for the HPCI and RCIC turbine exhaust line check valves,73-603, -609,71-580, and -592. The licensee proposes to verify the closure of these valves during -refueling outages in conjunction with the Appendix J leak rate testing.
3.10.2.1.1 Licensee's Basis for Reouestina Relief--These check valves are not equipped with position indication, and system design does not provide any practical method of verifying closure other than pressurization similar to leak rate testing. Such testing requires installation of temporary equipment which is impractical on a quarterly basis, and it would render the system inoperable during the testing period. Additionally, the valve location (top of torus) cctld present a personnel safety hazard during operation.
Normally, testing of this type is accomplished by required containment local leak rate testing in accordance with Appendix J.
Al ter natelq1thg: Proper valve closure will be verified by completion of local leak rate tes. ting performed in accordance with 10 CFR 50, Appendix J.
3.10.2.1.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to verify closure of these valves each refueling outage in conjunction with the Appendix J 1eak rate test.
To verify these valves closed using pressure or flow it is necessary to ,
remove the HPCI/RCIC system from operation and pressurize the exhaust header i downstream of the valve. These valves are located on top of the torus and testing during power operations could present a personnel safety hazard. It may be impractical to verify closure of these valves during CSDs because it involves leak testing the valves or using a non-intrusive technique and both are involved procedures and may result in a delay in returning the plant to )
power operation.
The licensee should evaluate leak testing and non-intrusive techniques to determine if it is feasible to verify the closure of these valves during 24
l . .
CSDs. If it is feasible to perform this testing at the Code frequency, this testing should be performed as required. If the licensee determines that performing this testing at the Code frequency is impractical or a hardship without a compensating increase in the level of quality and safety, this should be documented in the IST program.
In rulemaking to @ 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of 5 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in 0M-10. S 50.55a,1 (f)(4)(iv), provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of S 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OM-10, 1 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant ,
operation or CSDs. The NRC staff imposed no limitations to OH-10 associated with the test frequency requirements for check valves. Accordingly, the licensee's proposed alternate testing is in compliance with the rulemaking effective September 8,1992, and relief is not required. Therefore, it is recommended that the alternative be approved pursuant to s 50.55a 1 (f)(4)(iv), provided the licensee implements all related requirements, which includes 1s 4.3.2.2(h) and 6.2 of OM-10. Whether all related requirements are met is subject to NRC inspection. In addition, the licensee should evaluate l the feasibility of testing these valves during C50s. If it is practical to verify valve closure at the Code specified frequency, this testing should be implemented within one year or by the next refueling outage, whichever is longer. The IST program should be updated as necessary to reflect changes.
3.11 Containment Inertina System 3.11.1 Category AC Valves 3.11.1.1 Relief Reauest. PV-24 requests relief from the test frequency requirement of Section XI, 1 IWV-3521, for the containment inerting I containment isolation check valves,76-653. The licensee proposes to verify closure of these valves during refueling outages in conjunction with the Appendix J 1eak rate testing.
3.11.1.1.1 Licensee's Basis for Reauestina Relief--This purge check valve serves as an outboard containment isolation valve. Testing of this valve requires entry into primary containment disconnection of the purge line for installation of test equipment. Because of the plant design, demonstrating closure can only practically be accomplished by pressurizing downstream, as is performed during leak rate testing in accordance with 10 CFR 50 Appendix J. Conducting such a test would therefore pose a hazard to personnel safety or require the deinerting of containment for safe entry and would also require the depressurization of the purge line which could result in the introduction of moisture in these lines.
Alternate Testina: Proper valve closure will be verified by completion of local leak rate testing performed in accordance with 10 CFR 50 Appendix J.
25 l
3.11.1.1.2 Evaluation--The Code requires a full-stroke exercise of safety-related check valves quarterly or during CSDs if quarterly testing is impractical. This testing is to demonstrate that the valves are capable of moving to their safety function position (s) to assess their operational readiness. The licensee proposes to verify closure of these valves each refueling outage in conjunction with the Appendix J leak rate test.
It is impractical to excrcise these valves closed quarterly during power operations or during CSDs because this involves stopping purge flow and leak testing the valves or verifying closure using a non-intrusive technique. Leak testing requires a containment entry to pressurize the downstream piping. The primary containment is required to be inerted during power operations and is maintained inerted during many CSDs. therefore, entry for testing would be a '
personnel safety hazard. Even during CSDs when the containment is deinerted, entering containment, setting up the special test equipment, conducting the test, and returning the system to operation could take sufficient time that it would delay returning the plant to power.
In rulemaking to s 50.55a effective September 8, 1992, the 1989 Edition of ASME Section XI was incorporated in 1 (b) of & 50.55a. The 1989 Edition of Section XI provides that the rules for inservice testing of valves are as specified in 0M-10. s 50.55a, 1 (f)(4)(iv), provides that IST of valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 1 (b) of 9 50.55a, subject to the limitations and modifications listed, and subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.
OH-10, 1 4.3.2.2, permits deferral of full-stroke exercising until refueling outages when this exercising is not practicable during plant operation or CSDs. The NRC staff imposed no limitations to OH-10 associated ;
with the test frequency requirements for check valves. Accordingly, the {
licensee's proposed alternate testing is in compliance with the rulemaking ;
effective September 8,1992, and relief is not required. Therefore, it is ;
recommended that the alternative be approved pursuant to @ 50.55a l 1 (f)(4)(iv), provided the licensee implements all related requirements, which ,
includes 1s 4.3.2.2(h) and 6.2 of OH-10. Whether all related requirements are i met is subject to NRC inspection.
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A e --- _ - .. 4.-*4A- - J 4- y I
APPENDIX A '
IST PROGRAM AN0MALIES J
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A-1 i
-, . .J.,
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APPENDIX A IST PROGRAM AN0MALIES i
During the review of the licensee's submittals, inconsistencies and omissions were noted among the relief requests that are part of the licensee's second ten-year interval IST program submittal, dated August 31, 1992. These issues are summarized below. l l
- 1. The IST program does not include a description of how the components were selected and how testing requirements were identified for each component. The review performed for this Safety Evaluation (SE)/TER did not include verification that all pumps and valves within tha scope of 10 CFR 50.55a and Section XI are contained in the IST program, and did not ensure that all applicable testing requirements have been identified. Therefore, the licensee is requested to include this information in the IST program. The program should describe the !
development process, such as a listing of the documents used, the method of determining the selection of components, the basis for the testing required, the basis for categorizing valves, and the method or process used for maintaining the program current with design modifications or other activities performed under 10 CFR 50.59. l
- 2. Many of the licensee's relief requests were difficult to interpret, particularly in the " Basis for Relief" and " Proposed Alternate Testing and Frequency" sections. The basis section should clearly state the need (according to the regulations) for relief. Problems with the licensee's bases fit into three categories: the basis was either not complete and clear, not entirely applicable, or did not establish impracticality, burden, or hardship. Also, the specific reasons that ,
support the granting of relief were not thoroughly and clearly stated.
In several requests some aspect of the proposed alternate testing was either unclear or not stated. The proposed testing must be assessed to determine if it is equivalent to or better than the Code required i testing, or if it provides a reasonable alternative for cases where the i Code-required testing is impractical or a hardship. If the proposed testing is not adequately described, it cannot be fully assessed ,
according to the regulations. In some cases, the frequency of testing _i was not specified. Relief cannot be granted according to the j regulations to test at an undefined frequency. The licensee should -
review each relief request against these criteria prior to submittal to ;
the NRC for consideration.
i
- 3. Several of the licensee's relief requests (PV-13, PV-14, PV-18, PV-19, 1 PV-21, PV-23, PV-27, PV-29, PV-30, and PV-35) are approved by GL 89-04 and are not evaluated in this TER. The licensee indicated compliance with GL 89-04, but did not specifically address all aspects of the Generic letter provisions in the requests. In these cases, it is assumed that the licensee is complying with all of the requirements of the applicable GL 89-04 positions. Relief is not granted for the above relief requests for testing that deviates from that prescribed in GL 89-
- 04. Whether the licensee complies with the provisions of GL 89-04 is subject to NRC inspection. If the licensee intends to deviate from a A-2 l
GL 89-04 position, a revised relief request must be submitted for review and approval prior to implementing the testing. ,
- 4. PV-4 requests relief from the testing requirements of Section XI for valves in systems out of service that are being returned to service and for valves tested at CSD that require corrective actions due to stroke time measurements. The licensee proposes to determine system requirements for operation from the TS requirements. Since deferring the testing of valves in systems out of service permits exceeding the I Section XI test intervals and system maintenance and manipulations might I have affected the valves, the condition of these valves may not be l known. Therefore, compliance with plant TS may not be an adequate basis for returning a system with untested valves to operation. The licensee has not demonstrated that plant TS adequately cover the testing of all valves in out of service systems. There may be cases where valves l cannot be tested per the Code prior to the return of the system to I operable status. However, the licensee's basis for relief does not address those cases or provide specific information that demonstrates the impracticality or burden of complying with this Code requirement for any of the affected valves. For these reasons, general relief from the testing requirements of 1 IWV-3416 should not be granted and the licensee should comply with this requirement. The licensee should submit for review specific information that supports the granting of relief for certain valves that cannot be tested prior to operation.
1 IWV-3417(b) requires that if a valve fails a stroke time test, the action to repair the valve should start immediately. In addition, if the test failure occurs during CSD, the repairs must be made prior to startup. The plant TS provide the minimum system, subsystem, and component operability requirements for safe operation and have been reviewed and approved by the staff. Compliance with the plant TS would I provide an acceptable level of quality and safety provided the TS specifically address the valve or its associated system and permit plant startup when the valve is inoperable. Because some safety-related valves and their systems are not specifically addressed in the plant TS, the effects of their inoperability may not be considered in an analysis.
Therefore, plant operation with these components out of service may be unanalyzed and should not be permitted. Additionally, if corrective action for a valve is deferred under this relief request, prior to entering an operating mode where the valve is required to be operable, the valve should be repaired or replaced and successfully tested.
(Refer to Section 3.1.1.1 of this report)
- 5. Many of the licensee's relief requests (PV-8, PV-10, PV-11, PV-15, PV-17, PV-22, PV-24, and PV-28) indicate that the closure of the affected check valves will be verified by performing an Appendix J leak l rate test. The requests demonstrate the impracticality of performing the leak test quarterly and during CSDs, however, they do not specifically address other test methods. In many of these cases, verifying valve closure using another technique would likely be impractical for the same reason (s) that leak testing is impractical. In other cases, there may be other reasons that it is impractical to verify closure using an alternate method. However, this is not documented in the IST program.
A-3
Several testing techniques have recently been shown to be capable of providing reliable indication of check valve closure without disturbing the valve or the associated system. Some examples of these techniques are acoustics, magnetics, ultrasonics, thermography, and radiography.
The licensee should evaluate the use of non-intrusive techniques to determine if it is feasible to use one or more of them to verify the closure of the affected check valves qcarterly or during CSDs. If it is practical to verify valve closure at the Code specified frequency, this testing should be implemented within one year or by the next refueling outage, whichever is longer. The IST program should be updated as necessary to reflect changes. If the licensee determines that performing this testing at the Code frequency is impractical or a hardship without a ccmpensating increase in the level of quality and safety, this should be documented in the IST program. (Referto Sections 3.3.1.1, 3.5.1.1, 3.6.1.1, 3.7.1.1, 3.8.1.2, 3.10.2.1, and 3.11.1.1 of this report)
- 6. Valve relief requests PV-13, PV-14, PV-18, PV-19, PV-29, and PV-30 are for check valves that may not be practically verified closed using system pressure or flow or full-stroke exercised open with flow per GL 89-04, Position 1. The licensee proposes to full-stroke exercise these valves by sample disassembly, inspection, and a manual exercise. .
The NRC considers valve disassembly ar.d inspection to be a maintenance !
procedure and not a test equivalent to the exercising produced by fluid I flow. This procedure has some risk, which make its routine use as a-substitute for testing undesirable when some method of testing is ,
possible. Disassembly and inspection, to verify the full-stroke open or !
closure capability of check valves is an option only where exercising cannot be practically performed by system pressure, flow, or other positive means. Check valve disassembly is a valuable maintenance tool that can provide much information about a valve's internal condition and as such should be performed under the maintenance program at a frequency commensurate with the valve type and service.
Some test method may be feasible to full-stroke exercise these valves.
The licensee should consider methods such as using non-intrusive techniques (e.g., acoustics, ultrasonics, magnetics, radiography, and thermography) to verify a full-stoke exercise of the subject check valves. This testing may only be practical at CSDs or refueling outages. The licensee should perform their investigation and if a test method is found to be practicable, the IST requirements of the applicable valves should be satisfied by testing instead of disassembly and inspection. If testing is not practicable and disassembly and inspection is used, it must be performed in accordance with GL 89-04, Position 2. The licensee should respond to this concern.
- 7. PV-6 requests relief from the test frequency and stroke time measurement requirements of Section XI for the main steam automatic depressurization system (ADS) valves. The licensee proposes to exercise them during refueling outages and to verify valve operation by observing an indication of steam flow through each valve. Valve stroke times will not be measured. Trending the stroke times for these valves may not be meaningful since test-personnel response times and variations in system parameters could mask changes in valve condition. However, not A-4
. .. a O
monitoring for degradatio1 of these valves is unacceptable. The licensee should develop a method to obtain repeatable stroke times for these valves or propose sonc other method to adequately monitor for valve degradation. Relief should be granted for an interim period of one year or until the next refueling outage, whichever is longer. At the end of the interim period, the licensee should implement a method to monitor for degradation of these valves. (Refer to Section 3.2.2.1 of this report)
- 8. PV-20 requests relief from the leak rate pressure differential direction requirements of Section XI for the listed main steam, HPCI, and RCIC valves. The licensee proposes to leak rate test these valves with differential pressure in the reverse direction during periodic leak testing. These are Category A valves that pet form a containment isolation function. 10 CFR 50, Appendix J, requires that test pressure be applied in the same direction as when the valve would be required to perform its safety function, unless it can be determined that the results from the tests for a pressure applied in a different direction will provide equivalent or more conservative results. GL 89-04 and OM-10 permit testing CIVs in accordance with 9 50, Appendix J. GL 89-04 and the rulemaking of September 8,1992, also prescribe additional requirements for Analysis of Leakage Rates and Corrective Action for CIVs. Therefore, these valves may be tested in accordance with Appendix J and 3s IWV-3426 and -3427(a).
An SE transmitted by a letter from D. G. Eisenhut to H. G. Parris, dated October 24, 1984, determined that an exemption to the Appendix J test direction requirement for these valves is not acceptable because it does not meet the equivalent or more conservative results criteria. The SE concluded that the fact that plant design does not currently permit testing in the direction of accident pressure is not, in itself, sufficient justification for an exemption from the requirements and intent of Appendix J. Approval of a requested deviation from the ASME Code requirements (IST relief request), does not constitute an exemption from the 6 50, Appendix J, requirements. An exemption should be requested and approved for any deviation from the Appendix J requirements. (Refer to Sections 3.10.1.1 of this report)
- 9. PV-25 requests relief from the test frequency requirements of Section XI for the RHR and core spray injection testable check valves. The licensee proposes to full-stroke exercise these valves open using the test operator during CSDs when a drywell entry is made and during refueling outages. PV-25 does not address exercising these valves open with flow. It appears that flow could be established through these valves during CSDs. If testing these valves open with flow is practicable, it should be done during CSDs as required. If this testing is not practicable, the licensee should document the reason in their IST program. (Refer to Sections 3.8.1.1 and 3.9.1.1 of this report)
- 10. PV-18 requests relief from the exercising method and frequency requirements of the Code and proposes to sample disassemble and inspect the subject valves at refueling outages. The subject valves are in series parallel pairs (as shown in Figure 1). They open to break the vacuum caused by steam condensing in the turbine exhaust lines and close A-5
F {
~ l to prevent diversion of exhaust steam into the suppression pool gas space. The systems (HPCI/RCIC) containing these valves are not equipped with test taps or instruments for individually testing them open with flow or closed with reverse differential pressure. However, the l licensee may be able to perform a test to demonstrate that the '
series / parallel pair passes and restricts flow using the installed provisions during refueling outages.
Twise kwh peau Coanguesion
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M E5 L5 mm-W MM m
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- i. - w Figure 1 Series Parallel Check Valve Configuration l
If feasible, these series parallel check valves should be tested for opening and closure as sets at least each refueling outage. If the set ;
fails to allow adequate forward flow or to block reverse flow, then the valves in the set should be declared inoperable and be repaired or replaced as necessary. The licensee should also investigate the i feasibility of testing these valves open and closed using non-intrusive techniques (refer to Item 6 above). The licensee should respond to this concern.
- 11. PV-29 requests relief to disassemble and inspect the listed check valves. GL 89-04 grants relief to use this test method when it is impractical to verify a full-stroke open and/or closed using pressure or ,
fl ow. However, to receive relief; i.his testing must be performed in I accordance with Position 2 of the EL. The licensee's proposed alternate ;
testing implies that a sampling program will be used for these valves. l That approach is allowed by Position 2, however, from a review of the j system prints it appears that these valves would not meet the Position 2 criteria for grouping. The subject valves range in size from two to fourteen inches in diameter and see different service conditions. If the closure of these valves is verified by sample disassembly and inspection, the sample groups, should be determined in accordance with the guidelines of GL 89-04, Position 2, and should be clearly identified in the IST program. The licensee should respond to this concern.
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